February 1, 2021
On Jan. 28, the U.S. Department of Health and Human Services (HHS) updated the CARES Act Provider Relief Fund (PRF) FAQs. Updates involve use of PRF payments for vaccine administration, Phase 3 General Distribution updates, and modifications and updates specific to PRF Reporting. Note – HHS has not yet provided a new deadline for the first PRF report.
COVID-19 Vaccine Administration
HHS clarified that PRF payments may cover the administration of a COVID-19 vaccine to a Medicare enrollee that only has Part A coverage, but not Part B coverage. In such cases, HHS considers the administration of the vaccine unreimbursed by other sources, as payment for vaccine administration is typically under Part B.
PRF Phase 3 General Distribution
Providers that applied for a Phase 3 general distribution will receive up to 88% of reported losses (both lost revenue and healthcare-related expenses attributable to coronavirus incurred during the first half of 2020) or 2% of annual revenue from patient care, whichever is greater. Additionally, HHS explained that applicants might not receive a Phase 3 general distribution payment should HHS determine the reported revenues and operating expenses from patient care were not exclusively from patient care, or if reported figures were not reflected in submitted financial documentation. Additionally, applicants that already received PRF payments that equal or exceed reimbursement of 88% of reported losses will not receive a Phase 3 general distribution payment. If you believe your application warrants a payment, note that HHS is still making Phase 3 general distribution payments and will continue making such payments through the first months of 2021.
HHS modified and updated several FAQs related to the attestation to, use of, and reporting on use of general and targeted distribution payments to reflect the Coronavirus Response and Relief Supplemental Appropriations Act. These include modifications to how providers may calculate lost revenue, with HHS specifying that reporting entities may use budgeted revenues if the budget(s) and associated documents covering calendar year 2020 were established and approved on or before Mar. 26, 2020.
HHS also provided some reporting expectations, indicating that reporting entities will submit a consolidated report through the PRF Reporting Portal covering all payments (both general and targeted) received from the PRF. Further, HHS clarified that the provider that originally received a targeted distribution payment is responsible for reporting on the use of those funds through the PRF Reporting Portal.
HHS stipulated that reporting entities must report revenue for the full 2019 and 2020 calendar years, even if the provider fully expended PRF payments in the early months of the pandemic. HHS explained that reporting actual patient care revenue for both calendar years in full is necessary in order to inform program integrity and future audit strategy.
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