Part II – More Insights on PRF Reporting Guidance: Terms and Use of Funds
Regulation | June 16, 2021 | by Nicole Fallon
This is the second article in a series where LeadingAge analyzes and breaks down the June 11 Provider Relief Fund reporting requirements guidance issued by HRSA/HHS. This article discusses some key terms, additional information about the reporting process and offers additional insights on how the PRF funds can be used.
First, HRSA announced on a June 15 stakeholder call that it has uploaded a revised June 11 Provider Relief Fund reporting requirements document to the PRF website that makes an important clarification for those who received some targeted distributions as nursing homes. The changes clarify that only the Nursing Home Infection Control distribution and incentive payments are limited in their use to infection control expenses. The original document led some providers to erroneously believe that the Targeted SNF Distribution, sent to nursing homes in May 2020, could no longer be used for the broader set of terms and conditions that includes lost revenues related to coronavirus.
The reporting requirements contain a few new key terms that providers should get familiar with in preparation for reporting:
- Payment Received Period: HRSA divides PRF payments into four periods of time based upon when a Provider Relief Fund payment was received, called Payment Received Period. The duration of time a provider has to spend PRF and when they must report on the use of the funds is tied to this period. PRF payments are assigned to the period based upon the date it was deposited by ACH into a providers bank account or the date the provider cashed the paper check. HRSA has offered no indication that it will be issuing a report to providers listing the PRF monies received, and dates deposited so providers are encouraged to examine their bank records now to bucket their payments received into the four payment received periods.
- Period of Availability: This is defined as the period of time in which the funds from a given payment received period must be used. We are clarifying with HRSA when the period of availability begins. It ends with the “deadline to use funds” assigned to the payment received period. All funds can be used retroactively. Data to be submitted as part of the reporting process, including other assistance received, revenues, and lost revenues, will be only for the period of availability.
- Deadline to Use Funds: This is a very straightforward term. It is the last date by which funds from a given payment received period can be used. All funds have a deadline by which they must be spent or returned, in part or in whole. However, all PRF funds can be used for eligible, uncompensated coronavirus expenses and lost revenues retroactively to January 1, 2020.
The dates associated with each of these terms can be found in PRF reporting guidance and in a table LeadingAge created which ties the timelines to the various distributions.
More information on reporting
- More reporting resources will be available July 1, 2021. HRSA is currently developing additional supporting resources for the Reporting Portal and process. They will be available on July 1 when the reporting portal opens for submitting reports. The resources will include a comprehensive user’s guide and toolkit, live and on-demand training on using the reporting portal; and an excel template to help providers organize the data needed. On this last item, unfortunately, the spreadsheet won’t be able to be uploaded into the report. The information contained within the spreadsheet will need to be entered manually into the portal. Providers will be prompted to provide the relevant quarterly revenue data for the reporting period.
- Providers who receive less than $10,000 in any specific payment received period will not need to report for that period. This will be particularly helpful for smaller providers.
- Providers must follow the prescribed reporting schedule for the appropriate payment received period. Providers cannot submit reports early or submit a single report for all the PRF funds received. In most cases, multiple reports will have to be submitted.
- Providers will have a 90-day window to submit reports on a particular payment received period.
Clarifications on how the PRF funds can be used
HRSA and the PRF FAQs posted June 11 offer further clarification on how providers can apply the PRF payments. First, providers should be aware that they can apply PRF to cover eligible coronavirus expenses incurred prior to receipt of those funds and as far back as January 1, 2020. So, for example, a provider who received a PRF payment on April 10 can submit uncompensated expenses for personal protective equipment incurred on February 25, 2020, if used to prevent, prepare for, or respond to coronavirus. In addition, any uncompensated coronavirus expenses and lost revenues from one period can be covered by funds in a future reporting period. Due to this flexibility, there will be overlapping periods of time for reporting.In addition, HRSA confirmed, as part of its June 15 stakeholder call, that hazard pay is still an approved expense for the remainder of 2021 even though the coronavirus situation is improving around the country. However, HRSA said providers should have policies or procedures in place defining hazard pay eligibility and providers should be able to demonstrate that the policies are being consistently applied.
Providers who have unspent PRF at the end of a reporting period will be required to return the unspent amount and this will be done through the reporting portal. The specific process has yet to be defined.
Up next in the series of articles on the June 11 reporting requirements, we will dig deeper into the impacts of the new requirements on lost revenues.