Clarity and insight offered on the requirements and its deadlines
On Saturday, Sept. 21, the Department of Health and Human Services (HHS) released the reporting requirements for healthcare providers that received COVID-19 relief funds. Any recipients of Provider Relief Fund (PRF) payments exceeding $10,000 are required to comply with the reporting requirements.
The reporting requirements for PRF payments will be much more detailed than originally anticipated. Until further clarification on the detail of the reporting is released, we believe it is possible for some dental practices that have recovered significantly to not be able to show full use of PRF payments.
This has been a consistent theme throughout this year for government stimulus. CWA highly recommends doctors maintain a higher level of cash in their business until their PPP loan is forgiven and their PRF payments have been reported. Most practices should have these two things completed by Q1 or Q2 of 2021.
The documents released on the HHS website were extensive and complex, causing a stir of confusion for recipients of the funds. The following outlines the key takeaways as they stand currently.
- All recipients must report the use of the funds within 45 days of Dec. 31, 2020.
- Any recipients that have not used all of their funds will receive a six-month extension, with a new reporting deadline by July 31, 2021.
Use of Funds:
- The use of funds must be documented by showing healthcare related expenses, such as supplies, equipment and training attributable to the coronavirus.
- If these do not fully expend the funds, the recipient can use year-over-year lost revenues on a quarterly basis to justify the use of the funds. Note: This is different than what was on the application which originally stated that lost revenue would relate to just March and April on a year-over-year basis.
- The HHS defines lost revenue as patient care revenue less patient care related expenses. The comparison period is the full calendar of 2020 as compared to 2019.
- The HHS further limits the lost revenue amount to the recipients “net gain” for 2019. The definition of a “net gain” is unclear, but likely refers to the practice net income for 2019.
- The HHS states that lost revenue can be calculated using any “reasonable method” in the FAQ.
- Any unused amount is subject to recoupment by the HHS. The parameters for recoupment are not known at this time
- Recipients that receive between $10,000 and $499,999 in stimulus funds must aggregate their costs into two categories (1) general & administrative expenses and (2) other healthcare related expenses.
- Examples of G&A expenses that fall into this category could include mortgage or rent, personnel costs for preventing and responding to the pandemic, and utilities and operations bills.
- Other healthcare-related expenses attributable to COVID-19, the guidance clarifies, may include supplies and equipment used for COVID-19 response efforts, including personal protective equipment, etc.
The HHS rules for both the usage and reporting of the funds appear to be more cumbersome than originally communicated. The calculation for lost revenue for the recipient is still not yet well defined. We anticipate more guidance and clarity from the HHS over the next few months, prior to the opening of the reporting system.
If you are anticipating your practice’s lost revenue (decrease in your practices’ 2020 net income) to be less than the amount of your HHS funding, we recommend you begin gathering documentation for coronavirus related healthcare expenses.
The landscape of the relief response and legislation associated has continued to change and this program is no different. We commit to keeping you updated. Visit our website for the latest information.