HHS Publishes General and Targeted Distribution Post-Payment Notice of Reporting Requirements

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Under the Provider Relief Fund Terms and Conditions, each recipient is required to submit reports to HHS. This notice supplements HHS’ July 20, 2020 Post-Payment Notice of Reporting Requirements (previously reported on here). This notice supplements HHS’ July 20, 2020 Post-Payment Notice of Reporting Requirements, available here (previously reported on in the July 27, 2020 Health Headlines, available here). Furthermore, the reporting system will now be available to providers in early 2021 (previously HHS announced that the reporting system would go live on October 1, 2020).

Provider Relief Fund payment recipients must report on their use of funds by submitting: (1) healthcare-related expenses attributable to coronavirus; and (2) lost revenues attributable to coronavirus.

Expenses Attributable to Coronavirus

Providers that received between $10,000 and $499,999 in aggregated Provider Relief Fund payments are required to report healthcare-related expenses attributable to coronavirus, net of other reimbursed sources (e.g., payments received from insurance and/or patients, and amounts received from federal, state or local governments, etc.) in two aggregated categories: (1) general and administrative (G&A) expenses; and (2) other healthcare-related expenses. These are the actual expenses incurred over and above what has been reimbursed by other sources.

Recipients who received $500,000 or more in payments are required to report healthcare-related expenses attributable to coronavirus, net of other reimbursed sources, and they must do so by reporting more detailed information within the two categories of G&A expenses and other healthcare-related expenses.

G&A expenses include:

  • Mortgage/rent;
  • Insurance;
  • Personnel;
  • Fringe benefits;
  • Lease payments;
  • Utilities/operations; and
  • Other general and administrative expenses.

Healthcare-related expenses include:

  • Supplies;
  • Equipment;
  • Information technology;
  • Facilities; and
  • Other healthcare-related expenses.

Lost Revenues Attributable to Coronavirus

Payment amounts not fully expended on healthcare-related expenses attributable to coronavirus are then applied to lost revenues, represented as a negative change in year-over-year net patient care operating income. Once revenue information is provided, cost/expense impacts will be calculated based upon a calendar year comparison of 2019 to 2020 healthcare expenses to determine net operating income. Revenues and expenses include all lost patient care revenues and patient care cost/expense impacts.

The notice further explains revenue from patient care (as related to the payer mix) as follows:

  • Medicare Part A+B: The actual revenues/net charges received from Medicare Part A+B for patient care for the calendar year.
  • Medicare Part C: The actual revenues/net charges received from Medicare Part C for patient care for the calendar year.
  • Medicaid: The actual revenues/net charges received from Medicaid/Children’s Health Insurance Program for patient care for the calendar year.
  • Commercial Insurance: The actual revenues/net charges from commercial payers for patient care for the calendar year.
  • Self-Pay (No Insurance): The actual revenues/net charges received from self-pay patients, including the uninsured or individuals without insurance who bear the burden of paying for healthcare themselves, for the calendar year.
  • Other: The actual gross revenues/net charges from other sources received for patient care services and not included in the list above for the calendar year

Note that recipients may apply payments toward lost revenue, up to the amount of their 2019 net gain from healthcare-related sources. Recipients that reported negative net operating income from patient care in 2019 may apply payment amounts to lost revenues up to a net zero gain/loss in 2020.

Other Considerations

Providers will also need to provide non-financial data quarterly, including personnel metrics, patient metrics, and facility metrics.

Additionally, if recipients do not expend their 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 coronavirus but not reimbursed by other sources or to apply toward lost revenues in an amount not to exceed the 2019 net gain.

Finally, the reporting requirements do not apply to the Nursing Home Infection Control distribution or the Rural Health Clinic Testing distribution. HHS explains that separate reporting requirements will be announced at a later date for these distributions. Furthermore, these reporting requirements do not apply to reimbursement from the HRSA Uninsured Program. Additional reporting may be announced in the future for these payments.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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