The Provider Relief Fund portal is now open: Providers can successfully navigate the PRF reporting process with these tips

• The wait to learn how providers can report Provider Relief Fund (PRF) distributions finally ended when the PRF portal was opened by the federal government on July 1, 2021.
• Although HHS has opened the reporting portal, providers must register before starting the 16-step submission process.
• While providers may have been gathering expenditure data throughout the pandemic to report to HHS, the reporting portal also requires additional information that providers may have overlooked or that may not be easily accessible.

Healthcare providers are familiar with the concept of a waiting room, and they have been in one metaphorically speaking as the rules for how to utilize and report Provider Relief Fund (PRF) distributions have evolved over the past year. The wait just recently ended. The U.S. Department of Health and Human Services (HHS) released the latest PRF Post-Payment Notice Reporting Requirements (PPNRR) as of June 11, 2021. Following that communication, the federal government opened the long-awaited PRF portal on July 1, 2021, finally giving healthcare providers a tool with clearer instructions for reporting how their PRF distributions were utilized. HHS has also issued updates to the PRF frequently asked questions through July 15.

With these developments, there is a lot of updated information that providers need to be aware of and take into consideration. This communication summarizes the key components that will help providers navigate their PRF reporting strategy and related audit requirements.

Post-payment reporting requirements summary

Many healthcare providers have been monitoring the evolution of the reporting requirements throughout the past year and may have a sense of what is expected. There are, however, important changes with the latest update to the requirements, including:

• Portal reporting requirements are applicable if payments in excess of $10,000 were received in a reporting period.
• Portal reporting requirements apply to general and targeted distributions, including Skilled Nursng Facility (SNF) and Nursing Home Infection Control distributions.
• The reporting entity for targeted distributions is the entity that received the distribution. A parent entity cannot report on its subsidiaries’ targeted distributions, even if distributions were transferred to/from the parent entity.
• Expenses incurred to prevent, prepare for and respond to the coronavirus that were not reimbursed (or obligated to be reimbursed) by other sources are eligible expenses and are considered first in the usage of funds.
• Eligible expenses are categorized as either general and administrative or healthcare-related, with more granular reporting by subcategory for providers that received more than $500,000 in distributions.
• Recipients are required to report any interest earned on distributions received.
• SNF and Nursing Home Infection Control distributions can be used only for qualifying expenses; lost revenue is not an appropriate usage of these targeted distributions.
• If all PRF distributions are not used on eligible expenditures, then the reporting entity can calculate lost revenues using one of three options:

Option 1 –the difference between actual patient care revenues by calendar quarter, as compared to corresponding patient care revenues in 2019.

Option 2 – the difference between budgeted patient care revenue compared to actual, by calendar quarter, utilizing a budget approved prior to March 27, 2020.

Option 3 – any other reasonable method, which will be subject to a higher level of scrutiny and potential audit by HHS.

The final post-payment notice also established four separate reporting periods, based on when a recipient received funds. The following chart outlines the reporting schedule:

Portal best practices

HHS opened the reporting portal to providers on July 1, 2021. Providers must register before starting the 16-step submission process. While providers may have been gathering expenditure data throughout the pandemic to report to HHS, the reporting portal also requires additional information that providers may have overlooked or that may not be easily accessible. This is a robust tool, and reviewing the following tips ahead of time may best help prepare for the experience.

• PRF distributions received will be pre-populated and require providers to certify the information is correct before proceeding. Disputes over payments received must be resolved with HHS before the submission can be finalized. This is important to understand as the resolution process with HHS could take time, so log in to the portal early and determine the pre-populated amounts are accurate.
• Expenses incurred to prevent, prepare for and respond to the coronavirus that are not reimbursed by other sources are entered first, and they cannot exceed the total amount of PRF distributions received. While expenses for reimbursement under the PRF program cannot exceed payments received, additional excess unreimbursed expenses are entered into the portal on a separate screen.  There are still billions of dollars of unappropriated PRF funds available, so providers should capture excess COVID-related expenses and enter them into the portal in case this information is going to be utilized by HHS in some manner for future PRF allocations. 
• The lost revenue calculation is the next step, calculated quarterly. The recent guidance clarified that only calendar quarters with lost revenues are considered in the calculation for PRF usage. This change to the determination of lost revenue was a very positive development and is expected to allow many providers to capture more lost revenues than anticipated under prior interim HHS guidance, especially in those high-impacted quarters in 2020 when elective surgeries were halted. 
• The lost revenue calculation for the comparison to budgeted revenue, which may require providers to allocate budgeted patient care revenue amounts that were not initially budgeted by the payer.
• Certain statistical information is required to be entered by quarter. As expected, based on previous PRF guidance, the nonfinancial data elements required to be reported are extensive and are focused on personnel, patient and facility metrics. Providers should familiarize themselves with the requested information to allow sufficient time to gather the necessary information.
• Providers must answer all questions and type dollar amounts into all numeric fields to proceed to the next portal screen. Providers may return to previous steps and update accordingly, allowing time to investigate all portal sections even if they are not committed to submitting data yet. 

