Home Health & Hospice Week

Uncertainty over reporting duties continues.

If you missed the Department of Health and Human Services’ announcements that you don’t have to submit a July 10 report supporting your COVID-19 expenses for Provider Relief Funds, you aren’t alone.

HHS released the information in a very low-key frequently asked question posted June 13. “Recipients of Provider Relief Fund payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee,” HHS says on its PRF FAQs webpage.

That FAQ means “there is no report due on July 10,” an HHS spokesperson tells Eli.

This is good news, since the lack of a reporting form and instructions at this late date would have made reporting difficult to impossible, experts note.

But it shouldn’t be a total surprise. Consulting firm The Health Group in Morgantown, West Virginia “never thought that [HHS] would be able to develop a format for reporting use of Provider Relief Funds in time to meet the initially scheduled July 10, 2020 reporting date,” it says in its electronic newsletter.

What’s confusing is that HHS released the information so quietly, says home health finance expert Dave Macke with VonLehman & Co. in Fort Wright, Kentucky. “Something of this magnitude, they should have blasted it out,” Macke tells Eli. Providers have been anxiously waiting for the form and instructions for weeks.

The reporting confusion isn’t over, though, experts warn. HHS hasn’t changed the PRF terms and conditions, which require quarterly reporting.

“HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with” the provision in the CARES Act, and terms and conditions, requiring quarterly reporting, the FAQ says. “HHS will be requiring recipients to submit future reports relating to the recipient’s use of its PRF money. HHS will notify recipients of the content and due date(s) of such reports in the coming weeks,” the FAQ says.

“HHS will release guidance on reporting requirements in the coming weeks,” the HHS spokesperson echoes.

What that future reporting will look like is anybody’s guess, Macke says. “What kind of report? Will it be quarterly or one report at the end?” he asks. It looks like providers will just have to sit tight for those and other answers.

In the meantime: “Continue to identify COVID-19 PHE expenses in … accounting records in a sufficient manner to identify those expenses,” The Health Group advises. “And develop records supporting calculations of lost revenues,” the firm adds. Both those activities are “in support of the use of those funds,” The Health Group notes.

Plus: “Remember, the accounting records will need to accommodate the completion of cost reports encompassing the COVID-19 PHE period, regardless of how those expenses are incorporated into the provider’s cost reports,” The Health Group adds.

Note: The FAQ about quarterly reporting is in the “Reporting Requirements” section at www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/index.html.