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New Changes to Lost Revenues Calculation

Two important events happened this past Friday morning regarding the Provider Relief Fund.

First, the reporting portal did not open as previously announced and providers do not need to begin reporting on the use of their funds yet.

Second, additional reporting requirements and documents were released by HHS to incorporate the December 22, 2020 COVID Relief Bill updates with a focus on changes to the lost revenues calculation.

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Expanded definitions on lost revenues calculations were provided and HHS has offered three choices. We’ve also included the full reporting requirements from HHS below.

Option 1 – Report on calendar year 2020 actual patient revenue vs 2019 actual patient revenue

Option 2 – Report on calendar year 2020 actual patient revenue vs 2020 budgeted revenue. The budget must have been approved by March 27, 2020 and provided to HHS. Additionally, the CEO or CFO must sign an attestation “that the exact budget being submitted was established and approved prior to March 27, 2020.”

Option 3 – An alternate methodology using “any reasonable method of estimating revenue” may be used. Detailed descriptions of the methodology used and why the methodology is reasonable are required. Additionally, an explanation of why the methodology is reasonable, and establish how the identified lost revenues were in fact a loss attributable to coronavirus, as opposed to another source.

Finally, in the reporting requirements, HHS mentions that any provider using option 3 will be under increased likelihood of an audit and they will review if the alternate method is reasonable. If your organization is considering using the “any reasonable method” for calculation lost revenues, we recommend you prepare all three calculations and be prepared for a detailed review by HHS.

To download this blog post as a pdf, click here. To read more about what HHS has recently put out: HHS Provider Post Payment Notice of Reporting Requirements.

Got questions? Join us for our Provider Relief Fund Weekly Webinar Series.

Join us on Thursday, January 21, we will be hosting a webinar from noon to 1 p.m. EST to go over the recent reporting changes from HHS, provide any update on the reporting portal that we have, and answer any of your questions submitted through the registration page form. Click here to register for this event.

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