The past few weeks have continued to be slow with very little new information on the Provider Relief Fund (PRF) reporting requirements. HHS released four new FAQs on 2/24/21 surrounding COVID-19 expense reporting. The theme among these FAQs is that HHS expects PRF payments to be used for unreimbursed costs and that when claiming COVID-19 costs, every funding source for that cost needs to be accounted for first.
Weekly Insights: COVID-19 Expense Reporting
This is a good opportunity to go back and look at what information HHS has provided so far for identifying COVID-19 expenses. As this week’s FAQs emphasize COVID-19 expenses need to be reported net of reimbursement from any other source. That means payments received from COVID-19 patients, grants, state subsidies, cost-reimbursement payments and interest received from holding PRF payments.
With continued emphasis on reporting unreimbursed COVID-19 expenses, we recommend you spend this week reviewing your current COVID-19 expense calculations and asking the following questions:
- What funds or grants did I receive in 2020 specific to COVID-19?
- If those funds were for a specific purpose, did I include the expenses in my overall listing of COVID-19 expense?
- What did we spend, in both dollars and time, for our organization to prevent the spread of COVID-19?
- What expenses did I incur under General and Administrative expenses that I have not yet accumulated?
- What inputs to running the organization and keeping healthcare capacity open and serving COVID-19 patients have we not yet looked at?
All of these questions are important as you refine your COVID-19 expense lists and other reimbursed sources. For expenses, go through all your departments and look at how they supported COVID-19 and where their operations changed during 2020 “to prevent, prepare for and respond to Coronavirus.”
COVID-19 Expense Categories
While we have very limited definitions, we encourage you to think through your organization’s operations in 2020 to determine what costs can be included in these categories that were used to prevent, prepare for and respond to COVID-19:
General and Administrative Expenses Attributable to COVID-19
- Fringe Benefits
- Lease Payments
- Other General and Administrative Expenses
Healthcare Related Expenses Attributable to COVID-19
- Information Technology
- Other Healthcare Expenses
A final note to our Hospital clients:
One of the FAQ’s this week revolves around including Medicaid DSH payments as a source of reimbursement against your COVID-19 expenses. Every state makes Medicaid DSH payments under a different allocation, timeline, and eligibility requirement.
At this time, we recommend you see what you were paid in 2020 and what, if any, of your COVID-19 patients/expenses relate to the payments and underlying allocations.