If you are like many other local healthcare organizations, you have likely participated in one or more governmental assistance programs offered this past year, such as the Paycheck Protection Program (PPP), CARES Act Testing, government assistance (local, state or tribal) and the Provider Relief Fund (PRF). The focus of this article is to alert you to the PRF reporting requirements that you will be responsible for.
Marc Lion, CPA, CFP
The PRF, with its $175 billion of allocated funds, was established as part of the CARES Act to provide support to healthcare providers in the battle against the COVID-19 pandemic. Qualified healthcare providers were able to receive PRF payments for healthcare-related expenses or to cover lost revenue due to COVID-19. The grants received are considered income for income tax purposes. In addition, the distributions do not need to be repaid to the government, assuming providers comply with the terms and conditions.
Recipients of PRF payments must attest to the payment by accepting or rejecting the funds within 90 days of receipt through the Provider Relief Fund Application and Attestation Portal. Note that not actively attesting within the 90-day period is viewed as acceptance. For Phase 1 and 2 distribution recipients, the 90-day period has passed. For those who recently received funds in the Phase 3 General Distribution, the 90-day window to attest is currently open. To reject payment, the recipient must return the funds to the U.S. Department of Health & Human Services (HHS) within 15 calendar days of attestation.
On Nov. 2, HHS released its Final Reporting Data Elements PDF. This document updates and supplements the Oct. 22, Sept. 19 and July 20 General and Targeted Distribution Post-Payment Notice of Reporting Requirement. Providers who receive PRF payments exceeding $10,000 in aggregate are required to report their use of funds as part of the post-payment reporting process. Failure to comply could result in the repayment of the funds received.
The key dates to be aware of are as follows:
- Jan. 15, 2021: Reporting portal opens for providers
- Feb. 15, 2021: The original first reporting deadline for all providers on their use of PRF funds has now been extended to an unspecified future date. On Jan. 15, HHS, through the Health Resources and Services Administration, announced that it will amend the reporting time line for PRF funds due to the recent passage of the Coronavirus Response and Relief Supplemental Appropriations Act. HHS has been working to provide updated reporting requirements that comply with this recently passed legislation.
- July 31, 2021: Final reporting deadline for providers who did not fully expend PRF funds prior to Dec. 31, 2020
Reporting guidance on the use of PRF funds can be applied in the following manner and order:
- Healthcare-related expenses attributable to coronavirus that another source has not reimbursed (e.g. PPP) and is not obligated to reimburse, which may include general and administrative (G&A) or healthcare-related operating expenses.
Examples of G&A expenses include:
- Mortgage or rent for a clinical setting
- Direct employee expenses (wage limits apply)
- Fringe benefits
- Lease payments (diagnostic equipment, clinical care software)
- Utilities/operations (HVAC services, environmental services for cleaning)
Examples of healthcare-related expenses include:
- Specific medical supplies (surgical masks, temperature monitoring devices)
- Equipment (ventilators, HVAC systems, upgrades to filtration systems)
- Information technology (upgraded internet, remote working support, new EMR)
- Facility upgrades (improvements to waiting rooms to accommodate COVID-19 safety protocols)
- PRF payment amounts not fully expended on healthcare-related expenses attributable to coronavirus are then applied to patient care lost revenues. Recipients may apply PRF payments toward lost revenue up to the amount of the difference between their 2019 and 2020 actual patient care revenue.
- If recipients did not expend PRF funds in full by the end of calendar year 2020, they will have an additional six months in which to use remaining amounts toward expenses attributable to the coronavirus pandemic.
The specific methodology for reporting the above information has not currently been released. In preparation for a timely and accurate submission of the requested data, it is advisable for recipients of PRF payments to proactively analyze their coronavirus-related expenses. Contact a professional advisory services firm for guidance on COVID-19 regulatory and financial relief programs before it’s too late.
Marc Lion, CPA, CFP, is a Partner/Practice Leader with Entrepreneurial Business Services, Mazars USA LLP. For more information, visit mazarsusa.com.