The long-awaited guidance from the Department of Health and Human Services (HHS) was just released, indicating that the PRF Reporting Portal will be available on July 1, 2021. The latest "Post-Payment Notice of Reporting Requirements" is dated June 11, 2021, which supersedes the January 15, 2021 document, and the HHS website has also been updated with the new rules.
The time frame to use the funds and for the reporting of the use of those funds is broken down into 4 time periods ending June 30 and December 31, 2020 and 2021. Practices have one year from the end of each period to use the funds, and then another 90 days in which to file the report using the PRF Reporting Portal. No reporting is required if the aggregate amount of funds received within a specified time period is less than $10,000.
The first deadline is June 30, 2021, for a practice to use the funds it received from April 1 to June 30, 2020, with reporting due by September 30, 2021. The initial distribution of funds by HHS occurred in April 2020 by automatic direct deposit to the practice’s bank account. Later distributions resulted from an application by the practice.
The portal initially opened for registration on January 15, 2021, and registration can be done at any time. In order to register, the following information will be needed:
- The entity’s Taxpayer Identification Number (TIN)
- The contact person’s name, address and other contact information
- A portal username that was previously created, if any
- The date and amount of PRF payments that were received
HHS notes that the portal is only compatible with the most current version of Edge, Chrome, and Mozilla Firefox browsers.
The new notice of reporting requirements contains much more detail about the information to be reported and the nature of the expenses that will be considered allowable as a use of the HHS funds. It indicates that data will be reported in the following order:
- Interest earned on PRF payments
- Other assistance received
- Use of SNF and nursing home infection control distribution payments (if applicable)
- Use of general and other targeted distribution payments
- Net unreimbursed expenses attributable to coronavirus
- Lost revenues reimbursement
Each of the elements listed is then described in more detail within the document. The reporting of expenses is to be broken down into two categories:
- General and administrative expenses
- Health care-related expenses
Entities that received $500,000 or more will be required to report in more detail. Additional information will be requested about personnel, patient and facility metrics by quarter for calendar year 2019 through the end of the period being reported. Finally, there will be a survey including questions regarding the impact of payments during the reporting period.
Revenue information will also be required, and it would be wise to have available the amount received for patient care by payer for each month during all of 2019 and 2020. In addition, other funding sources such as the Small Business Administration’s Paycheck Protection Program (PPP) and Economic Injury Disaster Loans (EIDL) along with private, state or local government grants will be needed. Expenses and lost revenue covered by these sources cannot be used as justification to retain Provider Relief Funds.
The reporting appears to require quite a lot of detail and analysis of both revenue sources and the nature of expenses, and practices should not presume that they will be able to retain the entire amount of PRF monies received prior to careful analysis and review. Begin to gather data and investigate the reporting portal as soon as the period of funds availability ends so you have enough time to gather the information to meet the reporting deadline. We will continue to monitor developments and provide information as it becomes available and by subscribing to this blog, you will always be aware of the latest developments in COVID-19 relief options and reporting requirements.