Advisories July 2, 2021

Health Care Advisory: The PRF Reporting Portal is Open – Key Takeaways from New Guidance

On June 30, 2021, the Health Resources and Services Administration (HRSA) opened the Provider Relief Fund (PRF) Reporting Portal, which providers who received PRF distributions will need to use to submit required information. HRSA also released updated Portal FAQs, an updated Registration User Guide, and two new resources: the Reporting User Guide and Portal Worksheets. The opening of the Reporting Portal follows the Biden Administration’s Post-Payment Notice of Reporting Requirements (Reporting Requirements), released on June 11, 2021. On July 1, 2021, HRSA also released updated PRF FAQs and announced a webinar on July 8, 2021 at 3pm ET. 

As described in the Reporting Requirements and Reporting User Guide, PRF recipients must report on required data elements based on the relevant “period of availability” (see the table below). The period of availability is based on the date the payment is received, and PRF recipients must only use payments for eligible expenses and lost revenues during the period of availability. Providers that received more than $10,000 in aggregate payments during a payment period are required to report on expenses and lost revenues during the relevant period of availability. 

Reporting Requirements Chart

The Reporting User Guide and Portal Worksheets provide greater insight on the process and functionality of the PRF Reporting Portal. Based on a review of these materials and the updated PRF FAQs, there are several important details that PRF recipients should be aware of that may materially impact the ability to retain PRF payments. 

Takeaway #1 – Helpful New Guidance for PRF Recipients on Lost Revenues

According to the Reporting User Guide, and regardless of whether a PRF recipient chooses the “actual-to-actual” or “budget-to-actual” lost revenue approach, “for each calendar year of reporting, the applicable quarters where lost revenues were demonstrated are totaled to determine an annual lost revenues amount.” Thus, PRF recipient lost revenues will not be “offset” by any calendar quarters during which revenues increased. The Reporting User Guide states “a zero will be displayed if there is a positive change in revenue in any quarter.” 

As clarified in the PRF FAQs, lost revenues (and expenses) that exceed PRF payments from a particular reporting period may be “carried forward” and applied against PRF payments in later Reporting Periods. However, it is unclear from the Reporting Portal how this will be documented. However, it remains unclear whether Reporting Entities with fiscal years that are not aligned with the calendar year can use the budget-to-actual lost revenue approach. 

Should providers elect the “any reasonable method” lost revenue approach, HRSA will notify the Reporting Entity if the methodology is not reasonable. Reporting Entities will have 30 days to resubmit their reports using either the actual-to-actual or budget-to-actual lost revenue approach. 

Takeaway #2 – PRF Recipients Will Need to Determine the Impact of “Other Assistance Received”

HRSA provided several important clarifications on “Other Assistance Received” (e.g., Treasury/Small Business Administration assistance, Federal Emergency Management Agency (FEMA) programs, CARES Act testing funds, local/state/tribal government assistance, business insurance, other assistance). Specifically, HRSA states that:

  • The reported Other Assistance Received will not be used in the calculation of expenses or lost revenues. 
  • Patient care revenue should not be reported as part of Other Assistance Received because it is not a source of other assistance received as defined by the Reporting Requirements. 
  • Reporting Entities are expected to make a determination of expenses covered by PRF payments after considering Other Assistance Received. 

It appears that PRF recipients will have to independently determine the application of Other Assistance Received to expenses and lost revenues, excluding patient care revenues. PRF recipients will likely need to defend the chosen approach if subjected to an audit. 

Takeaway #3 – Begin the Reporting Process Early, But Wait to Submit

PRF recipients should not wait to start the process of reviewing and collecting information that will need to be reported. There are new required data elements (e.g., Personnel, Patient, and Facility metrics, Survey on the impact of PRF payments) and nuances in reporting (e.g., as parent entities on behalf of some or all subsidiaries, varying thresholds and required detail for reporting based on PRF payment amounts) that may impact how PRF recipients choose to report on PRF payments received. In addition, HRSA will automatically populate PRF payments for Reporting Entities in the portal, and, should there be an inconsistency, PRF recipients will have to call the Provider Support Line to resolve any discrepancies. PRF recipients also should consider waiting to submit the required information because there are several open questions that may be clarified through future guidance. 

In addition, throughout the PRF FAQs and Reporting Portal resources, HRSA makes it abundantly clear that the burden of proof will fall on the PRF recipient to substantiate the expenses incurred and lost revenues. PRF recipients should ensure sufficient documentation exists, is maintained, and is developed to supplement and support the Reporting Portal submission. 

Additional Important Details

HRSA provided several important details through its PRF FAQ update. These include:

  • Unused PRF payments from a Payment Period must be returned within 30 calendar days after the end of the Reporting Period. 
  • Purchases of tangible items do not need to be in the provider’s possession to be considered an eligible expense. However, the costs associated with those items must have been incurred prior to the Deadline to Use Funds date. 
  • If a provider receives a retroactive payment from FEMA that overlaps with the period of availability, the provider must not use FEMA payments on expenses or lost revenues already reimbursed by PRF payments. In these instances, the PRF would no longer be the payer of last resort. 
  • When reporting expenses, it is possible for a Reporting Entity to enter “0” if appropriate. PRF payments not expended on unreimbursed health care-related expenses attributable to COVID-19 during the period of availability are then applied to lost revenues. 
  • With respect to “net unreimbursed expenses,” these amounts will not be used in the calculation of expenses or lost revenues. HRSA instructs Reporting Entities to determine these amounts after taking into consideration Other Assistance Received and all PRF payments. Again, it is possible for a Reporting Entity to enter “0” if appropriate. 

While this reflects guidance in effect as of July 2, 2021, we expect to see HRSA’s guidance on PRF to continue to be refined, and we will continue to track this closely. Please reach out to our team if you have questions. 

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Nicholas Clarke
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