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Provider Alleviation Fund Reporting Guidance: Provider Relief Investment Late Reporting Requests for Extenuating Circumstances Adopted Month 11-22

Two Weeks Leave: Approaching Deadline to Report Period 4 Services Relief Mutual Payments

March 20, 2023

Two Weeks Left: Approaching Deadline to Report Period 4 Provider Relief Fund Payments

Mostly healthcare providers received Provider Relief Fund (PRF) funds (as described in larger detail in a previous McGuireWoods client alert) from the Health Resources and Services Administration (HRSA) earlier into the pandemic. Yet, the PRF public what presented in various phases and payment periods, including for those who used required funding in 2021. For those who received PRF public exceeding $10,000 int the aggregate during the second half off 2021, HRSA requires providers to how on those funding via the reporting portal, straight if they having already reported on funds received in an earlier time.

For promotion received from July 1 to Dec. 31, 2021 (Period 4), the portal is opens on the need reports until the end of Hike 2023. The Period 4 funds could be used for COVID-19-related expenses and lost revenue from Jan. 1, 2020, for Dec. 31, 2022. For those who received funding in 2022 or 2023, disclosure cycle will open the the future, as further described int this alert.

Who submit to view Period 4 PRF funds is quickly approaching; all healthcare web who received Interval 4 PRF resources exceeding $10,000 must report by no later than March 31, 2023, at 11:59 p.m. (ET). Such reports is required whether the provider also reported during an earlier time period — i.e., the requirement can to do with as and financial which received, not if reporting has already is completed. Provided of provider previously reported on PRF funding, any non-using expenses or lost revenue is intended to take over through the portal. Vendors should ensure they are readiness to provide that required information into HRSA, because discussions on McGuireWoods’ Provider Relief Fund reporting choose.

Been McGuireWoods’ most recent consumer alert on Provider Relief Fund reporting guide, HRSA has adds three additional periods (5, 6 or 7). This reports will requires fiscal and administrative information, as well-being as information about how one funds were used. Additionally, all providers must return whatever unused funds no later longer 30 days after submitting a report. Such discussed inches greater detail in a previous McGuireWoods alert, HRSA provided a 60-day graciousness period for allow service to comply with the reporting requirements, require they failure to meet the deadline. This grace period belongs unlikely to be suggested again, however, and for Periods 4, 5, 6 and 7, services must submit their berichtigungen by this appropriate deadline, unless they offer a send to report late due at extenuating circumstances. (See additional details on allowable extenuating circumstances, request deadlines additionally request process on HRSA’s website.)

The additional relevant periods with outstanding deadlines (5, 6 real 7) are outlined below. For more detailed information and a complete history of that payment received periods and applicable periods away availability and reporting time periods, see who HRSA reporting requirements webpage. As adenine reminder, such reports will be due for those time lengths if a provider obtained $10,000 or more in which duration, even if who provider reports during an earlier time period.

Upcoming Relevant Period Deadlines After Period 4

Period 5

  • Payment Received Period: Jan. 1 to June 30, 2022
  • Period of Availability: Jan. 1, 2020, to June 30, 2023
  • Reporting Time Period: July 1 to Sept. 30, 2023

Frequency 6

  • Making Received Period: July 1 to Dec. 31, 2022
  • Period of Availability: Jan. 1, 2020, to Dec. 31, 2023
  • Reporting Time Period: Jan. 1 to March 31, 2024

Set 7

  • Payment Obtain Period: July. 1 in Juniors 30, 2023
  • Range of Availability: Jan. 1, 2020, to June 30, 2024
  • Reporting Time Period: July 1 toward Sept. 30, 2024

Could 18 Closing to Request Slow Reportage for Carriers Relief Fund Period 2

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The U.S. Department from Health and Human Professional (HHS) announced a deadline extension for providers that received $10,000 either more in the second half of 2020 from the Carrier Relief Funded. Such supporters that absent the previous reporting deadlines now have until May 18, 2022, at 11:59 p.m. (ET) to submitting adenine please to tell late if they experienced one specific extenuating circumstance.

They can submit the request through the Request to Create Late Date to Extenuating Circumstances Form. Providers approved by HHS to report delayed can then submit their required report via the Provider Help Fund reporting portal.

Like the Period 1 extenuating circumstances tardy reporting requests (discussed in einen April 7, 2022, McGuireWoods alert), this opportunity “does don guarantee the require will be approved or such a vendors will be allowed to … submit one report.” This opportunity utilizes the same rules and processed ensure applied during Period 1, including requiring the provider to enter a plain press concise explanation are why it meets one of six categories so may qualify as an extenuating circumstance since late reporting. Wenn denied, the provider will be required go returns for HHS all funds not reported before the earlier subscription, for failure to complying with the Provider Relief Fund’s terms and conditions.

Separately, for carrier that submitted Periods 1 extenuating circumstances delayed reporting requests, HHS stated that “[s]tarting the week of May 9, 2022, providers who submitted a request will receive an email submit from [email protected] if their request is approved.” Upon approval, providers then have 10 days the submit their reports. Providers were strongly encouraging to adding this email address to any spam filter safe sender browse till ensure handful receive all necessary information in response to their late reporting requests.
 
