Provider Relief Fund: New provisions appear positive for those who accepted payments

It is hard to believe we are discussing appropriate use of Provider Relief Fund (PRF) payments nine months after they have been received – the money surely has been spent by now.
When Congress late last year passed the Consolidated Appropriations Act, which includes renewed stimulus payments to individuals and businesses, it changed the scope of the Provider Relief Fund Program. These updated provisions for how PRF payments may be used appear to be positive.

Background on PRF

Healthcare providers in areas heavily hit by COVID-19, as well as those who struggled to keep their practice and facility doors open due to canceled elective services and healthy patients delaying care, received this federal funding through the Coronavirus Aid, Relief, and Economic Security (CARES) Act.

The U.S. Department of Health and Human Services (HHS) quickly distributed PRF payments in April 2020. Since few strings appeared attached to these funds, many providers happily accepted them even though guidance outlining the allowable uses of the funds was anything but clear.

Per the program’s original terms and conditions, funds were to be used to reimburse for health care-related expenditures or lost revenue attributable to coronavirus. And, while this sounded simple, it led to a lot of confusion. Under the new legislation, Congress required HHS to permit eligible providers to calculate lost revenues using the following HHS guidance issued in June 2020:

  • You may use any reasonable method of estimating the revenue during March and April 2020 compared to the same period had COVID-19 not appeared. For example, if you have a budget prepared without considering the impact of COVID-19, the estimated lost revenue could be the difference between your budgeted revenue and actual revenue. It would also be reasonable to compare the revenues to the same period last year.

Some good news

The new law appears to reverse HHS’ recent statements on the determination of lost revenues and allows for provider flexibility in accounting for lost revenues attributable to coronavirus.

The new law allows PRF recipients flexibility to transfer funds among their corporate parents and subsidiaries. Specifically, Congress required that any reimbursement from the Provider Relief Fund may be allocated (through transfers or otherwise) among subsidiary eligible health care providers, including reimbursement that was marked by HHS as “targeted distribution” payments.

Reporting requirement update

On Jan. 15, 2021, HHS announced it will be amending the reporting timeline for the Provider Relief Fund Program due to the recent passage of the Coronavirus Response and Relief Supplemental Appropriations Act, which is the federal government’s follow-up to the CARES Act.

HHS has been working to provide updated reporting requirements that comply with this recently passed legislation. Consequently, PRF recipients (who originally thought they would have to report on the usage of this funds during a reporting period window of Jan. 15, 2021 to Feb. 15, 2021) will now be required to submit their reporting requirements on their use of these funds at a later date to be determined.

Starting Jan. 15, PRF recipients may begin registering for gateway access to the Provider Relief Fund Reporting Portal, where they will ultimately submit their information in compliance with the new reporting requirements HHS is issuing. (The HHS website features portal FAQs and a portal user guide.)

Recipients of PRF payments exceeding $10,000 in aggregate must register in this portal. At present, there is no deadline for completing registration in the portal. Recipients will later receive a notification about when they should complete the second step of submitting reporting requirements information on the use of funds. HRSA will send a broadcast email to the email address provided during the registration process.

The registration process will take at least 20 minutes to complete and must be completed in one session – partially complete registrations will not be saved. Be sure to have all of the information required to register before beginning this process.

Our take on these latest developments

Hopefully, things relative to the PRF are finally starting to firm up. Providers should continue to carefully track HHS’ FAQs and other guidance. When not contradicted by Congress, this guidance will define HHS’ expectations for the permissible use of the funds and help providers prepare for reporting and audits.

If you would like to talk through the Provider Relief Fund and how we can help your practice or facility understand the latest guidance and navigate the auditing and reporting requirements, please reach out to your Rehmann advisor. You also may contact us at info@rehmann.com.

Rehmann is focused on providing practical guidance and insights to help empower organizations and individuals as we navigate through the uncertainty and complexity of this pandemic, together. Find resources and guidance at our COVID-19 Knowledge Center. Please click here to subscribe to our communications to ensure you remain up to date during these uncertain times. 

Published in Business Wisdom

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