On July 20th, HRSA hosted a Reporting Technical Assistance Session regarding the Provider Relief Funds Portal. A few members of the Blue & Co. team attended this online session and took away some key pieces of information that will hopefully provide some guidance to your organization as you work your way through the provider relief funds portal.
Update on Period of Availability
As a general reminder, all of the reporting surrounding provider relief funds is based on the date the payment was received. Also, HHS did confirm that providers cannot report multiple periods at one time. If the reporting is not done in a timely manner, the provider (your organization) will be deemed noncompliant, and funds could be recouped.
The period of availability overlaps for each reporting period, and it is important to note that all periods of availability go back to 01/01/2020. There will be no extension on use of funds granted beyond period of availability. The unused funds are due within 30 days after the end of the reporting time period.
Other Key Takeaways
- Lost revenues/excess expenses can be carried forward towards future periods of availability. All lost revenues/expenses should be entered into the first reporting period. Any excess that wasn’t utilized can be input into future period of availability periods. This will not be done automatically by the portal, you will need to enter the information.
- HHS did clarify that construction contracts can only be claimed for projects that were completed during the period of availability, not just for those contracts signed.
- If expenses less other assistance received are higher than payments received during reporting period, the portal will only require totals for 2019 and 2020 calendar year actual net patient revenues.
- Updated guidance was put out last week that confirmed provider relief funds will not be required to be on the schedule of expenditures of federal awards for any fiscal year ends prior to June 30, 2021. Previously the date was December 31, 2020. This will significantly reduce the number of single audits required for dates before June 30, 2021. Single audits will still be required if your organization had over $750,000 in other federal expenditures during your fiscal year.
- The presenter did confirm you can put $0 for expenses if you have enough lost revenue to cover what you received. However, there is no guarantee that any expense amounts entered will not be used for future funding.
Update on Calculating Lost Revenues
When it comes to calculating lost revenues, you only need to upload supporting documentation to the reporting portal if you are using option II or III. No supporting documentation is required for reporting expenses or using option I (actual to actual) to calculate lost revenues. If you choose option III for lost revenues and HRSA does not deem it reasonable, you have 30 days once you receive notification from HRSA to resubmit using option I or II.
Quick Note about Supporting Documentation:
- Your organization must maintain the documentation for 3 years after you submit the report for audit purposes. The burden of proof of expenses/lost revenues falls on the provider.
- Lack of documentation during an audit will be grounds for payback.
Providers need to make sure not to double-dip and reduce expenses/lost revenues in future periods by amounts already claimed in a previous reporting period.
Here are Two Examples:
If you had one quarter of lost revenue that was more than what you needed, the presenter from this session recommended doing option III and just noting this in the narrative. Otherwise, you will need to input information for all quarters using option I or II and that information is auditable. Either way is fine but utilizing option III in this circumstance can save some time.
If your organization needs assistance with the Provider Relief Funds Portal, please reach out to your local Blue & Co. Advisor or reach out to one of our team members below.
Michael Alessandrini, Director
Peter Szostak, Senior Manager
Greg Heitkamp, Senior Manager
Mark Daffer, Manager