Step-By-Step Guide for Using the HHS Provider Relief Fund Reporting Portal

Jan 7, 2022

Step-By-Step Guide for Using the HHS Provider Relief Fund Reporting Portal

Overview of Provider Relief Fund: The Department of Health and Human Services has distributed billions of PRF funds to cover expenses and lost revenue brought on by Covid-19. Providers can use PRF funds to cover expenses, so long as the expense “prevents, prepares for, or responds to coronavirus,” and the expenses were not reimbursed (or obligated to be reimbursed) by any other source. The expenses do not need to be specific to providing care for possible or actual Covid-19 patients, but the lost revenue must be a direct result of Covid-19.The goal is to use up, and get credit for, all your PRF grants (and not have to repay them). Thankfully, HHS makes this relatively easy to do. First, HHS interprets health care related expenses attributable to Covid-19 very broadly, including, supplies and equipment used to provide health care services for possible or actual Covid-19 patients (Note: HHS says that any patient can be a “possible Covid-19 patient”), workforce training, reporting Covid-19 test results to federal, state, or local governments, building or constructing temporary structures to expand capacity for Covid-19 patient care or to provide an area for non-Covid-19 patients separate from where Covid-19 patients are treated, and acquiring additional resources including facilities, equipment, supplies, health care practices, staffing, and technology to expand or preserve care delivery. In addition, employee or contractor payroll, employee health insurance, rent or mortgage payments, equipment lease payments, and electronic health record licensing fees are broad expense categories that are also permitted.

Provider Relief Fund payment amounts not fully expended on unreimbursed health care-related expenses attributable to coronavirus during the period of availability are then applied to lost revenues.

According to HHS, the term “lost revenues that are attributable to coronavirus” means any revenue that a health care provider lost due to Covid-19.

The following, however, are not eligible for PRF forgiveness:  Insurance, non-patient dining services, fundraising events, Prescription sales revenues, Grants or tuition, charity care adjustments, bad debt, retail, auxiliary, or parking services, real estate revenues, amounts of contractual adjustments from third party payors, and gains and losses on investments.

Additionally, PRF funds cannot be used to replace lost revenue if the revenue was reimbursed by any other source, including SBA loans, PPP1, PPP2, FEMA, local/state assistance, business insurance, or any other assistance.

There are three methods for determining lost revenue: 

1. Actual revenue method: Use 2019 calendar quarters as a baseline and determine the difference between actual patient care revenues in each quarter of 2019 as compared to that same quarter in 2020. You can also compare Q1 and Q2 2021 to Q1 and Q2 2019.

2. Budget approach: In this method, the Reporting Entity will use an “approved” 2020 or 2021 budget as a baseline and determine the difference between the budgeted revenues and the actual patient care revenues received in 2020 or 2021, respectively. To be considered an approved budget, the budget must have been ratified, certified, or adopted by the Reporting Entity’s financial executive, executive officer, or other responsible representative, and the Reporting Entity will be required to attest that the budget was established and approved prior to March 27, 2020.

3. Alternate reasonable methodology: Lost revenue may be calculated using any reasonable method for estimating revenues. This requires a narrative explaining your method and an attestation by a senior member of the business explaining how lost revenues were attributable to Covid-19 (as opposed to a loss caused by any other source). Unfortunately, HHS has not provided examples of a “reasonable method.” Whichever method you choose, apply it consistently. This method will receive higher scrutiny from the HHS review and increases your risk of audit. The good news: If a provider chooses this option and is denied, they will have an opportunity to re-report using one of the other two methods.

Note that the revenue periods are broken down into calendar quarters, not full years. This means that if revenue in Q1 2020 was lower than revenue in Q1 2019, you will be eligible for PRF funds in the amount of lost revenue in that particular quarter, even if total annual revenue in 2020 was higher than total annual revenue in 2019. Any quarter in 2020 with revenue in excess of the same quarter in 2019 will receive a zero-balance (or be ignored completely). It will not affect the eligibility of those quarters in 2020 whose revenue is lower than 2019.

