Provider Relief Funds Update

Last week HHS updated their FAQ’s for the first time in almost a month. We did learn that the period to incur COVID-19 expenses and lost revenues is still set to end on 6/30/21 and there was no mention of an extended time period. For now, HHS is moving ahead with having a total of two reporting periods: one for calendar year 2020 and one for the first six months of 2021.

Weekly Insights

While the FAQs were primarily modified answers to past questions, there were several important updates and themes that were presented in this recent update.

1. No extension of the reporting period past 6/30/21 was granted. HHS will continue with the current standard that the opportunity to incur lost revenues and COVID-19 expenses ends on 6/30/21. We will be coming up to the end of the current Public Health Emergency period soon and changes to that may later impact reporting on PRF, but for now the end date for PRF is still 6/30/21.
2. For Hospitals that receive Medicaid DSH, a previous FAQ indicating Medicaid DSH needs to be applied to COVID-19 expenses related to uncompensated care was removed and no longer appears in the FAQs.
3. A variation on the phrase “…provided that those expenses or losses have not been reimbursed from other sources and other sources were not obligated to reimburse them” was added to the end of numerous FAQs adding further explanation as to how PRF funds can be used.

This last point is another example of HHS continuing to emphasize that PRF funds are considered the payer of last resort and that all reimbursement, payments, grants and federal programs need to be used to reduce COVID-19 expenses when that revenue is tied to the expenses your organization is accumulating.

We recommend you continue to look at your COVID-19 expenses that you’ve accumulated for reporting and consider all aspects of payments or grants that may relate to those expenses prior to using PRF funds.

These types of revenue are also frequently referred to as “Other Assistance” and several examples from HHS include:

• Payments made on COVID-19 patients accounts from commercial insurance, Medicare, Medicaid, CHIP, etc
• Funds received from FEMA
• Provider Relief COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured
• SBA and Treasury’s Paycheck Protection Program (PPP) loans
• State and local grants and assistance for healthcare related expenses
• Business interruption insurance proceeds
• Interest earned from holding PRF payments

Please continue to accumulate your PRF expenses and lost revenues while we wait for the reporting portal to open. Remember, if you’ve received more than $10,000 from the PRF you will be required to login and report on your healthcare expenses and lost revenues.

Even if you haven’t started yet, it’s not too late. Please contact your local Blue & Co. representative or Michael Alessandrini for more information on provider relief funds and we can help you get ready for the reporting period.

Download a pdf version of this provider relief funds update blog post here.