Get to know the latest clarifications on reporting ins and outs. If you blinked over your July 4th vacation, you might have missed important updates to Provider Relief Fund reporting. Background: Last month, the HHS Health Resources and Services Administration announced four new PRF reporting periods and related due dates, which translated to an extension for the use of some PRF funds (see HCW by AAPC, Vol. XXX, No. 22). The first due date is Sept. 30. As promised, HRSA opened the PRF reporting portal on July 1. Along with it, HRSA issued some critical new information and guidance, including clarifications on how to calculate lost revenues and how to repay funds providers couldn’t justify with eligible expenses. Question: For example, one updated Frequently Asked Question reads “Can recipients use 2020 budgeted revenues as a basis for reporting lost revenues?” Answer: “Yes,” the FAQ says. “When reporting use of [PRF] payments toward lost revenues attributable to coronavirus, Reporting Entities may use budgeted revenues.” However, you can only use them “if the budget(s) and associated documents covering calendar year 2020 were established and approved prior to March 27, 2020.” The budget also “must have been ratified, certified, or adopted by the Reporting Entity’s financial executive, executive officer or other responsible representative as of that date, and the Reporting Entity will be required to attest that the budget was established and approved prior to March 27, 2020.” Plus: “Documents related to the budget, including the approval, must be maintained in accordance with the Terms and Conditions,” HRSA
But keep in mind, “the lost revenue calculation will only consider quarters that demonstrated lost revenue,” BKD cautions in online analysis. The reporting FAQs have “resolved several pressing questions about how recipients may calculate lost revenue and whether losses from one ‘period of availability’ can be carried forward to other periods,” says Jed Roebuck with law firm Chambliss, Bahner & Stophel in Chattanooga, Tennessee. (Short answer: They can.) The new information is welcome, for the most part. “Many of the clarifications include additional opportunities for providers to use and retain these much-needed funds,” accounting firm BKD cheers. In addition to updating the reporting-specific Provider Relief Fund FAQs, “to aid providers in preparing their reports, HHS also issued data entry worksheets, updated and added new portal user guides, [and] issued nine pages of reporting portal frequently asked questions (FAQs),” lists law firm McGuireWoods in online analysis. Helpful: “The Reporting User Guide provides detailed instructions for navigating page-by-page through the Reporting Portal, complete with sample screenshots from the portal and Data Entry Worksheets,” Roebuck relates. “We encourage all PRF recipients to review this User Guide thoroughly before beginning their mandatory PRF reporting,” he advises. Note: Links to the materials are at https://prfreporting.hrsa.gov. Stay tuned to HCW by AAPC for more news and analysis about the new reporting requirements and their impact.