Funding, applications, more funding, reporting, more applications and perhaps more funding! The evolution of information is constant. There is hardly time to blink because you might miss something important.
Currently, many who received in aggregate greater than $10,000 from Health and Human Services(HHS) Provider Relief Funds (PRF) in the second quarter of 2020 are now scrambling to put together all of the information required to be reported by September 30, 2021. In the midst of this scrambling, HHS this week announced that there would be another $25.5 billion of PRF monies, i.e. Phase 4 General Distribution, made available to healthcare providers who qualify. The applications for Phase 4 are expected to be available on September 29, 2021. The information on qualification is expected to be issued some time before then.
With the announcement of Phase 4, HHS also announced Phase 3 reconsiderations are available. Providers will now have an opportunity to request a reconsideration if they believe their Phase 3 payment was not calculated correctly according to the detailed information released about the methodology utilized.
Wow, not only are providers faced with the added daily tasks associated with addressing Coronavirus and all of the health issues that the pandemic has brought with it, they now also have to deal with the added stress of the additional costs, lost revenues, various relief applications and reporting requirements! Fortunately, HHS has acknowledged this burden and has recently announced that there will be a 60-day grace period when no penalties will be imposed on those who may not be able to meet the aforementioned September 30th reporting deadline. While it is seemingly great news that there is a grace period, the deadline is still September 30th, so we would recommend making every effort to meet that deadline, if applicable.
In general, the reporting associated with the PRF payments requires the provider to report on the use of funds received. While there are various categories of allowable expenses, the underlying requirement for all expenses is that the funds must have been used to prevent, prepare for, or respond to Coronavirus. As providers are completing the required reporting, we strongly recommend that they review expenses reported for the use of funds to be sure that supporting documentation is maintained for why these expenses are to prevent, prepare for, or respond to Coronavirus.
Quite a bit of additional information, including quarterly patient metrics and quarterly personnel metrics for quarters ended March 31, 2019 through June 30,2021, are required to be reported as well. That being said, blink now, then quickly get working on the reporting process because it is more comprehensive than one may expect. If you have any questions, please contact our office for assistance.
Article Submitted by – Terri L Marakos, CPA, CHBC
