- Fringe benefits; and
- Other G&A overhead expenses.
In addition, these entities must provide further detailed information for healthcare expenses to identify supplies, equipment, information technology, facility costs and other healthcare expenses.
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Explore This IssueFebruary 2021
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3. Lost Revenues Attributable to Coronavirus
Reporting entities may apply PRF payments toward lost revenue from 2020 patient care. This calculation includes the revenue or net charges from patient care, revenue from patient care payer mix, prior to net costs and expenses, and will separately account for the amount of other assistance received from federal, state and other sources.
The recently passed Appropriations Act added flexibility for certain provider budgets established and approved before March 27, 2020, allowing applicable providers several options to calculate lost revenues, one of which uses a budgeted-to-actual revenue comparison rather than an actual year-over-year calculation as required by prior HHS guidance.
Reporting entities will need to provide additional revenue information, depending on which of the lost revenue calculation options they use.
PRF reporting takes into consideration other assistance eligible providers received during 2020, including, but not limited to, funds from the Paycheck Protection Program; CARES Act Testing relief; local, state or other government assistance; and business insurance, among other things.
Providers should be aware that any monies received through a state program may include similar reporting and documentation requirements and may indicate a priority order of spending that cannot supersede the HHS PRF terms and conditions. These other federal and state monies may not overlap with HHS PRF distributions to cover the same expenses or lost revenue.
It is worth noting for reporting entities that held PRF payments in an interest-
bearing account, the value of interest earned on those PRF payments must also be reported. The reportable use of PRF distributions includes the interest earned on those PRF distributions.
4. Non-Financial Information
Non-financial information for reporting includes a PRF recipient’s number of personnel (i.e., full time, part time, contract, other), total rehires, total new hires and total personnel by labor category, total number of patients and types of visits (i.e., in person or telehealth visits, admissions, residents), and information regarding the facility (i.e., total available staffed beds).
Auditing & Enforcement
The PRF terms and conditions generally indicate that provider-recipients of payment distributions must promptly submit records and documentation of expenditures upon the request of HHS and fully cooperate with audits by HHS, the Office of the Inspector General (OIG) or the Pandemic Response Accountability Committee.
The HHS has warned that significant anti-fraud monitoring of the funds would occur and that the OIG would provide oversight to ensure the funds were used appropriately to comply with the applicable terms and conditions. The HHS has indicated that non-federal reporting entities who received and expended annual federal awards exceeding $750,000 in the aggregate during their fiscal year are subject to single audit requirements.
The record retention and potential audit lookback period is at least three years for providers who retained and expended PRF payment distributions. Therefore, providers should take care to document expenditures accurately and in detail. Deliberate omission, misrepresentation or falsification of any information contained in payment applications or future reports may result in criminal, civil or administrative penalties, including but not limited to revocation of Medicare billing privileges, exclusion from federal healthcare programs and related fines.