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HHS Releases Reporting Requirements for Provider Relief Fund Recipients

What ASCs need to know

BY KARA NEWBURY | OCTOBER 2020

Last month, the US Department of Health & Human Services (HHS) published the Post-Payment Notice of Reporting Requirements and a summary of reporting requirements for Provider Relief Fund (PRF) recipients. The notice specifies the information that providers must submit.

The Trump administration created the PRF under the Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020, which allocated $100 billion for healthcare providers to make up for lost revenue or support additional costs that are attributable to the coronavirus.

When the first round of funding—$30 billion—went out beginning on April 10, the terms and conditions that providers had to attest to to keep the funds were vague. For reporting requirements, it simply stated “The Recipient shall submit reports as the Secretary determines are needed to ensure compliance with conditions that are imposed on this Payment, and such reports shall be in such form, with such content, as specified by the Secretary in future program instructions directed to all Recipients.” The summary of reporting requirements published last month clarifies matters and covers two categories.

The first category includes healthcare-related expenses attributable to coronavirus that a provider incurred. This is net of other reimbursed sources, like payments received from third-party payers or patients. Healthcare-related expenses attributable to COVID-19 include the purchase of supplies, such as personal protective equipment (PPE), hand sanitizer or supplies for patient screening. Expenses attributable to COVID-19 also includes those incurred in both direct patient care overhead activities related to maintaining healthcare delivery capacity, which includes operating and maintaining facilities.

The second category includes lost revenues attributable to COVID-19. To calculate this amount, the agency is using a year-over-year comparison of actual 2019 and 2020 revenue information and includes in the calculation the PRF payment for additional expenses outlined above.

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.

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.