On June 11, 2021, HHS released an updated Notice of Post-Payment Reporting Requirements (the Notice). Notably, the notice describes how the period of availability of payments from the CARES Act Provider Relief Fund (PRF) is based on the date of receipt of payment (rather than requiring that all payments be used before the due date). June 30, 2021), and it details the updated reporting deadlines. and requirements. This new notice replaces all previous versions of the Post-Payment Notice Reporting Requirements documents, and it applies to all past and future FRP payments. Additionally, last week, HHS posted eighteen new and changed PRF Frequently Asked Questions (the FAQs). FAQs cover reporting requirements, Phase 3 payments, return of unused funds, and more.
Post-payment notification of reporting requirements
Period of availability of funds and reporting periods
Suppliers are required to report their use of funds during each payment period received in which they received one or more payments exceeding, in total, $ 10,000, as shown in the table below. Suppliers may only use payments for eligible expenses and lost revenue attributable to COVID-19 by the deadline for the relevant received payment period. These deadlines depend on the date of receipt of payments (that is to say, the date of deposit for automated clearing house (ACH) payments or the date of cashing the check). Additionally, reports must be completed and submitted to HRSA by the last date of the relevant reporting period. This is a change from previous notices and guidelines that required all payments to be used by June 30, 2021, regardless of when they were received.
Recipients will have 90 days to complete the declaration (rather than a 30-day reporting period). The reporting portal is currently only open for registration and will open for the initial reporting period on July 1, 2021. More information about the reporting portal is available here.
Steps to report the use of funds
The notice explains that reporting entities will report on their use of funds using their normal accounting basis (for example, cash accounting, accrual accounting) and submit consolidated reports. Below is a high-level overview of how (and the order in which) the data will be reported:
Interest earned on PRF payment (s): For reporting entities that held the PRF payment (s) in an interest-bearing account, the dollar value of interest earned on those PRF payments should be reported. Interest earned on Qualified Nursing Facility (SNF) and Nursing Home Infection Control Distribution payments and interest earned on other FRP payments will be reported separately.
Other assistance received: The reporting entity will report on other aid received quarterly during the availability period. If the reporting entity reports on behalf of subsidiaries, the aid received for each category should be aggregated for each of the subsidiaries included in the report.
Use of SNF and distribution payments for infection control in nursing homes (if applicable): The reporting entity will report infection control expenses paid with payments received through SNF and nursing home infection control distributions (including interest earned), if the entity has received any fund from one of these targeted distributions.
Use of general distribution payments and other targeted distributions: The reporting entity will report expenses paid with payments received through general and targeted distribution payments (excluding SNF and nursing home infection control distribution payments). Unreimbursed expenses attributable to the coronavirus are considered first in calculating the overall use of funds.
Net unreimbursed expenses attributable to COVID-19: The reporting entity will report the unreimbursed expenses attributable to COVID-19 (net after the application of other aids received and payments from the Relief Fund to providers) by quarter for the period of availability, broken down into general expenses and administrative and / or other related to health care. Expenses.
Reimbursement of lost income: Payment amounts (excluding SNF and Nursing Home Infection Control Distribution payments) that are not fully spent on healthcare-related expenses attributable to COVID-19 may then be applied to lost patient care revenue, if applicable. Recipients can choose to apply payments to lost income using one of three options, up to the amount:
Option i: the difference between the actual income from patient care;
Option ii: the difference between budgeted revenues (before March 27, 2020) and actual patient care revenues; or
Option iii: calculated by any reasonable method of estimating income.
The FAQ explains that spreadsheets will be available to help reporting entities complete the reports. In addition, reporting entities that use part of their funds for lost income may also be required to upload supporting documents when reporting their lost income calculation. The documentation required depends on the method of calculating lost revenue chosen by the suppliers.
Notice is available here.
Frequently Asked Questions
The new amended FAQs generally deal with the following general categories: (1) Terms and conditions; (2) Audit and reporting requirements; (3) Use of funds; (4) Supporting data; (5) Change of owner; (6) Non-financial data; and (7) Phase 3. Many FAQs overlap with the Notice instructions.
In addition, and in particular, the FAQ reminds recipients of phase 3 that they are not limited to using phase 3 funds to cover losses or expenses related to COVID-19 only during the first two quarters of calendar year 2020. While HHS has collected information on losses and expenses. associated with the first two quarters of 2020 for the purpose of making additional general distribution payments to suppliers with demonstrated financial need, the terms and conditions do not place limits on the quarters to which these funds must be applied to cover losses or expenses eligible. In addition, the FAQs also explain that when the first reporting period begins, providers will be able to return unused funds through the reporting portal.
The full FAQ document is available here.