January 20, 2021

Think back to high school or college and the stresses you were under to complete an assigned report before the submission due date. A topic had to be selected, the research had to be performed, and then the actual writing process had to begin. The time and tedium of the task could be overwhelming for some, leading many to dread these laborious projects. No wonder, then, that some individuals—years after graduation—will experience nightmares of being back in school and failing to have the required material by the day of reckoning.

Well, for those of you who have been dreading the submission of reports as required by the Provider Relief Fund (PRF) mandates, you can breathe a little easier. The due date has just been extended.

Deadline Delay

By way of background, the Department of Health and Human Services (HHS) had previously published a set of reporting instructions that would apply to those receiving PRF funds in excess of $10,000 in the aggregate. The Department had originally planned on opening a reporting portal by January 15, 2021, and had set February 15, 2021 as the first deadline for submissions. However, with the passage of the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act in December, an additional $3 billion was added to the PRF program fund. This, along with the inclusion of new language within CRRSA implicating PRF reporting requirements, created new roadblocks to the original timeline.

To be more specific, it has taken some time for HHS to update the PRF reporting requirements so that they correlate with current law. In other words, the passage of CRRSA made it inevitable that a delay in the reporting requirements would be necessary. In addition, HHS officials felt it would be critical for PRF recipients to have additional time to familiarize themselves with the new requirements. As of this writing, the new deadline for actual PRF reporting has yet to be announced. Here is an excerpt from the January 15, 2021 HHS announcement that PRF recipients will find most helpful:

In the interim however, starting today, HHS is encouraging all PRF recipients that have received aggregate PRF payments that exceed $10,000 to establish a reporting account by registering at the newly enabled PRF reporting website. While there is currently no deadline for providers to establish a reporting account in the newly enabled Reporting Portal, all providers will be required to complete this first step in order to advance and fulfill their reporting requirements once HHS announces the new deadline to do so.
The announcement goes on to list those PRF recipients for whom the reporting requirements do not apply.

The reporting requirements released today do not apply to funds from: Nursing Home Infection Control, Rural Health Clinics Testing, and COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment and Vaccine Administration for the Uninsured recipients.
For those planning to report and needing to register, the portal can be accessed by going to the following government website, which provides a link to the portal: Reporting Requirements and Auditing | HHS.gov.

Requirements Revised

As alluded to above, the new CRRSA law actually changed some of the original PRF reporting requirements. That’s sort of like your English professor giving you one set of parameters for your term paper at the beginning of the semester, but then changing them up after you’ve completed half the project. The American Hospital Association (AHA) released a special bulletin in which they summarize some of the new PRF reporting requirements. They include the following:

Providers will be allowed to calculate lost revenue using one of three methods:
The difference between 2019 and 2020 actual patient care revenue;
The difference between 2020 budgeted and 2020 actual patient care revenue, using a budget that was established and approved prior to March 27, 2020; or
Any other reasonable method, which providers must describe and justify its use.
Subsidiaries’ parent organizations may transfer “targeted distribution” to another subsidiary. However, the original targeted distribution recipients are the entities that must report on the use of funds. HHS also states that transferred targeted distributions face an increased likelihood of audit.
The full range of requirements can be accessed by going to the following government link: General and Targeted Distribution Post-Payment Notice of Reporting Requirements January 15, 2021 (hhs.gov). Hopefully, the new reporting requirements, coupled with the reporting deadline delay, will lessen the likelihood of sleepless nights and bad dreams.

Please reach out to us at info@miramedgs.com if you have questions about this or any other topic. Our mission is to support the work of hospitals through innovative business solutions.