On January 15, 2021, the U.S. Department of Health and Human Services opened the reporting portal for individuals who had received Provider Relief Funds (PRF) from the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The portal is currently open for “registration” only. HHS has not yet set up the reporting portion of the portal and the date by which the first reports will be due is currently unknown.
Who Needs to Register?
Entities that received one or more payments which totaled more than $10,000 from the General and Targeted Distributions will need to register on the portal.
Registration is NOT required at this time for providers who received less than $10,000 total in PRF or have received PRF based on:
- The Nursing Home Infection Control Distribution
- The Rural Health Clinic Testing Distribution
- Reimbursement for Testing, Treatment and Vaccine Administration
- The Vaccine Administration Assistance Fund
What is the Deadline for Registration?
At this time there is no deadline for registration.
The previous due date for submitting documentation regarding the use of PRF was February 15, 2021. HHS is now stating that they will provide information regarding when documentation must be submitted at a “later” date.
How Do Providers Register?
Providers should go to the HHS website and register.
Some things to know about registration:
You must complete the registration process in ONE session. You cannot stop, and return to your submission. HHS is estimating that the registration process will take approximately 20 minutes.
You should have the following information available when you start the registration process:
- Tax ID Number (TIN) (or other identifying number submitted during the application process)
- Business name (as it appears on a W-9) of the reporting entity
- Contact information (name, phone number, email) of the person responsible for submitting the report
- Address of the reporting entity as it appears on a W-9
- TIN(s) of subsidiaries (if a provider is reporting on behalf of subsidiary(ies)
- Payment information for any of the payments received, including:
- TIN of entity that received the payment
- Payment amount
- Mode of payment (check or direct deposit ACH)
- Check number or ACH settlement date
You will also need to create a username (in the form of an email address) and create a password during the registration process.
What Happens Next?
HHS will contact providers using the email provided as part of the registration process to notify providers as to when they can begin reporting actual information related to the use of PRF funds.
Notice of Reporting Requirements
HHS has issued another Post-Payment Notice of Reporting Requirements document. For the most part, the 1/15/21 Requirements track the previously published November 2, 2020 guidance, reiterating that PRF can be used for health care related expenses, including general and administrative expenses and lost revenue.
Some items of interest include:
The 1/15/21 Requirements outline the numerous ways that providers can quantify lost revenue. The requirements are consistent with language in the recently passed Consolidated Appropriations Act, 2021.
Lost revenue can be calculated as follows:
(a) the difference between 2019 and 2020 actual patient care revenue;
(b) the difference between 2020 budgeted and 2020 actual patient care revenue as long as providers can demonstrate that the 2020 budget was established and approved by March 27, 2020.
(c) by “any reasonable method of estimating revenue.”
This catch-all provision will require a provider to describe the methodology used, explain why it is reasonable, and demonstrate how the revenue loss was attributable to COVID-19.
The 1/15/21 Requirements also state that ALL providers will need to include information regarding their actual patient care revenue in 2019 vs 2020. Even providers who can demonstrate that they used all of their PRF for health care related expenses will need to provide information regarding 2019 actual patient care revenue and 2020 actual patient care revenue.
The 1/15/21 Requirements also contemplate that providers who did not expend all their PRF by December 31, 2020 can use the PRF for covering lost revenue in 2021. Providers can calculate lost revenue for 2021 by comparing actual revenue from Quarter 1 to Quarter 2 of 2019 with actual revenue from Quarter 1 to Quarter 2 of 2021. Alternatively, providers can compare budgeted revenue from Quarter 1 to Quarter 2 of 2020 to Quarter 1 to Quarter 2 of 2021.
Parent Use of Subsidiary Funds
Also consistent with the Consolidated Appropriations Act, 2021, HHS recognizes that parents can take Targeted Distribution funds received by one subsidiary and provide those funds to another subsidiary. However, providers who transfer targeted distribution funds will have an increased likelihood of an audit.
HHS plans to offer Question & Answer Sessions via webinars in advance of the reporting deadline and additional information will be provided in the HHS Provider Relief Fund FAQ document.