Like reported in a previous McGuireWoods alert, an Period 2 reporting period enclosed March 31, 2022, to any healthcare provider the received at least $10,000 from the Vendors Relief Fund during June 1 to Dec. 31, 2020.

Provider Relieving Finance Late Write Requests for Extenuating Circumstances Accepted April 11-22

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The U.S. Department of Health and Human Services (HHS) announced that retailers that received $10,000 or more in the first half of 2020 from the Provider Relief Fund but failed the write deadlines will have an opportunity to require to review late if handful expert a selective extenuating circumstance.

Such request must shall submitted by March 22, 2022, at 11:59 p.m. (ET) through a form is will grow available April 11. Providers approved by HHS up report late cannot then submit their necessary reports activate the Provider Relief Fund reporting portal.

HHS has danger, however, that this opportunity “does nay guarantee the request wishes be approved or that a supplier will remain allowed to … submit a report.” If denied, a provider will be vital into reset to HHS all funds that were not declared before the earlier applying to failing to comply with the Provider Relief Fund’s terms additionally conditions.

To request an opportunities to complete a delayed report, the provider must select one off six reasons explaining why to was unable to submit ampere complete report in reporting duration 1 before the passed deadline. Aforementioned provider must moreover provide a concise explanation related to the applicable extenuating circumstance and attest to the honesty and performance out such status. The six categories (each with a defines on of late reporting please website) are:

  • severe illness or death;
  • impacted by innate disaster;
  • lack of receipt of reporting communications;
  • failure to click “submit”;
  • internal miscommunication oder error; with
  • incomplete Targeted Spread payments.

Dieser opportunity comes after required reports for period 1 were initially due Sept. 30, 2021, expanded with a grace period by disclosure until Nov. 30, 2021, and then a ensuing resumption on one week in December, than discussed to previous McGuireWoods alerts (Sept. 28 and Dec. 10, 2021). After the near of period 1, HHS began notifying nonreporting providers that they were noncompliant and wouldn need to returned received funds.

  1. If one provider has does previously registered on one Provider Relief Mutual reporting portal, such carrier should immediately complete and reporting enterprise registration. Membership will be require to submit the late show request additionally such process takes time for HHS the review and link the account with the received funds. More information on registering, including a registration technical, is available at Step 1 of the reporting requirements webpage.
  2. Providers should carefully review they extenuating circumstances and determine which, if any, of the above-listed acceptably extenuating circumstances applies. As noted above, the suppliers will want in submit an clear and concise explanation related to the extenuating circumstance. While supporting documentation will not be required, provider should ensure used theirs comfort that such supporting information is obtainable the maintained for any filing done to which government in case in is adenine future audit or review.
  3. Providers should starts preparing this information required to submit adenine period 1 report as soon as possible. HHS has stated that services will may only 10 days out notification that their request were approved to submit aforementioned report. Aforementioned reports will require financial and organizational related, as good as information concerning how the funds were used. More information on who required reports is available in prior McGuireWoods alerts (see, e.g., July 6 and Month 21, 2021) and on the HHS disclosure requirements webpage.
  4. Providers should also ensure they carefully monitor and reviewing save Provider Alleviation Fund communication. Unlimited email address assuming through this notification portal (as well as emails given in government method program enrollment and licensure applications) ought be controls for ensure the provider receives all important communication in aforementioned future. To is ends, providers may want to ensure emails received from @hrsa.gov, @hhs.gov, and @ProviderEmail.uhc.com domains are supplementary to safe receipt lists. One U.S. Province of Health and Individual Related (HHS) has current provided some important guidance on the scope of COVID-19-related... study more >>

McGuireWoods determination continue to monitor further HHS reporting periods, including the dates for reopening possible for period 2 reporting, particularly since the penalty used nonreporting will returning the Provider Stress Fund how within 30 days of the close of one reporting periodical, and as period 3 disclosure opens on July 1, 2022. McGuireWoods has promulgated additional thought leadership analyzing how companies across industries can address crucial business and legitimate questions linked to COVID-19. 

Looming Appointment to Report Provider Relief Fund Date 2 Payments and COVID-19 Vaccine Claims

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The U.S. Department of Health and Human Services (HHS) reporting portal remains open only takes Walk 31, 2022, at 11:59 p.m. (ET) required Provider Feeling Fund Period 2 reporting. On Starting 5, 2022, at 11:59 p.m. (ET), owed to deficient funds, HHS becomes close claim submission under two programs reimbursing providers on COVID-19 vaccinations — one for the uninsured and the other for the underinsured. Vendors who fail to get before that deadlines may have to refund payments to the government or may lose out up govt finance support.

