All providers subject to this guidance are required to submit certain demographic information, such as an entity’s tax identification number and fiscal year-end date, among other information. Additionally, these providers also must report total revenue on a quarterly basis for the comparison years covering all types of payers, and other federal, state and local assistance received. Finally, these providers must report three non-financial metrics and details if a change of ownership occurs.
- 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
Providers that received $500,000 or more must report more specific information about the additional expenses incurred, such as mortgage/rent, personnel, supplies and equipment. Those that received $750,000 or more in 2020 aggregate federal assistance from any source must attest that they are subject to federal single audit requirements and provide additional information.
In a recent letter to HHS Secretary Alex Azar, ASCA raised concerns with the reporting requirements with regard to the following:
- Reporting Threshold: $10,000 is a low threshold for requiring reporting and places an administrative burden on smaller providers;
- Expenses or Lost Revenue: The terms and conditions documents for all PRF general distributions state that the payments be used for healthcare-related expenses or lost revenues that are attributable to coronavirus. However, the reporting requirements indicate that providers must submit data on both, regardless of whether they spent more than they received through the PRF on expenses alone. If a provider can show all PRF funds were used on healthcare-related expenses attributable to coronavirus, that provider should not have to submit the financial information in the lost revenue section;
- Lost revenue definition: While the reporting requirements mandate a year-over-year comparison between 2019 and 2020, previous references to lost revenue indicated that March and April 2019 revenue would be compared to March and April 2020 revenue. Focusing just on March and April provides the most accurate picture of revenue lost due to COVID-19 and allows facilities to show how that funding was used to ensure they would be financially able to reopen.
Preceding last month’s notice, HHS released General and Targeted Distribution Post-Payment Notice of Reporting Requirements, announcing that all recipients of one or more payments exceeding $10,000 in the aggregate from the PRF would be subject to future reporting requirements. The announcement indicated that detailed instructions were forthcoming.
ASCA will update its members if the administration makes changes to the reporting requirements as a result of ASCA’s advocacy and the advocacy of other healthcare providers.
Additional reporting requirements may also be announced in the future. The US Health Resources and Services Administration (HRSA) plans to offer question & answer sessions via a webinar in advance of the reporting deadline and, as needed, HRSA also will issue frequently asked questions to aid in the reporting process. Stay tuned to ASCA publications for more information.