June 23, 2021

Summers remembered—in a time before smart phones and social media. The car is packed and the kids have climbed into their designated seats. Mom and Dad are in the front, excited to get this vacation on the road. They have all mentally readied themselves for the ride. The Atlantic coast awaits and the beach is beckoning; but, before they can pull out of the garage, they hear the phone ringing just inside the door. Dad reluctantly goes in to check who it is, in the off-chance it’s an emergency or otherwise important. Big mistake, or perhaps fortuitous. There’s been a death in the extended family. The trip in tatters and the kids in disbelief, they and the luggage must now be dislodged from the car.

The above is a true story. It’s repeated here as a reminder that the firmest of plans can suddenly change. But, unlike our story, sometimes they change for the better. There’s recently been a change of plans by the federal government that will positively affect many of America’s hospitals.

A Bit of Background

In an effort to provide emergency assistance to healthcare entities during the COVID crisis, the government rushed a series of measures into law. Among these were the Coronavirus Aid, Relief, and Economic Security (CARES) Act; the Paycheck Protection Program and Health Care Enhancement Act; and the Coronavirus Response and Relief Supplemental Appropriations Act of 2021. Together, these laws provided $178 billion for the Public Health and Social Services Emergency Fund to reimburse providers for healthcare expenses or lost revenues attributable to COVID. As always, there were strings attached to the government assistance.

Early on, healthcare entities were given a set of expectations that had to be met once these emergency funds were accessed. In July of last year, the U.S. Department of Health and Human Services (HHS) began issuing notices on post-payment reporting requirements. Then, on January 15 of this year, HHS issued updated requirements that included portal registration for fund recipients and a June 30 cut-off date for using the funds.

A New Standard is Set

Last month, the American Hospital Association (AHA) sent a letter to HHS, asking the agency to extend the June 30 deadline. The rationale for the request was that hospitals and health systems continue to incur expenses and difficulties related to COVID, such as the following:

Ensuring an adequate workforce
Acquiring equipment and supplies such as personal protective equipment, pharmaceuticals and safety equipment
Maintaining testing and additional screening for every hospital patient
The AHA’s letter to HHS stressed that healthcare entities “should be able to apply their PRF funds toward these costs, which they will undoubtedly continue to incur beyond June 30 and through the end of the PHE.” The AHA letter, in tandem with HHS’s continued monitoring of COVID’s impact on the industry, eventually led to the agency’s decision to extend the June 30 deadline. Here are the details of the changes to the reporting requirements, according to HHS’s website:

The period of availability of funds will now be based on the date the payment is received (rather than requiring all payments be used by June 30, 2021, regardless of when they were received).

Recipients are required to report for each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments).

Recipients will have a 90-day period to complete reporting (rather than a 30-day reporting period).

The reporting requirements are now applicable to recipients of the Skilled Nursing Facility and Nursing Home Infection Control Distribution in addition to General and other Targeted Distributions.

The PRF Reporting Portal will open for providers to start submitting information on July 1, 2021.
A Bird’s Eye View

So that our readers might better understand the date parameters relative to the Payment Received Period and the Reporting Period, the following chart (from the HHS website) is provided:

According to HHS, the above reporting requirements do not apply to the Rural Health Clinic COVID-19 Testing Program or the two claims-reimbursements programs (HRSA COVID-19 Uninsured Program and HRSA COVID-19 Coverage Assistance Fund).

If you have further questions about the changes to the usage and reporting requirements, you can go to the following HHS link: HHS Issues Revised Notice of Reporting Requirements and Reporting Timeline for Recipients of Provider Relief Fund Payments | HHS.gov. If you have a question about the business services we provide to hospitals, you can contact us by going to info@miramedgs.com. Our desire is to help hospitals enhance efficiencies so that hospitals can focus more on the mission of healing.