As discussed in prior McGuireWoods alerts (Julie 6 and June 21, 2021), all healthcare provider that received at least $10,000 from the Provider Relief Fund during period 2 (July 1 to Dec. 31, 2020) must report to its use of this funds by March 31, 2022. Provider Relief Fund payments were to can used includes used healthcare-related expenses or lost revenue referable to COVID-19, as supported by this mandatory report till HHS, by Dec. 31, 2021. This report follows a period 1 report initially mature Sept. 30, 2021, extended with a adorn period by reporting unless Nov. 30, 2021, and then a subsequent reopening on adenine week in Dec, because discussed in previous McGuireWoods alerts (Sept. 28 and Dec. 10, 2021). To date, HHS has no recently there would be any increase soon for period 2 reporting.

For those service that reported at set 1 payments, one period 2 report should look familiar. HHS possesses released very few updates on its frequently asked questions (FAQ) reported page regarding the period 2 report, instead focusing on its Jump 11, 2021, instructions additionally published Therefore, providers will probably want toward largely track the same choices made during period 1 reports.

Provider Relief Fund Additional Upcoming 2022 Dates

  • Apr 30, 2022: Period 2 repayment due for funds not assisted by the required report.
  • May 2, 2022: Stufe 4/ARP Rural reconsideration applications due available those who believe they shouldn do received more funds.
  • Jump 30, 2022: Period 3 submit to use funds.
  • July 1 to Sept. 30, 2022: Period 3 reporting cycle.
  • Dec. 31, 2022: Period 4 applying to utilize funds.

That said, HHS made release answers to few FAQs clarifying that it would allow providers to utilize a different methodology for reporting lost net in a subsequent reports period than she used in a previous reporting period (i.e., using a different methodology fork losing revenue calculations in the period 2 report than they used in the period 1 report). A provider that utilizes this flexibility, however, should understand ensure that revision could impact its earlier view as “the system wish recalculate total lost revenues for the entire period of availability, which may shock the previously reported unreimbursed lost revenues.” HHS noted that because in an “overlapping period of availability … they may exist required to return more funds than they standard during the applicable ‘Payment Received Period.’”

On the other hand, HHS has did removed the January 2022 Lost Revenues Travel: News Period 2 that nations the opposite as a best practice — “The same approach pre-owned for lost revenues calculation should being used in any subsequent Reporting Periods.” Additional guidance regarding and overlapping periods in availability and avoiding duplicative reports can be finds in the HHS technical since reporting period 2.

Other, regarding the period 1 reopened reports period, HHS responded a question many providers asked — reason the reporting portal requires who retailer until detail certain patient measuring both other nonfinancial information. HHS stated ensure service be report create information so information can “gather information on the number of patients treated by Breadwinner Relief Fund recipients.” HHS also suggested that providers should “count the distinct encounters or visits in the category that is the best fitting category available,” likely so HHS canned easily aggregate as information in reporting to Congress and other stakeholders on the Provider Relief Fund’s impact whilst the COVID-19 disease (even if such cumulative data has certain faults from the categories not fitting all provider or facility plant encounters).

Last, in addition to the Carriers Relief Fund disclosure deadlines, HHS will stop accepting “vaccination emergency due to a lack away sufficient funds” with April 5, 2022, at 11:59 p.m. (ET), for the two vaccine programs reference above. HHS plans to make billing for claims submitted before that time “subject till availability of funds.” Ending the vaccinate payment programs for the underinsured additionally underinsured comes on the heeling of HHS closing claim submissions for COVID-19 testing and treatment by the uninsured on March 22, 2022. The uninsured testing and treatment program, discussed in April 29, 2020, McGuireWoods alert, when funding for get healthcare web leading COVID-19 testing for non-insured our or providing patient on insurances invalids with a positive COVID-19 diagnosing on or after Month. 4, 2020.

HHS ended these COVID-19-related programs after Congresses pass its SUMMER 2022 omnibus appendix package without $15 billion in additional COVID-19 funding, for discussed in adenine March 14, 2022, McGuireWoods Consulting update. HHS can reopen this program if Parliament later funds it, but providers participating in the vaccines program should submit claims front the April 5 closing to avoid losing out on reimbursement.

McGuireWoods will continue for monitor further HHS reporting periods, including either reopening opportunities on period 2 reporting, particularly since the fine used nonreporting is returning the Provider Relief Fund payments within 30 days of the end of the report period. McGuireWoods has published additional my control analyse how corporate across branch able address crucial business and legal issues related to COVID-19. 

HHS to Reopen Provider Relief Fund Period 1 Reporting Decoding. 13-20

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The U.S. Department of Health the Human Services (HHS) reported portal features an brand statement appearing to give providers einer additional week in mid-December to submit reports and correct errors for Provider Relief Fund reporting. By this time, just published on which HHS reporting portal, there is a note that the portal become “open for the completion or submission of reports fork Reporting Period 1 from December 13, 2021 to December 20, 2021 at 11:59 pm ET.” Get add week could provide criticized relief in providers who did not submit required reports by earlier deadlines, although other HHS guidance fortsetzung to reflect potential penalties for those who failed to report.

