CARES ACT Provider Relief Fund Reporting Update

After several delays and many modifications to the reporting requirements, the U.S. Department of Health and Human Services (HHS) has revised the Provider Relief Fund (PRF) Post-Payment Notice of Reporting Requirements that was issued on January 15, 2021. The updated reporting requirements apply to General and Target Distributions, including Skilled Nursing Facilities (SNF) and Nursing Home Infection Control Distribution.

Providers who received CARES Act Provider Relief Fund (PRF) payments exceeding $10,000 in aggregate during a payment received period are required to report in each applicable reporting time period as outlined below.

Summary of Reporting Requirements

This is a welcome change to the original reporting guidance which required all recipients to report the use of funds by June 30, 2021, with a one-month reporting window.

Providers should register in the PRF Reporting Portal prior to their reporting time period as referenced above.

What is needed to register?

Before starting the registration process, recipients should have the following on hand:

• Tax ID Number (TIN)
• Business name of the reporting entity (as it appears on IRS Form W-9)
• Contact information of the person responsible for submitting the report
• Address of the Reporting Entity as it appears on IRS Form (W-9)
• Payment information (for each payment received)

1. TIN of entity that received the payment
2. Payment amount
3. Mode of payment (check or direct deposit ACH)
4. Check number or ACH settlement date

Steps for Reporting Use of Funds

Reporting entities will report on their use of funds using their normal basis of accounting (cash or accrual basis).

Recipients will report data in the following order:

• Interest Earned on PRF Payment(s) – For recipients that held the PRF funds in an interest-bearing account, the interest earned on those funds must be reported.
• Other Assistance Received – Recipients will report other assistance received by quarter during the period of availability.
• Use of SNF and Nursing Home Infection Control Distribution (if applicable) – Recipients will report on infection control expenses paid if the entity received funds from one of those target distributions.
• Use of General and Other Target Distribution Payments – Expenses must be those that were not reimbursed (or obligated to reimburse) by another source. Expenses will include General and Administrative and/or other Health Care Related expenses by quarter. Unreimbursed expenses attributable to coronavirus are considered first in the overall use of the funds.
• Lost Revenue Reimbursement – Those funds not fully expended on health care related expenses as defined above may then be applied to patient lost revenue using one of the following three options:

1. ‍Option 1 – The difference between actual patient care revenue‍
2. Option 2 – The difference between budgeted (prior to March 27, 2020) and actual patient care revenues. ‍
3. Option 3 – Calculated by any reasonable method of estimating revenue.

• Personnel, Patient, and Facility Metrics – Reporting entities will report the following metrics by quarter for calendar year 2019 through the current period of availability.

1. ‍Personnel Metrics – Total number of clinical and non-clinical personnel by labor category. ‍
2. Patient Metrics – Total number of inpatient admissions, outpatient visits, emergency department visits, and facility stays. ‍
3. Facility Metrics – Total number of staffed beds for medical/surgical, critical care and other.

The Post-Payment Notice of Reporting Requirements issued on June 11, 2021, provides extensive detail on the data elements associated with the reporting requirements as outlined above.

As always, your HHM Healthcare Team is available to answer questions and assist with Provider Relief Fund Reporting.

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