PRF Reporting Period 2 Update for Senior Living & LTC Providers
Senior living and long-term care (LTC) providers are busy preparing for Provider Relief Fund (PRF) Reporting Period 2 as the deadline of March 31, 2022, is approaching quickly. The U.S. Health Resources & Services Administration (HRSA) portal is currently open for providers to log in and start reporting required information. The following summary highlights key differences between PRF Reporting Periods 1 and 2 that senior living and LTC providers should be aware of.
Who Has to File?
Providers that received General or Targeted PRF payments exceeding $10,000 from July 1, 2020, to December 31, 2020, must report on the use of funds in PRF Reporting Period 2.
What Is Different?
Reporting on Nursing Home Infection Control (NHIC) Distributions
This will be the first time that LTC providers are reporting on the use of NHIC distributions. In August 2020, eligible skilled nursing facilities (SNF) received a per-facility payment of $10,000 plus $1,450 per bed. Subsequently, SNFs had the opportunity to receive Quality Incentive Payments (QIP) based on performance measures such as infection and mortality rates. QIP payments were distributed between November 2020 and February 2021 for performance periods September through December 2020. SNFs do have to report on the use of QIP payments during the appropriate PRF Reporting Period based on when the payments were received.
Multisite senior living and LTC providers should be aware that a parent entity cannot report on a subsidiary’s targeted distribution payments. HRSA guidance clearly states that the original recipient of a targeted distribution payment is the reporting entity.
In addition, lost revenues cannot be used for NHIC distributions. Providers can only report eligible infection control expenses not reimbursed from other sources. Providers will report these eligible NHIC expenses quarterly during the Period of Availability, which is January 1, 2020, through December 31, 2021, for PRF Reporting Period 2.
Information from Reporting Period 1
Information reported by providers in Reporting Period 1 will automatically populate into certain steps within the portal for Reporting Period 2. Providers will be able to change this information and need to be careful not to accidentally key over or update the information in error. We recommend that providers implement a strong review process around PRF reporting. For example, providers could assign a reviewer who is separate from the person entering the data into the portal. The person entering data could print the screens after all data is entered. Then, the secondary reviewer could input data into the portal with supporting information from Reporting Period 1 before an entity hits the submit button.
What Is the Same?
Senior living and LTC providers still have to report lost revenues for Q3 and Q4 of 2021 even if they only received NHIC distributions during Payment Received Period 2. Providers should have this information accumulated in the necessary format including any required attachments. The lost revenues by quarter will accumulate and can be applied to future reporting periods.
While not used in the calculation of unused funds, providers will have to accumulate and report certain personnel, patient, and facility metrics for an additional two-quarters similar to Reporting Period 1.
Finally, the reporting portal includes a survey at the end of the reporting process where providers can provide information to HRSA regarding the financial and clinical effects of the PRF payments received from July 1, 2020, through December 31, 2020. In addition, providers can include a short narrative, up to 1,000 characters, describing the devastating impacts of the pandemic on their operations.
What to Do Now?
- Review all available guidance on PRF Reporting Period 2.
- Gather all necessary information and supporting documentation for amounts that will be reported in the HRSA portal.
- Ensure that amounts reported meet the terms and conditions of PRF funding.
- Log in to the portal and on the “payments to recipient” step, agree the prepopulated payments received in Reporting Period 2 to internal records. If the populated amounts are not correct, providers should call the Provider Support Line to resolve. Providers cannot proceed to subsequent steps in the reporting until the dispute is resolved.
- Plan appropriately to be able to meet the March 31, 2022, deadline, as there are no extensions currently available. Providers that fail to report will be out of compliance with the terms and conditions of the PRF funding and will have to return applicable PRF payments.
The following resources provide additional guidance regarding NHIC distributions and eligible expenses:
- Nursing Home Infection Control Distribution | Official web site of the U.S. Health Resources & Services Administration (hrsa.gov)
- Targeted Distribution Questions | Official web site of the U.S. Health Resources & Services Administration (hrsa.gov)
- Provider Relief NF Infection Control Payment Terms and Conditions (hrsa.gov)
In addition, resources are available on Period 2 Reporting at the following links:
- Provider Relief Fund Reporting Requirements and Auditing | Official web site of the U.S. Health Resources & Services Administration (hrsa.gov)
- Reporting and Auditing Frequently Asked Questions | Official web site of the U.S. Health Resources & Services Administration (hrsa.gov)
- Reporting Resources | Official web site of the U.S. Health Resources & Services Administration (hrsa.gov)
Please reach out to your BKD Trusted Advisor™ or submit the Contact Us form below if you have further questions regarding PRF reporting.