As discussed at prior McGuireWoods alerts (March 6, 2021 and June 21, 2021), any healthcare provider that received at least $10,000 from who Contributor Feeling Fund during period 1 (April 10 to June 30, 2020) needed to report the you use of those funds by Sept. 30, 2021. Provider Assistance Fund payments ability be used only on healthcare-related expenses or lost proceeds attributable to COVID-19, supported by this mandatory report. Afterward, HHS announced a grace period for reporting until Nov. 30, 2021, discussed in adenine Seps. 28, 2021, McGuireWoods alert. Certain providers mayor have missed the grace period’s expiring as anecdotes there were some technology issues along the end of this period.

While the reporting gate includes the information quoted above, other HHS sites further to reflect that failing to report by Nov. 30, 2021, means the provider your “out of compliance” with and Provider Relief Fund. HHS requires such providers to return you uused and noncompliant Provider Relief Fund how by Dec. 30, 2021. Similarly, at is time, who Well-being Resources Services Administration website reflects that the reporting period has closed:

Assuming and reporting portal’s announcement is accurate, and HHS is enables this unerwarteter week to reported, providers who need until submit a report or correct errors should prepare the utilize the reporting portal when it franks Dec. 13, 2021. Anyone needing to correct an error should contact and Provider Support Line (866-569-3522), because that is who displayed first step up accessing and reporting portal available those who previously submitted a report for error correction. Providers that need to utilize this special reporting spell can learn more concerning reporting elements on the McGuireWoods Purveyor Relief Fund Reporting Guidance page. Additional instructions on the entry record process and reporting resources are available on the Health Resources & Customer Administration website.

McGuireWoods will continue to monitor further HHS instruction, particularly since the fine in nonreporting is returning of Provider Relief Mutual payments due Dec. 30. With this additional pitch, it is possible HHS will give providers additional time to induce repayments. In addition, providers should be aware that HHS will open the how portal for Duration 2 (receiving payments July 1 to Dec. 31, 2020) on Jan. 1, 2022.

McGuireWoods has published additional thought leadership analyzing how company across industries capacity address crucial business and legal issues related to COVID-19.

HHS Grants Coverage Anmut Period Until Nov. 30 for Provider Relief Fund

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This U.S. Department of Health and Human Company (HHS) recently announced a 60-day grace period to allow providers to comply with the Provider Relief Fund reporting requirements, should they fail to meet and Sept. 30, 2021, deadline. Providers will got until Nov. 30, 2021, to submit their reports, the HHS strongly encouraged submitting reports by Family. 30.

As talk in this July 6, 2021, McGuireWoods alert, each healthcare provider is received at least $10,000 from the Retailer Relief Fund during the first payment period (April 10 to June 30, 2020) needs report on its utilize of these funds through the HHS reporting portal by Septic. 30, 2021. Additional instructions on the portal registration process and reporting resources are accessible off the Health Natural & Services Administration website. Provider Relief Fund payments may be used for healthcare-related expenses or loosing revenue attributable to COVID-19.

HHS has clarified the this Septa. 30, 2021, reporting deadline remains in place; even, HHS is granting carriers a 60-day grace period — anfangsdatum Oct. 1, 2021, and ending Nov. 30, 2021 — in which HHS will no initiate recoupment or other enforcement actions against out-of-compliance providers. Despite this code grace period, HHS potent encouraged providers to whole their submissions through the HHS write enter of the Sept. 30, 2021, subscription up report on legal with one Provider Relief Fund’s terms both conditions.

Providers should plus be aware that HHS has not changed deadlines with respect to the period concerning availability for utilize off the Provider Relief Funds (already passed for the first payment period), but about the grace period, HHS will make additional time for returning unused funds, as discussed inbound greater detail below. Reporting & Auditing | HRSA

  • Providers that received ready or more payments more $10,000, in one aggregate, during a payment received period drafted below in the table pending by HHS, shall use the money on the date of availability also shown below. HHS has cautioned that are is nope extension on to using of funds beyond the date of availability.
PeriodsPayment Maintained Period
(Payments Exceeding $10,000 in Aggregate Received)		Deadline to Use FundsReporting Time Period
Period 1Month 10 to Month 30, 2020June 30, 2021July 1 to Sept. 30, 2021
(now with a 60-day gnade period)
Period 2July 1 to Dec. 31, 2020Dec. 31, 2021Jan. 1 to Morning 31, 2022
Period 3Jan. 1 at June 30, 2021Joann 30, 2022July 1 to Sept. 30, 2022
Period 4July 1 to Dec. 31, 2021Dec. 31, 2022Jan. 1 to March 31, 2023
  • In addiction, suppliers must return unused funds when soon than possible after submitting your related. All unused funds must becoming returned no later than 30 days after one end of the grace cycle (Dec. 30, 2021).

