Practice Management Alert

Question: Now that official Department of Health and Human Services (HHS) details are out about Provider Relief Fund (PRF) reporting, how do I prepare my practice for the now-explicit requirements?

New York Subscriber

Answer: After making sure you’ve absorbed all of the newly released details, stay tuned for further clarifications — of which many are likely. The HHS Health Resources & Services Administration “plans to offer Question & Answer Sessions via webinar in advance of the reporting deadline,” the Department of Health and Human Services says in its new PRF reporting guidance issued Sept. 19. “And as needed, HRSA will also issue Frequently Asked Questions to aid in the reporting process.”

“We expect additional comments and clarifications to be issued on the implementation of these reporting requirements,” predicts accountant Danielle Solomon with BKD in online analysis.

“There are a multitude of questions that remain unanswered related to the use and reporting of PRF funds,” point out attorneys Alexis Finkelberg Bortniker, Monica Chmielewski, Thuong Nguyen, and Anil Shankar with law firm Foley.

Evaluate “lost revenue” change’s impact on your practice. HHS’ switch-up on what counts as lost revenue is “a significant clarification from the frequently asked questions previously issued related to the PRF,” Solomon notes. “It’s important for providers to review these reporting requirements and evaluate the effect on their financial statements,” she urges.

Providers that thought they were in good PRF shape may now be in trouble, and vice versa, offers finance expert Dave Macke with VonLehman & Co. in Fort Wright, Kentucky.

Check your accounting methodology. While it doesn’t explicitly state it, HHS appears to be planning to use accrual-based accounting for reporting, Macke believes. If you are using a cash-based method, prepare now to get your reporting data in line with the other methodology.

Prepare for audits. “We are not sure when, if, and how these audits will be performed,” accountant Adam Brigandi with accounting firm Cerini & Associates says of the audits HHS references. “However, we encourage all providers to generate detailed records to substantiate the information they are submitting with their claims to be able to substantiate the forgiveness they are seeking pursuant to their HHS filings,” he counsels.

Note: The PRF reporting and auditing page at www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html contains a summary of the information and links to the six-page guidance document and FAQs.