After months of relative silence and the 6/30/21 deadline to use PRF funds looming, HHS released updated reporting requirements Friday afternoon. There are both new and familiar concepts in the updated reporting guidelines.
Below in our Weekly Insights, we provide as much of the detail as possible and highlight changes we believe are most important to you. We want to provide several of the most important points and questions that arise from these updated program requirements. Keep these in mind as you read the reporting requirements and our weekly insights. In most cases, we will need further clarification from HHS and HRSA.
- Reporting periods have been expanded and parceled into four separate periods. How will lost revenue calculations work under these new reporting periods? Especially if you are using budgeted revenue? These updates remove many of the lost revenue reporting details that were present in the January 15th guidance.
- Reporting begins soon on July 1st; however, only funds received prior to 6/30/2020 are required to be part of this initial reporting period. There is now anywhere from 6-18 more months to use funds you’ve received or will receive later this year. What expenses are your organizations still incurring to prepare, prevent and treat coronavirus now and in the coming year?
- SNF and Nursing Home Infection Control Distribution Payment program is now combined with PRF reporting. Previously these funds were excluded from this reporting. HHS indicates this will be a separate line item of reporting and lost revenues cannot be used to support these payments, only expenses used in COVID-19 testing, reporting, staffing, infection control and other key areas. These expenses will need to be separated from reporting on other General and Targeted Distributions received by SNFs and Nursing Homes.
- There is separate reporting for “Use of General and Other Targeted Distribution Payments” and then right after it “Net Unreimbursed Expenses Attributable to Coronavirus.” Both need to be broken into G&A and Healthcare-related expenses. In previous guidance these were considered the same expenses, only one reported at gross and the other net of other assistance. It’s completely unclear in the instructions if these are the exact same expenses reported at gross and net or if they are separate expenses.
PRF Reporting Periods and Other Updates
Here are summaries of the major points from the new reporting guidelines.
PRF Reporting Periods
The two reporting periods of CY2020 and 1/1/21 – 6/30/21 are gone. Replacing it are 4 separate reporting periods based on the actual date payments were received (date of the ACH deposit). HHS provided several tables and we’ve included Table 3 which is the combination of all 3 tables.
Current reporting begins on July 1st and runs through 9/30/21, but is only for payments received from April 10, 2020 – June 30, 2020.
Aggregation rules of payments have changed
Previously if you received aggregated payments > $10,000 you had to report. Now reporting is required if you had aggregated payments of $10,000 or more in the specific payment periods.
Early on in the pandemic funds were not released evenly and many of you may not have crossed the $10,000 threshold in reporting period 1, but then received large payments in reporting period 2. Under that scenario, you may not have to report right away AND can continue to expend those funds until 12/31/21.
Responsibility of Reporting
HHS continues to offer a matrix of the type of PRF recipients and definitions. A key matter of emphasis is that a parent entity may report on their subsidiaries’ General Distribution payments regardless of who received the payment. But the original recipient of a Targeted Distribution payment cannot be reported on by the parent entity. Remember that the parent and child entities are for organizations that have multiple TINs.
Data Elements required for reporting
Below are the 12 data elements along with key points. The language is inconsistent but most elements need to be reported quarterly through the current period of availability.
Many require quarterly reporting for CY 2019 as well.
- Reporting Entity Overview – Tax ID number, DBA, Address, contact and other basic information.
- Subsidiary Questionnaire – assists entities in identifying subsidiary TIN’s that fall under the parent TIN that is reporting as well as any targeted distribution payments transferred to/by a parent entity.
- Acquired/Divested Subsidiaries – if applicable, list of TINs that were acquired or divested during the period of availability. HRSA also asks that you self-report these transactions through their Provider Support Line.
- Interest Earned on PRF Payments – separate entries for interest earned on PRF payments AND interest earned on SNF and Nursing Home Infection Control Distribution payments.
- Tax and Single Audit Information – various tax identification and classification information. Status of Single Audit requirements during 2019 through current fiscal years and whether PRF payments are included in the Single Audit.
- Other Assistance Received – Treasury or SBA loans such as PPP loans, funds from FEMA, HHS CARES Act testing, State, Local and Tribal Government assistance, Business interruption insurance payments and any other assistance received. Reported by quarter during the period of availability.
- Use of SNF and Nursing Home Infection Control Distribution payments – expenses used in nursing homes for COVID-19 testing or reporting to local governments, improving infection control and other expenses. Expenses need to be reported by G&A and Healthcare-related expenses and if payments were > $500,000 reported into further sub-categories. Lost Revenues cannot be used for these funds.
- Use of General and Other Targeted Distribution Payments – these would be the “COVID-19 Expenses” used to prepare, prevent and treat COVID-19 that you are familiar with. Expenses reported between G&A and Healthcare-related expenses and if payments were > $500,000 reported into further sub-categories.
- Net Unreimbursed Expenses Attributable to Coronavirus – these seem to be the same expenses reported in #8 but after accounting for any reimbursement or other assistance related to those expenses. It is unclear if the baseline expenses differ from #8 or if it’s another subset of COVID expenses.
- Lost Revenues attributable to Coronavirus – reported quarterly and by payer mix (Medicare Part A & B, Medicare Advantage, Medicaid/CHIP, Commercial, Self Pay, Other) for the entire period of availability. 3 options for lost revenue calculations are the same by comparing to actual, budget or any reasonable method. HHS has removed a lot of the detail of the calculations and it’s unclear if this is now lost revenues from January 1, 2020 – June 30, 2020 or a quarterly comparison or some other measurement. It’s also unclear how budgeted revenues will work as the measurement periods go further into the future as budgets had to be approved by March 27, 2020.
- Personnel, Patient and Facility Metrics – reported by quarter for CY 2019 through current period of availability and include number of clinical and non-clinical personnel by categories such as FT, PT, contract, furloughed, separated and hired. Patient and facility metrics are required too, including IP admissions, OP visits both in-person and virtual, ED visits, staffed beds by unit.
- Survey Section – this seems more open ended and asks for answers to a number of questions regarding how funds were used in hiring, overall operations, prevention of bankruptcy, impact on patient services and assistance in changes needed to operate during the pandemic.
- Continue to collect, analyze and accumulate your COVID-19 costs incurred to prepare, prevent, and respond to COVID-19. Use the new guidelines and date of your PRF payments to determine how much more time you have to spend these funds into the remainder of 2021 and 2022.
- The phrase “Period of Availability” and extended reporting timeline appears to add a twist to the lost revenues calculation. Whether wholesale changes occur or not, continue on with your current calculations but be ready to perform additional analysis as new details emerge.
- If you own or operate a Skilled Nursing Facility, the inclusion of the Infection Control Distribution payments means there is an added reporting burden required in PRF reporting. Ensure you have detailed costs for these funds and that those costs are not included in your PRF payment support as it would be considered double-dipping of funds.
- Finally, join us this week for a webinar where we will discuss these issues and more and give you updates as we continue to learn more about the changes from HHS.
June PRF Update On-Demand Webinar
Fill out the form below to download the resources from the webinar.
Even if you haven’t started yet, it’s not too late.