Home Health & Hospice Week

Erase Feb. 15 due date from your calendar.

The Department of Health and Human Services has delayed the first reporting deadline for the Provider Relief Fund, but the feds are still inching forward on the requirement.

Then: HHS was supposed to have a PRF reporting system ready to begin operations on Jan. 15 with a reporting deadline of Feb. 15 for funds used in 2020.

HHS has not set a new deadline for the reports formerly due Feb. 15. However, HHS did go ahead and set up registration capability in the PRF reporting portal. “HHS is encouraging all PRF recipients that have received aggregate PRF payments that exceed $10,000 to establish a reporting account by registering at the newly enabled PRF reporting website,” it says. Providers with less than $10,000 in PRF payments aren’t required to submit a report.

The number of providers that will need to submit PRF reports in the system will be large. As of Jan. 11, HHS has made about $117 billion in payments to 644,091 providers with unique tax ID numbers, the department says in its release.

“A lot” of home health and hospice providers “meet the threshold and will have to report,” expects finance expert Mark Sharp with BKD in Springfield, Missouri.

Along with its delay statement, HHS has issued a new seven-page reporting requirements document that more clearly spells out lost revenue calculations (see story, p. 27), a new six-page Frequently Asked Question set, and a 27-page User Guide for the PRF Reporting Portal.

None of the new materials reference any changes to the second PRF reporting deadline on July 31 for PRF expenditures made in 2021. In fact, the FAQ set notes that “Reporting Entities with unused funds after December 31, 2020, must submit a second and final report no later than July 31, 2021 that includes patient care related revenue amounts earned January 1– June 30, 2021.”

In other words, “the second deadline stands” — at least for now, notes Dave Macke with VonLehman & Co. in Fort Wright, Kentucky.

What Will Registration Trigger?

While HHS is encouraging providers to register in the portal, experts are advising just the opposite. “Don’t register yet,” Macke recommends. “Just let the dust settle.” It’s always possible that earlier registration may bring an earlier reporting deadline, faster repayment timeline, or something else unforeseen and undesirable, he offers.

There’s “no pressure to register until we know the portal is ready to report in,” Sharp acknowledges. And we “don’t know when that will be,” he adds.

Holding off on registering is specifically allowed by HHS, in fact. “There is not yet a due date for the completion of the registration process,” HHS says in FAQ No. 8. “Registration must be completed before you can report on the use of funds. Please monitor the website for further information regarding the due date for reports,” HHS instructs.

“When we know it is open for reporting, I think it will be important to register,” Sharp says. Then “the provider can gain an understanding of how the reporting will work in the portal, and they can plan their final accumulation of the data accordingly,” he tells AAPC.

Right now, home health and hospice providers just don’t know much about how the reporting process will work. “Once again there are more questions than answers,” Macke observes.

In the meantime, stay tuned for further clarifications and updates. “HHS thanks our heroic healthcare providers for their tireless efforts combatting this pandemic and will continue to provide timely and transparent communication as it relates to the PRF program,” the agency pledges.