On Friday, June 11, 2021, the Department of Health and Human Services issued updated reporting requirements for the HHS PRF (Provider Reliefs Funds). The Reporting Portal will be open on July 1, 2021. Please see the various charts below, for the final due date of reporting and the uses of the HHS PRF funds. Most of our clients received their funds between July 1, 2020 and December 31, 2020, so your reporting must take place between January 1, 2022 and March 31, 2022 AND you must use the funds by December 31, 2021 (extended from June 30, 2021). Please confirm your individual situation with the chart below.
It is our understanding if your HHS Funds were less than $10,000, there will be no HHS reporting requirements.
You can use your HHS PRF funds for any of the following:
Use of General and Other Targeted Distribution Payments
Your Practice will report on expenses paid for with payments received through the General and Targeted Distribution payments. Expenses must be those that another source has not reimbursed and is not obligated to reimburse. Expense categories will include General and Administrative and/or other Health Care-Related Expenses by current year quarter. Unreimbursed expenses attributable to coronavirus are considered first in the overall use of funds calculation.
Examples of Expenses:
- Mortgage / Rent – Payments related to mortgage or rent for facility specifically for infection control
- Insurance – Premiums paid for property, malpractice, business insurance, or other insurance relevant to operations for infection control
- Personnel Workforce – related actual expenses paid to prevent, prepare for, or respond to coronavirus during the reporting period, such as workforce training, staffing, temporary employee or contractor payroll, overhead employees, or security personnel
- Fringe Benefits – Extra benefits supplementing an employee’s salary, which may include hazard pay, travel reimbursement, and employee health insurance
- Lease Payments – New equipment or software leases, such as dental equipment that is not purchased and will be returned to the owner
- Utilities / Operations – Lighting, cooling/ventilation, cleaning or additional third-party vendor services not included in the “Personnel” sub-category above
- Other General and Administrative Expenses – Expenses not captured above that are generally considered part of general and administrative expenses.
For further information, click here > https://www.hhs.gov/sites/default/files/provider-post-payment-notice-of-reporting-requirements-june-2021.pdf
Net Unreimbursed Expenses Attributable to Coronavirus
The Practice will report on unreimbursed expenses attributable to coronavirus (net after other assistance received and PRF payments are applied) by quarter for the period of availability, broken out as General and Administrative and/or other Health Care-Related Expenses, as follows:
- Supplies – examples are – cleaning supplies, office supplies, PPE, sanitizer, etc.
- Equipment – used for infection control – examples are – such as updates to existing HVAC systems or sanitizing equipment
- Information Technology – examples would be for Telehealth, Teleworking and increasing bandwidth
- Facilities Expenses – examples are – lease or purchase of permanent or temporary structures, or to retrofit facilities to accommodate revised patient treatment practices to support infection control during the period of performance
- Other Health Care – Related Expenses – examples are – expenses not captured above that are for infection control and are health care-related expenses.
Lost Revenues Reimbursement
PRF payment amounts not fully expended on health care-related expenses attributable to coronavirus may then be applied to patient care lost revenues, if applicable. Documentation requirements for lost revenues calculations are further defined within the Data Elements section within the hyperlink below. Recipients may choose to apply PRF Payments toward lost revenues using one of three options, up to the amount:
- Option 1: of the difference between actual patient care revenues
- Option 2: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenues
- Option 3: calculated by any reasonable method of estimating revenues
In order to satisfy this requirement, we are recommending you print from your QuickBooks / Peachtree Accounting Software, your 2019 Quarterly Profit & Loss Statements, along with your 2020 Quarterly Profit & Loss Statements in order to confirm your loss of Revenues for the respective periods.
You can find additional info at provider-post-payment-notice-of-reporting-requirements-june-2021.pdf (hhs.gov) AND also here>> https://www.hhs.gov/about/news/2021/06/11/hhs-issues-revised-reporting-requirements-timeline-for-provider-relief-fund-recipients.html. You can also call HHS at 1-866-569-3522 with any questions you and your team may have.
If you feel you need to spend additional funds on Covid -19 related operating expenses and supplies, you should do so before your reporting period ends. As a reminder, please use the attached Excel Worksheet to track all your Covid related expenses. You will need to submit such, to gain forgiveness of the HHS PRF payments you received.
If you have questions on the HHS Funds, please contact BWTP and we can assist you. As we have seen over the last year or so, additional guidance will be forthcoming as the HHS Reporting Program gets started. As we become aware of additional guidance, we will forward to you.