On January 15, the Department of Health and Human Services (HHS) postponed the first deadline for providers to report on how they used their Provider Relief Fund (PRF) funding. This deadline had been set for Feb. 15, 2021; HHS has yet to set a new deadline. HHS also issued updated PRF reporting requirements, which supersede all previous versions. The most significant update is the option to define “lost income” using “any reasonable method. These and other deadlines/requirements around federal COVID-19 funding are available on the NACHC COVID-19 “mega-spreadsheet”. Some highlights of the updated PRF reporting requirements:
- PRF funds must be spent to cover unreimbursed COVID-related expenses before they can be allocated to lost revenues.
- The definition of “COVID-19 related expenses” continues to be broad, and can include mortgage payments, HIT systems, utilities, etc.
- For CY 2020, providers can define “lost revenues” in one of three ways:
- Difference between CY2019 and CY2020 actual patient care revenue
- Difference between 2020 budgeted and 2020 actual patient care revenue. Providers who use this approach must provide evidence and attestation that their budgeted revenue was determined prior to March 27, 2020.
- Using “any reasonable method of estimating revenue.” Providers using this approach must describe their methodology, explain why it is reasonable, and demonstrate that the lost revenues were due to COVID-19. HHS explicitly states that providers using this approach are more likely to be audited.
- For CY 2021, providers are not permitted to calculate lost revenues using “any reasonable method.” Rather, Jan-June 2021 actual revenue must be compared to 2019 actual revenue or 2020 budgeted revenue for the same 6-month period.
As in previous versions of the reporting requirements, providers receiving over $500,000 in PRF funding must report their expenses in greater detail than those receiving less than $500,000. If a provider earned interest in PRF payments, they must provide information on that interest and how it was used.