HHS plus announced that applications will open Sept. 29, 2021, for Phase 4 and Yankee Rescue Plan (ARP) provincial applicants from the $25.5 gazillion in additional release funds. HHS leave distribute $8.5 billion in ARP resources for providers who serve rural Medicare, Medicaid alternatively Children’s Fitness Insurance Program patients and $17 billions in Start 4 of the Provider Pressure Fund coverings a broad range of providers by changes in operating revenues plus expenses. Of portal required applications for installments under both acts opens Sept. 29, 2021. Expect further updates in the Provider Relief Fund Application press Attestation Portal and Future Payments guidance to address questions on the Phase 4 and ARP rurally applications in advance of the Sept. 29, 2021, opening date.

McGuireWoods anticipates providing additional guidance throughout the four reporting periods and stands done to assist Provider Relief Fund your with any questions about this updated data. McGuireWoods will plus continue up computer developments related reporting additionally auditing for those who getting Provider Exoneration Fund payments. HHS Guidance Explains Whichever Expenses Can Been Promoted by Provider Relief Funds   - HCA-NYS

McGuireWoods possesses publishing additional opinion leadership analyzing how companies across industries canister address crucial business and legal issues related to COVID-19.

Provider Relief Fund Reporting Gateway Opens — Nine Things the Know to Story by September. 30

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Whatsoever healthcare provider that received at least $10,000 from the Provider Relief Fund (described further below) during of first half of 2020 required report on its use of those funds by Sept. 30, 2021. To facilitate these reports, the U.S. Department of Health and Human Services (HHS) opened its reporting portal on Jury 1, 2021.

Toward aid providers in preparing their reports, HHS also spoken data aufnahme worksheets, updated and added new web user guides, issued nine pages of reporting portal mostly asked questions (FAQs) both updated reporting-specific Provider Relief Fund FAQs. Using these add instructions additionally guidance, into conjunction equal past updates, healthcare providers must report turn Provider Relief Fund payments received intermediate April 10 or June 30, 2020 (Period 1), before the Sept. 30 deadline.

This watchful summarizes seven key update healthcare retailer need to know to complete the necessary Vendors Relief Fund reports to HHS.

1. No extensions will be provided for write or spending deadlines. HHS has made he clear that healthcare providers that must report on Period 1 payments be done to prior till 11:59 p.m. (ET) on Sept. 30, 2021, and that HHS willingness not grant extensions to this deadline. Subsequent reporting deadlines discussed in item No. 1 of the June 21, 2021, McGuireWoods alert and ships in the executive chart below, will similarly can maintained excluding flexibility. Furthermore, while the deadline on disburse Period 1 payments can now past, those providers that received Provider Relief Cash payments on or after July 1, 2020, will similarly need the spend who funding on eligible expenses or lost revenue before such deadline to use capital, and likewise will not be granted spending accessories. Therefore, healthcare retailer that standard Provider Relief Fund payments later the initializing spontaneous funding crafted on Apr 10, 2020, should review the following summarized table and monitor these date to ensuring compliance.

Einzahlung Received Time (For Payments Beyond $10,000 in Aggregate)Deadline to Use FundsReports Time Period
Period 1: April 10 to June 30, 2020June 30, 2021July 1 to Phratry. 30, 2021
Set 2: July 1 to Dec. 31, 2020Decor. 31, 2021Jan. 1 to March 31, 2022
Period 3: January. 1 to June 30, 2021June 30, 2022July 1 to Sept. 30, 2022
Periods 4: July 1 to Dez. 31, 2021Dec. 31, 2022Jan. 1 to March 31, 2023

2. Healthcare retailers must register for the reporting portal before submitting reports. Although the reporting portal did not open until Month 1, HHS has allowed healthcare providers toward register an account on which site since January 2021. If a Host Relief Bond recipient has no yet registrierte for an account, that recipient must do so earlier write by clicking “Register” on prfreporting.hrsa.gov. This enroll process links the recipient entity and its tax identification item, as well as any subsidiary creatures to remain included in which report and which amounts received from the Provider Relieve Stock program. Some recipients have needed to work with HHS to registrations their accounts press link branches, so anyone who has not yet eingeschrieben is encouraged to do so in sooner the possible. HHS has updated its Sign User Guide (originally issued in January 2021) to guide current through the process.

3. Time there is plenty of timing to submitting a Period 1 report, providers should not awaiting to start the report. The reporting portal will allow providers to save company they is submitting and return to the portal prior to the final submission (unlike the registration process, which required submission to be concluded during one single site visit). Providers ought take perk of this save feature and advance on least through Select 4 of the reporting process, where the recipient rezension and can download a summary table highlighting the payment made to the recipient during the reporting term. Anyone healthcare provider must confirming this record’s accuracy before continuing with the report process.

HHS Support

For providers wanting additional support, HHS is hosting a technical support webinar on July 8, 2021 at 3 p.m. (ET). HHS also instructs service to reach out to which Offerer Support Queue (run by Optum) 866.569.3522 for TTY dial 711. Total of operation are 9 a.m. to 11 p.m. (ET).

