Medicare Compliance & Reimbursement

Expect more clarification and updates with the new administration.

The feds decided to delay the first reporting deadline for the Provider Relief Fund (PRF). Read on for the details.

Then: The Department of Health and Human Services (HHS) was supposed to have a PRF reporting system ready to beginoperations on Jan. 15 with a reporting deadline of Feb. 15 for funds used in 2020.

Now: On Jan. 15, HHS announced a delay to the Feb. 15 reporting deadline. “In late December … Congress passed the Coronavirus Response and Relief Supplemental Appropriations Act which added another $3 billion in funding to the PRF program and included language specific to reporting requirements. HHS has been working to update the PRF reporting requirements to be consistent with this new law,” HHS says in a release. “The department wanted to give recipients ample time to familiarize themselves with the updated reporting requirements well in advance of required submission deadlines.”

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.

Along with its delay statement, HHS has issued a new seven-page reporting requirements document that more clearly spells out lost revenue calculations, a new six-page Frequently Asked Question (FAQ) 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,” acknowledges finance expert Mark Sharp with BKD in Springfield, Missouri. 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 adds.

Right now, 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.

Don’t be surprised to see potential changes as Biden administration officials take over at HHS, Macke points out.

Resources: Links to the new documents are at www.hhs.gov/coronavirus/cares-act-provider-relief-fund/index.html?. The portal, including a link to the FAQs, is at https://prfreporting.hrsa.gov.