Providers are encouraged to review the portal inputs early in a given reporting window to allow sufficient time to gather necessary information prior to the 90-day submission deadline. For additional information, refer to the PRF online portal user guide on the HHS website.           

Focusing on FAQs

While providers should review the HHS website for relevant frequently asked questions (FAQs) that are of particular relevance to their organization, there are several questions common to many organizations.

For example, if there is uncertainty about what constitutes eligible PRF expenses, look first for the FAQs that address required reporting documents and what expenses may be attributed to preventing, preparing for or responding to the coronavirus that are not reimbursed by other sources, such as the following:

• Recipients should consider expenses attributable to coronavirus to include supplies, equipment, IT, facilities, personnel and other healthcare-related costs/expenses incurred during the period of availability as defined above. Expenses should be offset by any amounts received through other sources such as direct billings to patients. Marginal increases in expenses related to coronavirus are allowable so long as they are not reimbursed by other sources. Examples of qualifying expenses might include rental costs for COVID-19 supplies storage, incremental increases in contract labor, sanitation supplies and direct time spent on COVID-19 task forces.

Providers will also find a number of FAQs that address different scenarios, including the following:

• Recipients that had a change in ownership during the year (i.e., a divesture or acquisition) should pay close attention to related FAQs. Most importantly, acquired  providers that received PRF distributions prior to a sale and that did not have sufficient eligible expenses or lost revenues in the predecessor period may have to return some of the PRF funding or seek approval from HHS for the successor owner to be able to utilize the funding.
• Eligible expenses must be incurred before the end of the period of availability of funds and follow the provider’s basis of accounting (e.g., cash basis, accrual basis, etc.).
• Providers may allocate normal and reasonable overhead costs from the parent to subsidiaries as an eligible expense if the overhead costs were incurred to prevent, prepare for or respond to coronavirus. Allocation of such costs could assist in utilizing targeted-distribution funds received by subsidiaries.
• If the reporting entity incurs more lost revenue in a reporting period than PRF distributions received, the lost revenues can be carried forward to the next reporting period. This is important information for providers that received funding in periods 2 and 3 (outlined above). Providers can carry over lost revenues and expenses to the next reporting period in order to recognize PRF distributions received in subsequent periods.

Additionally, the U.S. Health Resources and Services Administration (HRSA) has indicated that no extensions will be issued for the usage of funds. All unused funds at the end of the period of availability will need to be returned. The instructions for returning funds can be found on the HRSA website.

The FAQs offer guidance specific to not-for-profit and for-profit entities that are reporting expenditures and /or lost revenue. Not-for-profit providers will be required to report expenditures on their Schedule of Expenditures of Federal Awards (SEFA) based on the reporting periods entered in the portal as follows:

The AICPA Governmental Audit Quality Center (GAQC) has confirmed with HHS that the new guidance supersedes previous guidance in the 2020 Office of Management and Budget (OMB) Compliance Supplement Addendum that indicated PRF reporting was to begin for fiscal years ending Dec. 31, 2020, and later. Stay tuned for more guidance expected to be included in OMB’s 2021 Compliance Supplement.

The relevance of the aforementioned guidance for for-profit PRF recipients is still uncertain. Providers should remain alert for anticipated additional guidance from HHS addressing for-profit considerations.

Strategic execution

In summary, developing a strategy for PRF portal reporting is crucial to ensure that providers maximize their usage of PRF distributions and meet the portal reporting deadlines. To help plan next steps and benchmark progress, providers should explore the reporting portal early and familiarize themselves with its navigation, regularly review the HHS website and GAQC for updates, and consult with their external auditors on the audit requirements and timelines specific to their organization.