Provider Relief Fund Reporting Update
By Keith A. Solomon, CPA, Partner, Menachem Gongola, CPA, Senior Manager, and Krista Karabel, CPA, Manager
Recipients of more than $10,000 in Provider Relief Funds (PRF) are required to report healthcare related costs attributable to the coronavirus less any costs that have been reimbursed or are obligated to be reimbursed by another source and lost revenue in the PRF reporting portal.
The PRF reporting portal was scheduled to open on January 15; however, due to the passage of the Coronavirus Response and Relief Supplemental Appropriations Act in December 2020, the PRF reporting portal is currently open for registration only. In addition, the original submission deadline for the PRF reporting portal of February 15, 2021 has been delayed. New dates for the opening of the PRF reporting portal for funds used/lost revenue and the reporting submission deadline have as yet not been provided by the U.S. Department of Health & Human Services (HHS).
While healthcare entities wait on the opening of the PRF reporting portal, there are several data elements that providers should consider gathering in anticipation of the eventual opening of the portal:
- The PRF reporting portal is open for registration. 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. While there is currently no deadline for providers to establish a reporting account in the newly- enabled reporting portal, all providers will be required to complete this first step. The link to register is here.
- Gather and summarize eligible healthcare related expenses. Healthcare expenses must consist of costs incurred to prevent, prepare for, and/or respond to coronavirus and will need to be segregated by General and Administrative expenses and other healthcare related expenses.
- Providers should determine how lost revenue will be calculated for their entity. There are currently three options for the calculation:
- Calculate the difference between 2019 and 2020 actual patient care revenue. This method is probably the easiest to report and support for providers.
- Calculate the difference between 2020 budgeted and 2020 actual patient care revenue. The key with using this method is that the budget you use must be established and approved before March 27, 2020.
- Calculate lost revenue using an alternate reasonable methodology. This method will require approval and also has an increased likelihood of an audit by regulators. In addition, under this method, the provider needs to include a description establishing how lost revenue is a loss attributable to the coronavirus as opposed to a loss caused by any other source.
- Interest earned on Provider Relief Funds is considered a reportable revenue source. If a provider held PRF funding in interest-bearing accounts, the amount of interest earned on the PRF funds must be reported. Providers should calculate the interest earned on PRF funds in anticipation of reporting these funds in the PRF reporting portal.
The Healthcare Practice at PKF O’Connor Davies is available to assist you with the various compliance reporting and other requirements imposed by federal agencies. We also provide a full spectrum of audit, tax and consulting services for Healthcare not-for-profit and for-profit entities. For more information, please contact your client service partner or any of the following:
Keith A. Solomon, CPA
Healthcare Practice Co-Leader
Menachem Gongola, CPA
Krista Karabel, CPA