Answers To Frequently Asked Provider Relief Fund Reporting Questions
If your practice or healthcare organization secured one or more support payments through the Provider Relief Fund (PRF) that collectively exceeded $10,000, it may be time to report how these funds were used. While the reporting requirement is simply the next step in the PRF post-payment reporting process, it has resulted in confusion throughout the healthcare industry. This article will provide you with information, insight, and answers to some frequently asked questions in an effort to get you across the post-payment reporting finish line.
Why Do Healthcare Providers Need To Submit A Post-Payment Report?
Since the first PRF grant was dispersed in early 2020, billions of dollars have been distributed to healthcare professionals. This aid has provided much-needed financial assistance throughout the healthcare industry during the COVID pandemic. To ensure the money was well spent and fulfilled the desired mission, the Health Resources & Services Administration (HRSA), an agency of the Department of Health and Human Services, requires PRF recipients to confirm the funds were, in fact, used to cover expenses designed to prevent, prepare for, or respond to COVID.
When Do Provider Relief Fund Recipients Need To Report Their Use Of Funds?
Your reporting period is based on the date you received PRFs. The HRSA has outlined four specific PRF payment periods and respective 90-day reporting windows.
|Period||PRF Payment Received||Deadline To Use PRFs||PRF Reporting Window|
|Period 1||April 10, 2020 – June 30, 2020||June 30, 2021||July 1, 2021 – Sept. 30, 2021|
|Period 2||July 1, 2020 – Dec. 31, 2020||Dec. 31, 2021||Jan. 1, 2022 – March 31, 2022|
|Period 3||Jan. 1, 2021 – June 30, 2021||June 30, 2022||July 1, 2022 – Sept. 30, 2022|
|Period 4||July 1, 2021 – Dec. 31, 2021||Dec. 31, 2022||Jan. 1, 2023 – March 31, 2023|
For example, if you received a PRF payment between the dates of April 10, 2020, and June 30, 2020, the deadline to use your funds was June 30, 2021. Immediately following the deadline to use your funds, the PRF reporting window opened. Now, you will have 90 days to tell the HRSA how your funds were spent. Your PRF reporting window will close at 11:59 PM ET on Sept. 30, 2021.
Early reporting AND late reporting will not be accepted. You must report your PRF use of funds during the specified PRF reporting window.
How Do Providers Report PRF Use Of Funds?
The first step in your PRF reporting journey is to register for the portal by clicking here. The registration process will take around 20 minutes to complete. Additionally, you need to complete your registration in one session in order to have your data save.
Compile The Proper Documentation
Before beginning the registration process, arm yourself with the following documents and information:
- Tax ID Number (TIN) or another number that was submitted during the initial application process, such as your Social Security Number (SSN) or Employer Identification Number (EIN).
- The official business name of the reporting entity as it appears on IRS Form W-9.
- Basic contact information of the person responsible for reporting this information (you), including name, phone number, email.
- The address of the reporting entity, as it appears on IRS Form W-9.
- TIN(s) of subsidiaries (if a provider is reporting on behalf of subsidiary(ies) – in a list delimited by commas, (e.g.,123456789, 987654321, 135791357).
- Information specific to any PRF payments received.
- TIN of entity that received the payment
- Payment amount
- Mode of payment (check or direct deposit ACH)
- Check number or ACH settlement date
Once the registration process is complete, you can get to work reporting your COVID-related use of funds.
What Information Will Healthcare Providers Need To Report?
Go into this task with the mindset of protecting yourself and your organization short- and long-term. Yes, federal guidance released on June 11, 2021, doesn’t explicitly require you to provide a detailed outline of your expenses. Even so, it’s always best to collect more information rather than not enough. This helps protect your practice from a future audit headache.
In addition to the PRF, you will also need to collect and report the dates and amounts of all other program money received. These might be funds provided via the Paycheck Protection Program (PPP), the Economic Injury Disaster Loan (EIDL), or state grants that were provided to keep your practice afloat. While this information will not likely impact your reporting, the HRSA is asking for it to be provided. What is clear, however, is that you will not be able to use your PRF funds to pay wages if your wages were already being funded by another program, such as the PPP, Employee Retention Credit (ERC), commercial insurance, or direct patient payments.
Next, you must be able to show that PRF funds were used for COVID-related expenses. Types of expenses may include Personal Protection Equipment (PPE), the rental or purchase of special equipment, wages paid to employees in exchange for COVID-related procedures, such as taking patient temperatures at the door before allowing them to enter.
What Category Will Your Practice Fall Into?
Practices that secured $499,999 or less in PRF funds will be required to report COVID-related incremental expenditures in two broader categories:
- Healthcare Related
- General and Administrative
Practices that receive $500,000 or more in PRF collectively will be required to provide even greater detail.
Whatever funds that are not accounted for by COVID-related expenses can be applied to your practice’s loss of revenue by quarter. Lost revenue resulting from reduced direct patient care must be reported by the payer mix (Medicare, Medicaid, insurance, private funds, and patient payment) quarterly. This information can be obtained via your billing system.
Finally, any funding that was not spent on COVID-related incremental expenses or used to cover lost revenues must be returned to the HRSA within 30 days of the end of the reporting period.
Provider Relief Fund Help Is Available
While necessary, the PRF reporting requirement can be daunting and a little unclear. Fortunately, assistance is available if you need it. Rea & Associates has put together a Provider Relief Fund Task Force. This task force will help clients through the reporting process. Additionally, we will help you meet HRSA deadlines and provide the level of transparency the agency is looking for.
If you would like more information on the PRF or you are looking for guidance, contact our task force today.
By Alan Hill, CPA (Mentor CPA Firm) and Candice Rowe, CPA (Avon CPA Firm)