PRF Reporting Portal Launched, Requirements Revised and Reports Delayed

As promised, on January 15, the U.S. Department of Health and Human Services issued its revised reporting requirements, which incorporate the PRF policy changes outlined in the COVID Relief Bill that passed in late December. They include language LeadingAge advocated for that offers more options for how providers can calculate lost revenues. HHS also announced the opening of the Provider Relief Fund (PRF) reporting portal for registrations but noted the original Feb 15 reporting deadline is delayed until further notice.

Reporting Portal Registration

For now, all providers who have received more than $10,000 in aggregate PRF payments (including those who received Nursing Home Infection Control payments and/or incentives) should set aside at least 20 minutes to register in the newly-launched reporting portal. LeadingAge would recommend providers download and review the instructions in the PRF Portal User Guide and Portal FAQs prior to initiating their registration as these documents contain important information for completing the registration with the least amount of issues. For example, providers should know that the portal does not save data as it is entered for registration and will timeout after 15 minutes of inactivity. If this happens, the provider will need to start over again entering their data. In addition, a number of the data points entered for registration cannot be changed later so careful consideration should be given to the information entered, the email address used for communications, and ensuring accuracy on entering the Tax Identification Number (TIN).

Once the registration is complete, providers will receive an email confirmation from NoReply@hrsa.gov .It is recommended that providers choose the email address associated with the reporting portal carefully and add the NoReply@hrsa.gov email to their safe list so they are assured to receive the confirmation email as well as any future emails regarding PRF reporting.

At this point, HHS gives no indication when the reports will be due but encourages providers to take the time now to familiarize themselves with the requirements.

Reporting Requirement Updates

The January 15 version of the General and Targeted Distribution Post-Payment Notice of Reporting Requirements (“reporting requirements”) make the following changes to the previously issued guidance:

Adds two new options for providers to calculate lost revenues beyond comparing 2019 to 2020 actual patient care revenues:
- Comparison of budgeted to actual patient revenues for 2020. This is only allowed where a 2020 budget was established and approved prior to March 27, 2020. This approach will require additional documentation during the reporting process, which is specified in the reporting requirements. Providers can also use this approach to compare 2020 revenues to those for the first half of 2021;
- Allows providers to use “any reasonable method of estimating revenue” but they must describe the method, explain why it is reasonable, and establish how the losses related to coronavirus. They note this approach increases the likelihood of their reporting being audited and if the methodology is not accepted, will require reports to be resubmitted within 30 days. This option may help providers who added or subtracted service lines between 2019 or 2020;
Creates new reporting entity categories;
Permits parent organizations to report on behalf of their subsidiaries for General Distributions payments even if the subsidiary was the one that attested to receipt of the funds initially;
Allows both targeted and general distribution PRF funds to be transferred between parent organizations and their subsidiaries (previously, only general distribution funds could be transferred within an organization);
Requires the original recipient of targeted distributions to report on the use of those funds even if the funds are transferred elsewhere within the organization and regardless of who received the funds. So, nursing homes will need to report on their Targeted SNF Distributions from May and any of the Nursing Home Infection Control (NHIC)Distribution payments and/or incentives(note: NHIC funds will have different reporting requirements that have not yet been issued);
Adds a requirement to report on any interest earned on PRF payments received and held in an interest-bearing account. Earned interest on PRF payments is subject to the same terms and conditions as the original distribution.