Provider Relief Fund, Period 1 Reporting
By Israel Perez, Manager, Tax & Business Services
In response to COVID-19, Federal financial assistance to reimburse eligible health care providers for healthcare related expenses or lost revenues attributable to the pandemic were distributed by the Health Resources and Services Administration (HRSA). The financial assistance was distributed through the Provider Relief Fund (PRF) program.
Funds distributed through the PRF are required to be used to cover additional expenses due to the pandemic or to cover lost revenues, also as a result of the pandemic. PRF recipients must not report COVID-19 related expenses that were reimbursed by other grants or programs, such as the Paycheck Protection Program (PPP). The expenses that were covered with monies from the PRF program will be reported for Period 1. The following is a summary of information to be reported (Q1 2020 through Q2 2021):
- Financial assistance received from other sources due to COVID-19, other than the PRF
- Expenses incurred relating to COVID-19, and being applied to PRF in this reporting period
- Unreimbursed COVID-19 related expenses
- Revenue from patient care, for the purpose of calculating lost revenue
- Personnel, patient and facility metrics
The above information will be reported through the “Provider Relief Fund Reporting Portal” which was developed by HRSA. The PRF Reporting Portal opened on July 1, 2021 after it was postponed several times. The report for Period 1 covers funds received from April 10, 2020 through June 30, 2020, and was due to be submitted by September 30, 2021. However, a 60-day grace period is in place. The grace period began on October 1, 2021 and it will end on November 30, 2021. The grace period only applies to the reporting for Period 1. The deadline to use the funds for Period 1 remains at June 30, 2021.
PRF recipients are required to return any unused funds from Period 1 to the government within 30 calendar days after submitting the report for Period 1.
The following table is the reporting time periods for payments exceeding $10,000 in aggregated received:
| Payments Received Period | Reporting Time Period | |
|---|---|---|
| Period 1 | 4/10/2020 to 6/30/2020 | 7/1/2021 to 9/30/2021 |
| Period 2 | 7/1/2020 to 12/31/2020 | 1/1/2022 to 3/31/2022 |
| Period 3 | 1/1/2021 to 6/30/2021 | 7/1/2022 to 9/30/2022 |
| Period 4 | 7/1/2021 to 12/31/2021 | 1/1/2023 to 3/31/2023 |
Once in the HHS portal, providers will begin by completing basic information of the entity such as legal name, employer identification number, type of entity provider type, address, among other information.
The monies received during the reporting period will be populated in the portal and the PRF recipient should verify the amounts for accuracy. If PRF monies received were deposited into an account earning interest, the interest earned must be reported. If monies were used to invest in the stock market and a gain was generated, the capital gains must be included as well.
If the COVID-19 reported expenses do not cover all of the PRF received in this period, or if a provider chooses not to report all of their expenses, the PRF recipient can use the Lost Revenues using one of the following three options:
- The first option is to calculate lost revenue by using 2019 quarterly actual patient care revenue compared to quarterly actual patient care revenue for 2020 and the first two quarters of 2021.
- The second option is to compare budgeted revenue for Q1 2020 through Q4 2020 and Q1 and Q2 of 2021 to actual revenue for the same quarters of 2020 and 2021. However, to use this option, it is required that the budget was approved by March 27, 2020. Providers must also provide an attestation by the CEO, CFO or similar of the accuracy of the budget.
- The third option is an alternate reasonable method to calculate 2020 and 2021 lost revenue. A narrative must be provided to explain the methodology used. This method will be subject to a detailed review.
PRF recipients also need to complete the personnel, patient and facility metrics sections of the reporting. For many, it will be time consuming to gather the statistics as it is required to report the number of clinical and non-clinical employees categorized by full time, part-time, furloughed, separated and hired, as well as contractors. Depending on the provider type, patient metrics must be reported for the following (1) inpatient admissions, (2) outpatient visits (in-person and virtual), (3) emergency visit and (4) facility stays. Last but not the least, the number of staffed medical and surgical beds, critical care beds and other beds will be reported for the facility metrics, if applicable.
As indicated earlier, providers that received the Provider Relief Fund between April 10, 2020 and June 30, 2020, need to submit their report by November 30, 2021 which is the end of the 60 day grace period. If you have any questions or need assistance, please reach out to your Marcum Advisor.