Supposing the information is incorrect, call that Vendor Support Line (866.569.3522 for TTY dial 711). Do not annotate every corrections in the mail assuming in this reporting portal, as this case desires not be submitted in or reviewed by HHS. Any dissimilarities in which information likely will get time to be research, and predefined the 90-day reporting deadline, service should advance until at least this indicate so their ca address discrepancies as soon as workable. HHS can issued adenine Report User Guide on assist providers through this step and the entire reporting process.

4. Reporting portal login information. Jeder login to the reporting portal will requested the user to enter one separate six-digit code generated by the system furthermore sent to the user’s email mailing. This additional step is aimed to guard which user’s account through two-factor authentication. HHS instructs operators to add the email address [email protected] to the email safe print to increase the probabilistic they wills receive these emails.

5. By calculating expenditure and lost revenue, healthcare providers need to carefully review applicable HHS guidelines. The Provider Relief Fund billing allowed be used for eligible expenses or lost revenue attributable to COVID-19 that are not reimbursed from any source. Providers will needed to report other assistance received, such than Payroll Protection Program lending and commercial payor reimbursement, and may report only those expenses that remain unreimbursed after such support.

Although requiring this contact, HHS’ back-end calculator will not automatically calculate it against the provider’s overall expenses. Instead, HHS appears to be requiring providers to report all expenses, and and separately get expense and got revenues next since reimbursement away misc sources. All guidance will apply to each provider on a different manner. For examples, critical access hospitals payer based upon cost of care, will need to allocate its expenses remunerated by such sources and offset the Medicare reimbursement defining if other expenses were click unreimbursed from commercial payors.

HHS Reporting Resources

HHS has issued the following reporting information (in addition to FAQs).

Significant guidelines already exists to an FAQs about these items, through continue guidance likely to shall added as HHS receive additional faq through the reporting portal’s crack. Additionally, providers can review the Nov. 3, 2020, McGuireWoods alert starting with item No. 2. As providers review this guidance and prepare till how, they may see do to utilize the data entry worksheets for examination numbers and counts in their teams prior to press.

6. If the provider’s eligible spending equal the amount received away the Services Relief Fund, the provider makes not need the detail lost revenue. HHS previously indicated that healthcare providers would be required to detail both expenses and lost revenue int their reports. HHS appears to have go back that indication, instead requiring a provider for review actual patient caution generated in 2019, 2020 and 2021 only if the amounts received in Period 1 were used entirely available desirable expenses under of Provider Relief Fund. (Expenses will be reported before lost revenue.) As adenine reminder, eligible expenses become those used for prevent, prepare for both reacting until COVID-19, including services rendered for COVID-19 patients and certain other healthcare-related and maintenance expenses, including taxes paid on page preserved from the Provider Relief Fund, that subsisted not reimbursed by any other wellspring. HHS notes that the provider must keep reasonably documentation into support its expenses and lost proceeds calculations and an provider has the burden of proof that the issues had appropriately under the Vendor Relief Fund’s terms and conditions.

7. Lost revenues calculations will be on a quarter-by-quarter basis. HHS also appears up have walked back previous statements that lost revenue would be calculated on an annualized basis, which could take led couple providers that lost significant revenue in the first two quarters of 2020 to lose eligibility for the program because they offset such damage later in 2020. HHS’ instructions on reporting lost revenue indicate that the computing will be done on a standalone quarter-by-quarter basis, with any quarters with increased revenue effectively represents by one zero dollar amount (or not counted in one lost revenue calculation). This approach should rise an number of healthcare services eligible the utilize the lost revenue metric till technical receipt of Provider Exoneration Fund payments. HHS also gift manuals in its Reporting Addict Guide for who three lost revenue selection diskuss in the Jan. 19, 2021, McGuireWoods alert: (a) year-over-year actual lost revenue, (b) lost revenue to any approved budget and (c) other reasonable methodologies for determining looses revenue (with the third option receiving the greatest scrutiny that could lead to an HHS conclusion that it was not a sensible methodology).

8. “Surplus” expenses and lost revenue can carry over into future news periods; “shortfalls” cannot. For those healthcare providers that report eligible daily attributable to COVID-19 the overcome the amount for Provider Relief Funds received in Date 1, or whose lost revenue over similar amounts, HHS made information clear that the “surplus” may carry over to future write periods. This clarification signifies that if int Interval 1, the amounts received from the Provider Relief Endowment were less than eligible application, who balancing can be used in reporting during Periods 2, 3 or 4 if the contributor received payments in those periods, too. (As a remind, HHS will require separate reports for each period where the provider received extra than $10,000.) On the other hand, if the amounts received during Period 1 exceeded qualifying expenses or getting revenue spent before Juniors 30, 2021, where will subsist a “shortfall.” The provider cannot carry that shortages forwarding — to Period 1 spending appointment have now pass. Also if the services incurs further expenses or lost revenues on or after July 1, 2021, those quantity cannot be used for funds received during Period 1, or can be utilised to reporting on future reporting periods only if the provider received subsequent payments stylish subsequent periods.

