Provider Relief Fund – Time Is Running Out
Claire Hilleary, CPA, MBA | September 7, 2021
Time is running out for healthcare providers who received Provider Relief Funds (PRF) to submit use of funding reports in the first reporting deadline—which looms heavy on the horizon as September 30, 2021 quickly approaches. Providers who received the funding in excess of $10,000 during the first half of 2020 are required to submit their report during this first period. Additional reporting submissions may be required if additional PRF payments were received subsequent to June 30, 2020 in excess of $10,000.
However, many are still grappling with questions related to what expenses or lost revenue calculations need to be reported given the shifting guidance. Below, we touch upon a few of the more recent common questions that REDW advisors have been asked:
Are expenses related to securing and maintaining adequate personnel reimbursable expenses under the PRF?
Yes – The Health Resources & Services Administration (HRSA) FAQs state “expenses incurred by providers to secure and maintain adequate personnel, such as offering hiring bonuses and retention payments, child care, transportation, and temporary housing, are deemed to be COVID-19-related expenses if the activity generating the expense was newly incurred after the declaration of the Public Health Emergency and the expenses were necessary to secure and maintain adequate personnel.”
Can providers elect to use their calculation of Lost Revenues as their qualifying source without consideration of qualified expenses unreimbursed by other sources?
Yes –The HRSA updated their FAQs on July 1, 2021 to indicate it is possible for providers to enter a “0” value related to the unreimbursed expenses attributable to coronavirus in the reporting portal.
If providers use all funds received to cover unreimbursed healthcare related expenses attributable to coronavirus, do they still need to submit lost revenue information?
Yes – Providers will still need to submit actual patient care revenue for calendar years 2019 and 2020 within the reporting portal by quarter.
Will reporting extensions on submission of the required reports be allowed?
No – Per the HRSA FAQs, “Providers that received one or more payments exceeding $10,000, in the aggregate, during a Payment Received Period are required to report in each applicable Reporting Time Period. Providers that are required to report and do not submit a completed report by the applicable deadlines will be deemed out of compliance with the program Terms and Conditions and may be subject to recoupment.”
On August 24, 2021 the Medical Group Management Association (MGMA) submitted a letter to Health and Human Services (HHS) asking to delay the deadline until at least March 31, 2023, regardless of when funds were received, citing the sharp increase in COVID-19 cases coupled with the onerous reporting requirements of the program; however, no responses to this request have been made and it is uncertain if HHS will consider any additional delays.
Read the letter, here.
Are any additional funds from the PRF program expected to be released?
Yes, but the timing is uncertain. Congress has appropriated a total of $178 billion for the PRF program and an additional $8.5 billion for rural health programs; however, the Government Accountability Office (GAO) indicated that about 25% of the PRF appropriations and all of the rural provider funding remained unobligated as of May 31, 2021. In response, a group of 40 United States senators signed a bipartisan letter to HHS, dated August 26, 2021, asking for the remaining funding to be disbursed without further delay to help providers respond to the ongoing pandemic needs. To date, no response has been provided offering insight into the timing of these additional disbursements.
Read the letter, here.
We Welcome Your Provider Relief Fund Reporting Questions
REDW’s trusted advisors are currently helping healthcare clients meet reporting requirements and deadlines, and we will continue to update and inform as new guidance or issues emerge. Contact REDW Audit and Consulting Senior Manager Claire Hilleary, or Principal Chris Tyhurst for questions about PRF reporting or other related concerns.