The U.S. Department of Health and Human Services Releases Updated Guidance on the Provider Relief Fund (PRF)

On September 24, the U.S. Department of Health and Human Services (HHS) released updated guidance on the Provider Relief Fund (PRF) specifying how recipients should account for coronavirus-related expenses and lost revenue, in addition to new information on reporting requirements for recipients.

Through the Terms and Conditions of the PRF, recipients are required to submit reports to HHS on the use of the PRF funds. The new guidance requires PRF recipients who received one or more payments exceeding $10,000 in aggregate to submit information on their coronavirus general and administrative (G&A) expenses, as well as health-care related expenses that another source has not reimbursed. This new HHS notice further informs PRF recipients of the categories of data elements that recipients must submit for calendar years 2019 and 2020 as part of the reporting process. For recipients of over $500,000 in aggregate PRF payments, additional data elements are required. These data elements in the PRF Reporting System will allow HRS and HHS to assess whether recipients properly used PRF payments, consistent with the Terms & Conditions associated with the payment. Information about the reporting requirements and auditing can be found on the HHS page here.

HHS further defined “lost revenues” as the provider’s lost margin. Any PRF funding not used in full on coronavirus health-care related expenses may be used to offset negative change in year-over-year net patient care operating incoming (i.e. patient care revenues less patient care-related expenses). Recipients that report negative net operating income from patient care in 2019 may apply PRF funding towards lost revenues up to a net zero/gain loss in 2020. Finally, if by the end of calendar year 2020, PRF recipients do not expend their funds in full, they are granted an additional six months to use the remaining amounts.

While deadlines are not affected by the new HHS guidelines, the reporting portal will now be on January 15, 2021 instead of the previously stated October 1, 2020.

ASA reminds members of these important deadlines:

• January 15, 2021: reporting system opens for providers
• February 15, 2021: first reporting deadline for all providers on use of funds
• July 31, 2021: final reporting deadline for providers who did not fully expend PRF funds prior to December 31, 2020

The updated guidance from HHS can be found here. A useful summary document of the reporting requirements can be found here. ASA recommends our members consult with their accountant to ensure proper compliance with the reporting requirements for the PRF listed above.