CARES Act PRF Reporting Requirements Released

Thoughtware Alert Sep 21, 2020
COVID-19 medicare checklist

On September 19, 2020, the U.S. Department of Health & Human Services (HHS) released its Post-Payment Notice of Reporting Requirements. The instructions require Provider Relief fund (PRF) recipients who have received more than $10,000 in PRF funds to submit the following:

  1. Healthcare-related expenses attributable to the coronavirus that another source hasn’t reimbursed and isn’t obligated to reimburse, which may include general and administrative or healthcare-related operating expenses
  2. PRF payment amounts not fully expended on healthcare-related expenses attributable to the coronavirus are then applied to lost revenues, represented as a negative change in year-over-year net patient care operating income, net of the healthcare-related expenses attributable to the coronavirus

The instructions state that recipients may apply PRF payments toward lost revenue, up to the amount of their 2019 net gain from healthcare-related sources. If a recipient had an operating loss in 2019, it may apply PRF funds to break even in 2020. If recipients don’t expend PRF funds in full by the end of calendar-year 2020, they will have an additional six months to use remaining amounts.

The calculation of lost revenue noted above is a significant clarification from the frequently asked questions previously issued related to the PRF. It’s important for providers to review these reporting requirements and evaluate the effect on their financial statements. We expect additional comments and clarifications to be issued on the implementation of these reporting requirements.

The instructions define data elements related to demographic information, expenses attributable to COVID-19, lost revenues attributable to COVID-19, and nonfinancial metrics.

Timing

HHS has updated its website to state the reporting portal won’t be available until early 2021 (delayed from October 1, 2020, in its July 2020 notice). However, CMS doesn’t appear to have delayed the reporting deadline, so reports for 2020 expenditures and lost revenue related to COVID-19 are still due 45 days from December 31, 2020.

In addition, recipients who don’t expend PRF funds in full by the end of calendar-year 2020 will have an additional six months to use remaining amounts toward the expenses or lost revenues defined above.

For more information, reach out to your BKD Trusted Advisor™ or submit the Contact Us form below.

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