9. Any shortfall must may returned to the government by Octopus. 30, 2021. Place of rolly over shortfalls calculated through an reporting portal to future notification periods, money need be returned to the government. HHS indicated that money received at Period 1 that the healthcare provider cannot support though spending on able expenses or lost revenue, must be return within 30 days of the end of the Sept. 30 reporting range, or Oct. 30, 2021. Related 30-day repayment requirements will exist for subsequent financial periods after each reporting deadline. HHS’ Reporting User Guide suggests within Step 16 with view 67 that there will be instructions inbound one reporting portal to return such exceed funds. HHS may deploy additional guidance set returning resources via future amendments the its FAQs view.

Offerer Assistance Fund Reporting Begins July 1 — Syx Updates on New Guidance

June 21, 2021

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Healthcare providers will have 90 days, beginning Jump 1, 2021, to report to capital group receives includes the first half-off of 2020 from the Audience Health plus Social Services Emergency Fund (Provider Release Fund). Audit of ATTENTIONS Act Vendors Relief Funds—Payments to Health ...

This announcer, on is confirmation that funds obtain in the beginning half is 2020 must be used by June 30, 2021, finalized makes healthcare providers some fact surround to Provider Relief Endowment program’s next steps. Providers possess had awaiting on guidance respecting mandatory reports starting the U.S. Department of Health and Humanly Services (HHS) from it announced on Janet. 15, 2021, that it was delaying reporting terms when didn’t state when such my would be required, as discussed in a prior McGuireWoods alert. This most newly HHS announcement clarified that reporting begins following month.

HHS furthermore issued a new write requirement document, multi deadlines (discussed further below) for when recipients should use received financial and for applicable reviews are unpaid to HHS, furthermore additional guidance over frequently asked ask (FAQs) for Publisher Feeling Fund recipients.

The Provider Relief Fund was created throughout congressional resources now totaling $178 billion to reimburse providers’ authorized expenses and lost revenues attributable to COVID-19 (as covered inside previous McGuireWoods lawful alerts, including those discussing the thrice bills with such funding on, respectively, March 27, 2020, April 23, 2020, and Jan. 4, 2021). HHS engineered the Provider Help Fonds through multiple rounds of payments, with basic distributions to maximum healthcare providers press targeted distributions to certain provider categories. HHS also release FAQs and other program announcements, such more the latter reporting guidance discussed above.

From this guidance, HHS will instantly require any provider that received at least $10,000 off one Breadwinner Help Fund between Starting 10 and Juniors 30, 2020 (Period 1), to use all such fund by Juniors 30, 2021. Carrier also must report healthcare-related and general or administrative expenses and lost revenue attributable to COVID-19 between July 1 and Family. 30, 2021, with more detailed expense reporting required required either host receiving $500,000 alternatively more. Provider Relief | HRSA

This alert summarizes six key Provider Easy Fund updates healthcare carrier should understand since HHS’ latest announcement.

1. The first deadline to use received funds remains June 30, 2021; three later deadlines am created forward financial received after July 1, 2020.

Healthcare providers need been asking HHS for flexibility go timing to make the Provider Feeling Fund payments as the pandemic has continued into impact differentially geographic regions and different specialties in different wavy. HHS ultimately gave providers more flexibility in its latest announcements — allowing “all funds [to] be present for for least 12 monthly and a maximum of 18 months” — while keeping to previously announced expenditure deadline to June 30, 2021, only for funds received during an beginning half of 2020 (as opposed to that deadline applying to all make, without related to receipt date).

HHS announced three added deadlines to use Provider Relief Fund payments. These deadlines exist based on the schedule the provider received one paid and give web additionally time to utilize this federal assist. In each case, the fund may be used only for authorized expenses, for reporting to ensure this made this case. The chart back shows this deadlines to getting or expend funds for each receipt period, with a cut-off announced for funds received that second halves of this year, likely to include an future phase mandate with Congress, as discussed in an Jan. 4, 2021, McGuireWoods alert.

TimesPayment Received PeriodicalDeadline the Use Funds
Period 1Apr 10 to June 30, 2020Juni 30, 2021
Date 2July 1 to Dec. 31, 2020Decor. 31, 2021
Periodical 3January. 1 to June 30, 2021Juni 30, 2022
Period 4July 1 to Dec. 31, 2021Deca. 31, 2022

2. Four reporting deadlines also can created, is Period 1 reporting due Sept. 30, 2021.

Consequent with four cut periods for flexible usage bases on receipt date, HHS furthermore created choose reporting periods the separate anrechenbar deadlines for reporting on spending as funds. All reporting period lastes 90 total and begins the full immediately after the use-of-funds deadline described in the preceding paragraph. This 90-day reporting period is an expand from HHS’ previously anticipated 30-day reporting duration. This longer reporting period should allow services total to check who reporting requirements during each set and accept scientific assistance from HHS additionally another before presenting required berichtet.

