On September 19, 2020, the U.S. Department of Health and Human Services (HHS) updated their Post-Payment Notice of Reporting Requirements from August 14, 2020 (the Notice). The purpose of the Notice was to inform recipients of Provider Relief Funds about the timing of future reporting requirements. The Notice stated that the system for reporting compliance with the terms and conditions that the recipients agreed to when they received the Provider Relief Funds would be October 1, 2020. Per the HHS website, the reporting system will now be available in early 2021.
While vague on exactly when to report through the portal, the Notice offered clarity on what to report. The Notice includes categories of data elements that recipients must submit for calendar years 2019 and 2020, with plans of offering Question & Answer sessions via webinar, as well as continuing to issue Frequently Asked Questions to aid in reporting.
Broadly, recipients of more than $10,000 of Provider Relief Funds will report their use of those funds attributable to:
1. Healthcare-related expenses attributable to coronavirus that another source has not reimbursed and is not obligated
to reimburse which include:
a. General and Administrative expenses, and/or
b. Other Healthcare Related Operating expense
2. Provider Relief Funds not fully expended on healthcare related costs attributable to coronavirus that are applied to
lost revenues.
The defining of lost revenues is a major component of the September 19th notice.
- Lost revenues represent the negative change in year-over-year net patient care operating income, net of the healthcare related expenses attributable to coronavirus that have been included in the healthcare-related expenses whether they are general and administrative expenses or other healthcare-related operating expenses.
- Net Patient Care Operating Income, for example, would be patient care revenue less patient care related expense for the reporting entity that received the Provider Relief Funds.
If you have questions or would like more information, please contact your LaPorte CPAs & Business Advisors representative. This blog is the first of a series that will outline the components and calculations of reporting the use of Provider Relief Funds. Please revisit the healthcare page on our website for the next installment.