Provider Relief Fund Reporting Details Released
RHCs Must Use Most PRF Funds by June 30, 2021
Sarah Hohman, NARHC Government Affairs Associate
**Provider Relief Fund Portal Now Open**
On July 1, 2021, the Provider Relief Fund (PRF) reporting portal opened. Visit HHS.gov for resources, additional information, and to access the portal.
Original article 06/21/2021:
On June 11, 2021, the Department of Health and Human Services (HHS) released new guidance on the Provider Relief Fund (PRF) with the most detailed explanation of the reporting and auditing requirements to date.
In recent months, efforts were made by organizations including the AHA, as well as Members of Congress to extend the deadline to use PRF funds beyond June 30th. While HHS did opt to delay some deadlines, the June 30th deadline is still holding for PRF funds received in the first few months of the pandemic.
To be clear, recipients will need to “use” the PRF money they received between April 10, 2020, and June 30, 2020 (Period 1), by June 30, 2021. Therefore, the majority of funding that Rural Health Clinics (RHCs) received must be “used” by this June 30th, 2021, deadline.
However, HHS did extend the deadline for PRF payments that were made later in the pandemic. For instance, PRF payments received in the second half of 2020 (Period 2), must be “used” by the end of this year.
We are seeking additional clarification regarding precisely what “use by June 30th” means as we approach this deadline; however, it may be in your best interest to ensure that you have allocated funding to unreimbursed expenses and lost revenues for the relevant time period prior to this date. For instance, if you have kept your PRF funding in a separate account, waiting for clarification before allocating it to an appropriate expense, you may want to make the allocation this month, so you have “used” the money before July 1st.
The deadlines for using funds and reporting for each “payment period,” based on when the PRF funding was received by recipients are:
Recipients are required to report for each payment period in which they received one or more payments exceeding a total of $10,000 (rather than $10,000 in total across all PRF payments). For example, if you received funding of $10,000 or more as part of the COVID-19 High-Impact Distribution in July, you will be required to report an additional time in the portal during the relevant time period depicted above.
Notably for our community, these reporting requirements are separate from the Rural Health Clinic COVID-19 Testing Program and the RHC COVID-19 Testing and Mitigation Program reporting done on https://www.rhccovidreporting.com. However, we expect that these payments will need to be listed as “other assistance received” within the PRF Reporting Portal.
While we recommend that you review the official HHS guidance and other related documents fully yourself, we have tried to compile the key aspects for RHCs below.
Key Points from PRF Guidance
Important considerations to note when determining appropriate use and reporting of Provider Relief Funding, explained in more detail below, include:
- PRF should be used as a last resort following all other relief funding received
- All expenses attributed to PRF cannot be eligible for reimbursement through any other source
- Unreimbursed expenses must be the first use of this funding, prior to using it to cover lost revenue
Returning Unused Funds
- If your organization is unable to use some or all of the funding by the relevant deadline, you will be able to return funds through the PRF Reporting Portal once the applicable reporting window opens.
- The reporting portal will open on July 1; providers are encouraged to register in the portal in advance of the relevant Reporting Time Period dates.
- Duplication of expenses and lost revenues is not permitted. All recipients are subject to audit.
- For the purposes of registration and reporting, the Reporting Entity is the entity that registers its Tax Identification Number (TIN) and reports on payments received by that TIN and/or its subsidiary TINs.
- Reporting entities should use their normal basis of accounting: (e.g., cash, accrual, or modified accrual).
- When determining expenses, PRF funds are to be considered the “last resort” payment following other funding sources eligible for reimbursement (Paycheck Protection Program, FEMA, CARES Act, Local, State, and Tribal Government Assistance, Business Insurance, and other).
- The PRF Reporting Portal will also require recipients to enter other assistance received by quarter during the period of availability to assess use of funds. This list is available on page 7 of the guidance document.
- The reporting portal includes requirements to report personnel, patient, and facility metrics as well as a survey on the impact of payments. More information on the metrics and survey can be found on page 11 of the guidance document.
- Organizations that expend $750,000 or more in annual awards require a single audit.
- Reporting entities that received $10,001-$499,999 in aggregated PRF payments in a single payment received period must report under the categories of (1) General and Administrative and (2) Health Care-Related Expenses. If entities received $500,000 or more in aggregated payments they must report with additional sub-categories, which can be found in the Post-Payment Notice of Reporting Requirements.
Reimbursement for Expenses
- Allowable expenses under the PRF are the Net Unreimbursed Expenses used to prevent, prepare for and respond to coronavirus. Providers must obtain appropriate records and cost documentation for all expenses and retain original documentation for three years. Costs must be tangible and not opportunity costs.
- An organization should first determine their expenses attributable to coronavirus, such as supplies, equipment, information technology, facilities, personnel, and other health care-related costs/expenses for the period of availability, and then offset any amounts received through other sources, such as direct patient billing, commercial insurance, Medicare/Medicaid/Children’s Health Insurance Program (CHIP); other funds received from the federal government, including the Federal Emergency Management Agency (FEMA); the Provider Relief Fund COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured (Uninsured Program); the COVID-19 Coverage Assistance Fund (CAF); and the Small Business Administration (SBA) and Department of the Treasury’s Paycheck Protection Program (PPP). Provider Relief Fund payments may be applied to the remaining expenses or costs, after netting the other funds received or obligated to be received which offset those expenses.
- Expenses for capital facilities projects may be fully expensed only when the project was directly related to preventing, preparing for and responding to the coronavirus such as upgrading an HVAC system, retrofitting a COVID-19 unit, etc.
- PRF recipients may use payments for eligible expenses incurred prior to receipt of those payments (i.e. pre-award costs) so long as they are to prevent, prepare for, and respond to coronavirus; however, the end date of the payment received period is a strict deadline for use of funds.
- Taxes on Provider Relief Fund payments are “healthcare related expenses attributable to coronavirus” and considered reimbursable with this funding.
Lost Revenues Reimbursement
- Recipients may choose to apply PRF payments toward lost revenues using one of three options and appropriate documentation for each will be required:
- The difference between actual patient care revenues in the quarters before COVID (2019 or Q1 2020*) and the actual patient care revenues in the quarters during COVID;
- The difference between budgeted (prior to March 27, 2020) and actual patient care revenues - To be considered an approved budget, the budget must have been ratified, certified, or adopted by the Reporting Entity’s financial executive or executive officer as of that date, and the Reporting Entity will be required to attest that the budget was established and approved on or before March 26, 2020.
- Calculated by any reasonable method of estimating revenues.
* It is unclear which quarters can be compared for option 1*
- HHS has updated FAQs regarding PRF use and reporting which we recommend you review for further clarification on the newly released guidance.
- HRSA will hold webinars for Reporting Entities which will include opportunities for question and answer sessions. HRSA will also update and issue additional Frequently Asked Questions and a detailed PRF Reporting Portal User Guide when the portal opens.
NARHC will also continue to provide technical assistance, specifically in navigating the PRF Reporting Portal when it opens July 1. We understand that this guidance may be overwhelming for some of you and that the June 30, 2021 deadline is quickly approaching. However, as always NARHC is here to help you report on the funding you received. Please make sure you stay up to date on key RHC news by checking NARHC.org for updates.