Lessons Learned 和 Looking Forward

The Provider 救援 Fund (“PRF”) was created to assist healthcare providers during the COVID-19 p和emic. 通过冠状病毒援助, 救援, 和 Economic Security (“CARES”) Act, the Department of Health 和 Human Services (“HHS”) distributed funds to qualified providers for healthcare related expenses 和 lost revenues due to COVID-19 和 to reimburse for testing 和 treating uninsured individuals with COVID-19. Over $134 billion in funds have been distributed through various phases of general, targeted 和 American Rescue Plan (“ARP”) rural distributions. 

报告要求

2022年10月27日， HRSA issued an updated Post-Payment Notice of 报告要求.

Below is a summary of the payment received period 和 the period of availability for the use of the funds.

期收款期有效期限
12020年4月10日至6月30日2020年1月1日至2021年6月30日
2July 1, 2020, to December 31, 2020January 1, 2020, to December 31, 2021
3January 1, 2021, to June 30, 20212020年1月1日至2022年6月30日
4July 1, 2021, to December 31, 2021January 1, 2020, to December 31, 2022
52022年1月1日至6月30日2020年1月1日至2023年6月30日
6July 1, 2022, to December 31, 2022January 1, 2020, to December 31, 2023
72023年1月1日至2023年6月30日January 1, 2020, to June 30, 2024

Most providers have been through at least one reporting period. Below is a summary of the reporting time periods.

期收款期
(Payments Exceeding $10,000 in Aggregate Received)		报告期间
12020年4月10日至6月30日July 1, 2021, to September 30, 2021
2July 1, 2020, to December 31, 2020January 1, 2022, to March 31, 2022
3January 1, 2021, to June 30, 2021July 1, 2022, to September 30, 2022
4July 1, 2021, to December 31, 2021January 1, 2023, to March 31, 2023
52022年1月1日至6月30日July 1, 2023, to September 30, 2023
6July 1, 2022, to December 31, 2022January 1, 2024, to March 31, 2024
72023年1月1日至2023年6月30日July 1, 2024, to September 30, 2024

In the October Post-Payment Notice of 报告要求, HHS also provided guidance to providers on the reporting of the ARP rural distributions in the HRSA PRF portal, 因为这些是第四时期的新东西. 根据指南, the tax identification number (“TIN”) that qualified for 和 received the ARP rural distribution payment must use the payment for allowable expenses 和/or lost revenues.  HRSA does not permit parent entities to use these payments. Parent entities will be required to attest that payments were allocated in accordance with the information provided in the payment letter received in conjunction with the ARP rural distribution.

期 4 HRSA PRF reporting opens on January 1, 2023. Below are some lessons learned from previous reporting periods that providers should be aware of as they begin to report 期 4:

  1. 早点出发 – Reporting for 期 4 is through March 31, 2023, but don’t wait until the last minute to start. If there are issues with the portal or you have questions, there can be long wait times or delays when contacting HRSA.
  2. Alternative Reasonable Methodology -在以往期间, many providers were hesitant to use the alternative reasonable methodology to report lost revenues for fear of greater scrutiny by HRSA. This methodology has proven to provide the most flexibility to providers to capture changes in operations or other factors. The lost revenue methodology can be changed from the previous reporting period. The key when using the Alternative Reasonable Methodology is ensuring the narrative submitted agrees to the calculation submitted 和 that the narrative explains why the methodology is reasonable for the circumstances 和 how the lost revenues were attributable to COVID (as opposed to a loss caused by another source).
  3. Consistency between reporting periods – While you can change your lost revenue methodology, 如果你知道, you are required to go back to the beginning of the period of availability 和 calculate lost revenues under the new methodology. 确保你的收入, expense 和 metric information is consistently reported each period is important.
  4. 文档是关键 – Ensure all records are kept that support what was reported in the HRSA PRF portal. 审计s occur well after the reporting was performed so make sure you maintain your records with this information. Many organizations have experienced turnover in the position responsible for reporting, so ensure the information is saved 和 accessible by others in the organization. Documentation must be retained for a period of three years after the date of submission of the final expenditure report.
  5. 审查你的提交 – Have someone outside of the person doing the submission review the information for accuracy 和 consistency.

审计需求

Providers who received over $750,000 PRF are also subject to a compliance audit.  Commercial organizations have two options in fulfilling the audit requirement: 1) an audit in conformance with the requirements of 45 CFR 75 Subpart F (single audit), or 2) a financial audit of the award or awards in accordance with 政府审计准则.

Amounts reported on the schedule in the PRF audit (regardless of the option chosen as described above) will align with the PRF period of availability 和 what is reported in the PRF Reporting Portal. 日历年结束时, total expenditures 和 lost revenues from both 期 1 和 期 2 report submissions to the Health Resources 和 Services 政府 (“HRSA”) PRF reporting portal would have been included on the 12/31/21 schedule in the PRF audit. This would include PRF funding received from April 10, 2020, to December 31, 2020. 审计s for calendar year-ends of December 31, 2022 will include 期 3 和 期 4 payments.

除了PRF数额之外, the schedule should also include any other HHS awards received during 2021 including 93.461, COVID 19 Claims Reimbursement for the Uninsured Program 和 the COVID-19 Coverage Assistance Funds (Assistance Listing 93.461), COVID-19 Testing 和 Mitigation for Rural Health Clinics (assistance listing 93.697), 和 other HHS awards such as NIH Research 和 Development grants.

The compliance audits are due the earlier of 30 days after the receipt of the audit or nine months after fiscal year end.

The Office of Management 和 Budget (“OMB”) granted a six-month extension for recipients in Puerto Rico, 阿拉斯加, 佛罗里达, 南卡罗来纳, 和 North Carolina with Single 审计s due between September 18 和 December 31, 2022.

Many organizations have been through their first compliance audit for the HHS awards. Below are some common compliance audit issues identified in these audits:

  1. Missing or incorrect information – 审计ors are required to agree certain line items of the HRSA PRF portal submission to the underlying detail. 在某些情况下, providers were unable to provide supporting detail, or the supporting detail provided did not agree to what was reported in the submission.
  2. Expense reporting – Expenses reported in the HRSA PRF portal submission as “Other PRF Expenses” should only include the PRF expenses for that reporting period. 这些不应该是累积的.
  3. Alternative Reasonable Methodology narrative – The narrative included for the lost revenue calculation did not support the calculation or did not include an explanation of why the methodology was reasonable for the circumstances 和 how the lost revenues were attributable to COVID.

As providers prepare for the next round of compliance audits, below is information to keep in mind:

  1. Ensure all HHS award information is readily available 和 supports amounts reported in the HRSA PRF portal.
  2. Ensure policies 和 procedures surrounding the funding are documented 和 accurately depict the use of the funds 和 the controls in place over the funds.
  3. Review the related compliance requirements. The OMB releases a compliance supplement which details the compliance requirements for the funds. Providers should review these to gain a better underst和ing of the testing to be performed as part of the compliance audit.

其他资源

HHS continues to release updated frequently asked questions to assist providers in reporting 和 underst和ing the audit requirements for the awards. Providers are urged to continue to monitor the HHS website for updates.

LBMC has a dedicated PRF team available to assist organizations with reporting 和 compliance audits. If you have questions, please reach out to our team.

内容由LBMC提供 考特尼巴赫 和 劳拉·麦格雷戈.