How to Prepare for HHS Reporting

Last week, the Medical Business Advisory team of KatzAbosch highlighted 5 Time Sensitive Projects Medical Practices Can’t Ignore in 2021. The article announced the start of mandatory reporting for all providers who received more than $10,000 in CARES Provider Relief Funds (aka HHS stimulus funds). The portal is now open for registration only. Providers who received more than $10,000 are encouraged to register as soon as possible.

The release date for the reporting portion of the portal has yet to be announced. In the meantime, please take this time to start gathering the necessary documents/information to prepare for when the reporting portal becomes available.

Please review the information below for a “step by step” process to help you register on the portal and prepare for the reporting phase that should be opening in the near future. 

Step 1: Portal Registration

Before starting the registration process, providers should review the registration guide. The user guide provides step-by-step instructions on how to complete the registration. This process will take approximately 20 minutes and must be done in one session (it does not allow providers to save partial information).

Once reviewed please have the following information available before accessing the portal:

Information Required to Register:

• Tax ID number – TIN or other number submitted during the application process (e.g., Social Security Number (SSN), Employer Identification Number (EIN))
• Business name – as it appears on the W-9 of the reporting entity
• Contact information – Name, Phone number, Title, and Email of the person responsible for submitting the report
• Address – Street, City, State, Five-digit Zip code of the reporting entity as it appears on your W-9
• TIN(s) of subsidiaries – If a provider is reporting on behalf of subsidiary(ies), they will be asked to submit a list of TIN’s delimited by commas – e.g.,123456789,987654321, 135791357
• Payment information – for any and all of the PRF payments received
  • TIN of entity that received the payment
  • Payment amount
  • Mode of payment (check or direct deposit Automated Clearing House (ACH))
  • Check number or ACH settlement date

When you are ready to register visit prfreporting.hrsa.gov to start the registration process. Registered providers will be notified via email when the portal’s reporting function is available. Please ensure the email used to register is accurate and up to date.

Step 2: Consider How To Report Practice’s Metrics

Due to the passage of the Coronavirus Response and Relief Supplemental Appropriations Act in late December, certain changes were made to the Provider Relief Fund’s reporting requirements.

PRF recipients now have the ability to select one of the following methods to apply PRF Payments toward lost revenue, up to the amount:

1. Of the difference between 2019 and 2020 actual patient care revenue; or

2. Of the difference between 2020 budgeted and 2020 actual patient care revenue

• Budget must have been established and approved before March 27, 2020
• CEO or CFO (or similar) must sign attestation
• May be required to submit additional documentation at the time of reporting

3. Calculated by any reasonable method of estimating revenue

• Using this alternative methodology may subject recipients to an increased likelihood to be audited by the Health Resources & Services Administration (HRSA)
• Recipient using this methodology must submit
• Description of the methodology
• Explanation of why the methodology is reasonable, and
• Establish how the identified lost revenues were in fact a loss because of the coronavirus, opposed to loss caused by some other source

Step 3: Gather Expense and Revenue Data

The PRF Reporting System will allow HRSA to assess whether recipients properly used PRF payments according to the Fund’s Terms and Conditions.

A. Healthcare Related Expenses due to coronavirus, net of other reimbursed sources (ie. PPP, Insurance Payments, etc.)

1. Per the reporting requirements notice, entities that received between $10,001 and $499,999 in total PRF payments will report healthcare related expenses in 2 categories:

i. General and Administrative (G&A) expense, and
ii. Other Healthcare Related expenses

As we head toward the end of January, it is not clear as to how the expenses will be reported for recipients within this category. Once HRSA releases the reporting section of the portal, more information about how to report these expenses will be available. The reporting section’s release date has yet to be determined.

2. Reporting entities that received over $500,000 or more (approximately $25M in Revenue) in PRF payments are expected to report expenses in the same 2 categories but in greater detail:

i. General and Administrative Expenses Categories

• Mortgage/Rent
• Insurance
• Personnel
• Fringe Benefits
• Lease Payments
• Utilities/Operations
• Other G&A expenses

ii. Healthcare Related Expenses

• Supplies
• Equipment
• Information Technology
• Facilities
• Other Healthcare Related Expenses

B. Lost Revenues Due to Corona Virus

1. Total Revenue from Patient Care Related Sources in 2020: Recipients will provide information to calculate lost revenues. Net Revenue sources will be entered for the calendar year by quarter (e.g., January-March 2020) AND by payer mix:

i. Medicare Part A or B
ii. Medicare Part C
iii. Medicaid/Children’s Health Insurance Program (CHIP)
iv. Commercial Insurance
v. Self-Pay (no insurance)
vi. Other: Actual gross revenues/net charges from other sources received for patient care and not included in the list above

2. Additional Revenue Information: Depending upon which of the lost revenue calculation options you select (see step 2), recipients will need to provide the following:

i. Option 1 – Lost revenue based on 2019 actual revenue vs. 2020 actual revenue

• If you selected this option you will be required to submit Revenue from Patient Care Payer Mix as outlined above for the calendar year 2019 (by quarter)

ii. Option 2 – Lost revenue based on 2020 budgeted revenue vs 2020 actual revenue

• If you selected this option you will be required to submit a copy of your 2020 budget approved before March 27, 2020, and
• An attestation from the Reporting Entity’s Chief Executive Officer, Chief Financial Officer, or similar responsible individual, certifying that the submitted budget was approved prior to March 27, 2020