On Jan. 15, the U.S. Department of Health and Human Services (HHS) updated its Provider Relief Fund (PRF) reporting requirements to reflect changes required by the recently passed Consolidated Appropriations Act of 2021 (CAA). In addition to calculating lost revenue attributable to COVID-19 based on the difference between 2019 and 2020 actual patient care revenue, PRF recipients may now choose from two other methodologies.
The methodologies are:
Budgeted Revenue: The difference between 2020 budgeted and 2020 actual patient care revenue. If a provider elects this method, they must use a budget that was established prior to March 27, 2020.
Alternative Reasonable Method: This is any reasonable method of estimating lost revenue. If a recipient uses an alternative reasonable method for calculating lost revenues attributable to COVID-19, the recipient must submit a description and an explanation of why the methodology is reasonable, and establish how the identified lost revenues were attributable to COVID-19. The updated guidance also states that the use of an alternative reasonable method will increase the likelihood of a Health Resources and Services Administration audit.
Also, as required by the CAA, the guidance clarifies that a parent organization may transfer targeted distribution funds received by a subsidiary. However, the original targeted distribution recipient remains responsible for reporting on the use of funds.
HHS has opened the PRF reporting portal for recipients to register. However, it has delayed reporting to give recipients ample time to familiarize themselves with the updated reporting requirements in advance of required submission deadlines. HHS did not announce new reporting deadlines as part of this update.