The US Department of Health and Human Services (HHS) released new information and terms for Provider Relief Fund (PRF) recipients. The notification, General and Targeted Distribution Post-Payment Notice of Reporting Requirements, for providers who received one or more PRF payments exceeding $10,000, describes the data that will be required as part of the post-payment reporting process. This is a supporting document to the July 20 Post-Payment Notice of Reporting Requirements.
According to the American Orthotic & Prosthetic Association (AOPA), the $10,000 reporting threshold is a notable change from the statutory requirement in Section 15011 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Provider Relief Fund Terms and Conditions, which had required recipients of more than $150,000 in total funds appropriated under the CARES Act to submit a report to HHS within ten days following the end of each calendar quarter. AOPA said it expects further guidance on the issue.
Recipients will report their use of PRF payments by submitting the following information:
1.     Healthcare related expenses attributable to coronavirus that another source has not reimbursed and is not obligated to reimburse, which may include General and Administrative (G&A) or healthcare related operating expenses (further defined within the data elements section below).
2.     PRF payment amounts not fully expended on healthcare related expenses attributable to coronavirus are then applied to lost revenues, represented as a negative change in year-over-year net patient care operating income (i.e., patient care revenue less patient care related expenses for the Reporting Entity, defined below, that received funding), net of the healthcare related expenses attributable to coronavirus calculated under step 1. Recipients may apply PRF payments toward lost revenue, up to the amount of their 2019 net gain from healthcare related sources. Recipients that reported negative net operating income from patient care in 2019 may apply PRF amounts to lost revenues up to a net zero gain/loss in 2020.
If recipients do not expend PRF funds in full by the end of calendar year 2020, they will have an additional six months in which to use remaining amounts toward expenses attributable to coronavirus but not reimbursed by other sources, or to apply toward lost revenues in an amount not to exceed the 2019 net gain. For example, the reporting period January-June 2021 will be compared to the same period in 2019.
AOPA believes that HHS may have provided the clarification “in an amount not to exceed the 2019 net gain” because, under previous guidance, if lost revenues could be applied to expenses irrespective of the impact on margin, it would have introduced the possibility of PRF funding making a healthcare provider more profitable in 2020 than it was in 2019. AOPA said it is concerned about the potential impact of this approach for some providers and will continue to monitor the issue.
Under the new guidance, recipients will be required to report several data elements, including demographic information, information about expenses attributable to coronavirus, information about lost revenues, and non-financial information such as metrics on personnel, patients, and facilities.
Recipients that received between $10,000 and $499,999 in aggregated PRF payments must report healthcare-related expenses attributable to coronavirus in two categories: general and administrative expenses and  other healthcare-related expenses. Providers receiving $500,000 or more in PRF payments will report their expenses in greater detail within each of these categories.
To read the document, visit the General and Targeted Distribution Post-Payment Notice of Reporting Requirements on the HHS website.
To read the July 20 document, visit the HHS website.
