With the closing of Period 1 and Period 2 reporting for the Provider Relief Fund (PRF), and Period 3 reporting on the horizon, there are many lessons learned that can be useful for those with future reporting responsibilities. This guidance also applies to those who have received the American Rescue Plan (ARP) Rural Distribution.
The Provider Relief Fund (PRF) was a unique program with many conditions clarified and/or modified over the course of a year and a half. With the various options to qualify the funds received, we have seen a diversity in application, further compounding the various compliance challenges. Below are a few things to keep in mind.
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Lessons Learned in PRF Reporting:
- Any expenses used in previous reporting periods should not be reported in future reporting periods. Specifically, the PRF Reporting Period 2 fact sheet states “Provider Relief Fund payments may be applied to expenses and lost revenues attributable to coronavirus according to the Period of Availability of funding. However, expenses and lost revenues may not be duplicated: payments may not be applied to the same expenses and lost revenues that were reported on in prior reporting periods.”
- Lost revenue calculations must be supported by underlying system documentation. While an Excel spreadsheet or other data gathering software can be used to accumulate and sort data into the format needed for reporting presentation, it is essential to retain the source reports to ensure balances can be properly verified and supported. This is especially critical for any billing systems unable to reproduce point-in-time source reports.
- Providers can opt to use a different lost revenues calculation methodology for the various periods. However, due to the overlapping periods of availability, the reporting system will recalculate the lost revenues for the entire period of availability. The PRF Frequently Asked Questions dated April 6, 2022, states “if a Reporting Entity changes the method used to calculate lost revenues, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues. The system will also require that the Reporting Entity submit a written justification to support and explain the change in lost revenues methodology.”
- Providers must be mindful to carefully review reported expenses. Expenses must be used in the service to prevent, prepare for and respond to coronavirus and cannot be reimbursed from other sources. Expenses may include those incurred expenses necessary to maintain health care delivery capacity by the recipient or to increase health care delivery capacity in the future as informed by community health needs. This may include outreach and education about the vaccine for the provider’s staff, as well as the general public.
These are just a few considerations we have encountered in our auditing of the PRF program, and there are sure to be other challenges ahead. Period 3 reporting is set to open July 1, 2022 and remain open through September 30, 2022. For more information, refer to the most up-to-date Frequently Asked Questions.
REDW advisors are here to assist and be your trusted resource. Please reach out to me, Claire Hilleary, CPA, below or at 505.998.3458 if you have any questions.