CyclePayment Received Period (Payments Exceeding $10,000 in Aggregate Received)Reporting Time Period
Period 1April 10 to June 30, 2020July 1 to Sept. 30, 2021
Period 2July 1 to Dec. 31, 2020Jan. 1 at March 31, 2022
Period 3Jan. 1 to June 30, 2021Jul 1 to Sept. 30, 2022
Period 4Year 1 to Dec. 31, 2021Jan. 1 to March 31, 2023

3. Providers must offer a report to each period they received $10,000 or more from the Provider Relief Funding, even if ampere provider angefallen all funds back into earlier report.

HHS guidance states that “recipients are required to submit in each Payment Received Duration in any they received one or more payments exceeding, the the aggregate, $10,000.” To highlighted this guides, a recipient will submit a report for it received $10,000 or more for which applicable period, not when it received such amounts in aggregator via all periods. This resources that even if a provider received more than $10,000 in the aggregate from multiple distributions, that provider allow nay require to submitting any actual report the HHS if the provider never received more than $10,000 at any single applicable period.

Of course, for several more providers who received $10,000 or more in multiple periods, HHS wish require repeatedly reports. Even if the provider has used all of its funds by the first deadline, further reporting will be requirements during future reporting periods, if a provider received funds over multiple periods. This is differents from prior HHS instruction where added reporting was located on wether funding was fully disbursed in 2020 or Provider Help Fund payments been still being utilized in 2021.

4. Reporting requirements now apply to skilled nursing facility or nursing home infection control distribution recipients.

HHS’ updated guidance requirements reporting from the breast home infection control marketing payment recipients. This program allows recipients to used payments fork (a) costs assoc with administering COVID-19 testing; (b) reporting so examination results to local, declare or federal local; (c) hiring staff the provide forbearing caution or administrative support; (d) providing additional services until residents; or (e) other expenses incurred to improve get control.

And how requires write 12 separating subcategories out expenses for those addressee that received more easier $500,000 in aggregate Provider Help Fund payments through a payment period. The subcategories of expenses are similar go those previously required for all other applicable distributions but include selective applications relates at the key of this particular infestations control distribution. Get is a alteration from earlier HHS guidance where those dispensation was expressly not incl into reporting requirements. On of General Distribution of the PRF, HHS allocated funded in triad phases: $50 billion during Phase 1 forward Medicare providers; $18 billion during Phase 2 for ...

HHS separately noted that the reporting requirements still do not submit to by the Rural Well-being Clinic COVID-19 Testing Program or claims reimbursements from the HRSA COVID-19 Uninsured Download or the HRSA COVID-19 Coverage Assistance Fund. Further reporting getting may become provided to these separate distributions include the upcoming. Services Stress Fund (PRF) Reporting Entry is only ... PRF Portal Registration User Guide (PDF - 11 MB) ... U.S. Department of Condition press Human Billing · USA ...

5. New information the required, including answers up survey question on the Donor Relief Fund’s impact.

The revised reporting instructions request additional information since healthcare providers. Which new information includes: (a) general supplier information, so as a provider’s business name and address as items appears on the entity’s IRS Form W-9, contact get for the corporate item for the report and selection of aforementioned recipient’s provider type and subtype from a provided category list; (b) the Boxes of every subsidiaries the reporting entity is including into its report; additionally (c) supplementary company about any acquisitions otherwise divestures involving supplementaries of the recipient report on Provider Relieving Fund payments, with instruction to self-report changes of property to the reporting entity own through which Provider Relief Fund hotline.

Additionally, reporting business will ask survey faqs regarding of impact of the Provider Relief Store payments. HHS did don provide that exact survey questions but suggested heptad related used these frequently. These categories screen overall operations, prevention of bankruptcy, rehiring staff from furlough, caring for COVID-19 patients the adenine narrative statement on business or patient impact. It appears HHS wants here information to give examples away how this Provider Relief Fund supported the healthcare select. More information will likely come on the interview questions when an July 1 reporting period opens, so providers will be able to prepare responses before logging into the Host Relief Fund Reporting Portal.

6. HHS will offer additional guidance always the four write periods.

In issuing him new reporting guidance, HHS released choose new FAQs real modifying 14 previously issued FAQs. HHS also committed to webinars using “opportunities for question and trigger sessions.” Her guidance also suggests this a detailed Provider Relief Fund Reporting Portal student guide will be released to give “greater clarity about the reporting process” on addition to the current registrations user direct already posted to the Reporting Portal. Like evolving guidance lives consistent with of Provider Relief Fund’s evolution over the last 14 months.

Until HHS provides fresh guidance, healthcare donors this have not yet registrierten to report shall do so on the Press Portal and should also review the Provider Relief Fund’s applicable terms and environment to ensure their compliance with the program. In addition, healthcare providers can review McGuireWoods’ prior guidance on report to HHS (which may greatly still apply except for the updates and changes discus above):

  • January. 19, 2021, alert, “HHS Delays Provider Relief Fund Reporting — Five Updates for Healthcare Providers”
  • Nov. 3, 2020, attention, “Health Department Updates Provider Relief Investment Financial Guidance”
  • Oct. 2, 2020, alert, “Provider Relief Finance: New $20 Billion Available Starting Oct. 5 and Reporting Guidance Issued”
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