Important Dates

Period 1 April 10, 2020 to June 30, 2020 June 30, 2021 July 1, 2021 to September 30, 2021
Period 2 July 1, 2020 to December 31, 2020 December 31, 2021 January 1, 2022 to March 31, 2022
Period 3 January 1, 2021 to June 30, 2021 June 30, 2022 July 1, 2022 to September 30, 2022
Period 4 July 1, 2021 to December 31, 2021 December 31, 2022 January 1, 2023 to March 31, 2023

*Note: only providers who received greater than $10,000 in any reporting period are required to report.

Step-By-Step Guide for Using the HHS Provider Relief Fund Reporting Portal

*Only providers who received greater than $10,000 in any reporting period are required to report.

**Plan to set aside at least a few hours to complete the reporting.

  1. Log in at the PRF reporting website, which Requires a two-step verification. A code will be emailed to the address on file.
  2. Once you log in you will be directed to an entity overview page where you will enter your business information (name, address, etc.). Many of the fields will be pre-populated using the information you provided when you enrolled. Double check the information for accuracy and update any unpopulated fields.
  3. Note: Any data entered will not be saved unless you click the save button. DO NOT exit the webpage or click the “previous” button without first saving your progress.
  4. You will be asked questions about subsidiaries. Answer accordingly. If you answer “yes” to either question 1 or question 2, you will be directed to a separate page with additional questions after you click “Save & Next.” If you selected “no” you will continue to the next step.
  5. The next page will show a pre-populated list of the amounts you received from the PRF. You will be asked to verify the information and will be given a chance to dispute any mistakes in a dialog box. Note that you will only report funds received during the relevant reporting period. The date range will be shown at the top of the page. For all quarters outside of that date range, enter “0” whether you received funds in that quarter or not. If applicable, you will report those numbers in a later reporting period.
  6. Next you will be asked to provide information regarding interest earned on PRF funds, and tax and audit information. You will then be sent to an overview page to review.
  7. On the next page you will be asked to provide a list of all other sources from which you received assistance pertaining to Covid-19 such as PPP, SBA loans, FEMA, etc.
  8. Next you will be asked to list quarterly expenses (for a broad category of expenses) for Q1-Q4 2020 and Q1-Q2 2021 which were reimbursed using PRF funds. Again, you will only report expenses incurred during the relevant reporting period (see date range at the top of the page). If you didn’t pay any expenses for some of these categories, (or if expenses were incurred outside the relevant reporting period) enter “0”.
  9. Next you will be asked to report any other expenses attributable to Covid-19 that have not been reimbursed by another source and are not required to be reimbursed by another source.
  10. Next you will be asked to report your lost revenues attributed to coronavirus. You can use one of three methods:
    1. 2019 actual revenue: Compares revenues in each quarter of 2019 to revenues in the corresponding quarter in 2020 (or Q1 and Q2 2021).
    2. 2020 or 2021 budgeted revenue: Compares 2020 (or 2021) actual revenue to your 2020 (or 2021) budgeted revenue. Requires you to upload an “approved budget (see above)” and the required attestation files.
    3. Alternate reasonable method: Requires you to submit a narrative explaining your methodology, a calculation of lost revenues, and optional additional supporting documents. This will receive additional scrutiny and raises the chances of an audit.
  11. You will have a chance to review the information on the next page.
  12. Next you will be asked to enter information relating to personnel, patients, and facility metrics. This is used by HHS to quantify the impact of the PRF on your business operations.
  13. Next you will be asked to take a survey.
  14. Finally, review and submit.
  15. If you have unused funds, you will be given the option to “return funds” after you click submit.

Visit the PRF portal for a more detailed guide. Or, readers who are more visual learners can watch this 20-minute YouTube clip.

We will work diligently to answer general inquiries via our website if time permits and in a little more detail within our Newsletters. However, if your questions are detailed in nature, please request to set up a conference call for a formal consultation. Thank you.

DISCLOSURE

Collier & Associates, Inc. provides this information as a service to clients and other friends for educational purposes only. It should not be construed or relied on as legal advice or to create a lawyer-client relationship. Readers should not act on this information without seeking advice from professional advisors.

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