Reingruber Alert: Some Good News for CARES Act PRF Recipients

1/19/2021 - By Claudia Reingruber, CPA, CHC

HHS Announces Delay in Reporting Deadline for Provider Relief Funds (PRF): 

  • Reporting delay is due to provisions in the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSA) passed in late December 2020  
  • PRF reporting requirements will be updated to reflect the new law

The PRF Reporting Portal opened 01/15/2021 for registration only:

  • PRF recipients of more than $10,000 can register here: https://prfreporting.hrsa.gov/s/  
  • $10,000 threshold excludes funds from Nursing Home Infection Control, RHC Testing, and payments for COVID-19 services to the uninsured
  • The above link also contains a Registration User Guide, FAQs, and other info
  • Currently, there is no deadline for registration or anticipated date when reporting will be accepted 

Important Changes Due to the Enactment of CRRSA:

  • Options for calculating “lost revenue” have been expanded 
  • Three options are now provided for calculating Lost Revenue:
    • The difference between 2019 and 2020 actual patient care revenue,
    • A comparison of 2020 budgeted revenues to 2020 actual patient care revenue, provided that the budget was prepared and approved prior to 03/27/2020; or 
    • A calculation based on "any reasonable method of estimating revenue” 
  • Recipients using an alternate reasonable method of estimating 2020 revenue must submit additional information, including:
    • An explanation of why their method is reasonable; and 
    • Why the lost revenue was attributable to coronavirus.
  • HHS cautions that “recipients seeking to use an alternate methodology face an increased likelihood of an audit by HRSA” 
  • The updated General and Targeted Distribution Post-Payment Notice of Reporting Requirements as of 01/15/2021 can be accessed here: www.hhs.gov/sites/default/files/provider-post-payment-notice-of-reporting-requirements-january-2021.pdf 

Medicare Providers, CMS Announces New Medicare Cost Report Extensions: 

  • Cost reporting periods ending in 2020 have an additional 60 days from the initial due date to file, due to the ongoing Public Health Emergency.       
  • For example: 

Period Ending    Original Due Date    Extended Due Date
06/30/2020       11/30/2020            01/31/2021
09/30/2020       02/28/2021            04/30/2021
12/31/2020       05/31/2021            07/31/2021 

Note: These are automatic extensions - no request needed. 

The Healthcare Division at Saltmarsh can help: 

  • Assemble required info to register in the new PRF Reporting Portal
  • Evaluate new options available for calculation of “Lost Revenues”
  • Support the reasonableness of the method used to calculate lost revenues
  • Ensure all COVID expenses are identified and properly determined
  • Assess compliance with the Terms and Conditions for each PRF payment
  • Prepare for potential audits of PRF fund use
  • Keep current with ever-changing guidance regarding use of stimulus funds!

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