Fluent in Practice Management

If you have received the Health and Human Services (HHS) Provider Relief Fund payments of $10,000 or more, you must register in the Provider Relief Fund reporting portal.  This is a new requirement that just started in January.  Here is the link you will need to register:

www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html

When you register, you will need the following information:

• Tax ID Number (TIN) (or other number submitted during the application process such as Social Security Number or Employer Identification Number (EIN)).
• Business name (as it appears on a W-9) of the reporting entity.
• Contact information (name, phone number, email) of the person responsible for submitting the report.
• Address (street, city, state, and zip code) of the reporting entity as it appears on a W-9.
• Payment information (for any of the payments received):
  • TIN of entity that received the payment
  • Payment amount
  • Mode of payment (check or direct deposit ACH)
  • Check number or ACH settlement date

• You will also need to create a username (in the form of an email) and a password during the registration process.

The reporting deadline for showing how the HHS grant was used has been extended.  You will be notified via email by HHS when you are required to report usage of the funds.  What follows are approved ways to use the grant:

1. You can pay for healthcare-related expenses attributable to the coronavirus that another source has not reimbursed and is not obligated to reimburse.  Please reference our HHS blog done on October 23, 2020, for additional information on expenses and tracking.
2. You can apply the grant to loss of revenue.  There are three ways you can choose to calculate loss of revenue:

• Show a reduction between 2019 and 2020 actual patient care revenue (collections).
• Show a difference between 2020 budgeted and 2020 actual patient care revenue (collections). If recipients elect to use 2020 budgeted patient care revenue to calculate lost revenue, they must use a budget that was established and approved prior to March 27, 2020. Providers using 2020 budgeted patient care revenue to calculate the amount of lost revenues will be required to submit additional documentation at the time of reporting.
• Show loss of revenue calculated by any reasonable method of estimating revenue. If a recipient wishes to use an alternate reasonable methodology for calculating lost revenues attributable to coronavirus, the recipient must submit a description of the methodology, an explanation of why the methodology is reasonable, and establish how the identified lost revenues were in fact a loss attributable to coronavirus as opposed to a loss caused by any other source. All recipients seeking to use an alternate methodology face an increased likelihood of an audit by Health Resources and Services Administration (HRSA). HRSA will notify a recipient if their proposed methodology is not reasonable, including because it does not establish with a reasonable certainty that claimed lost revenues were caused by coronavirus. If HRSA determines that a recipient’s proposed alternate methodology is not reasonable, the recipient must resubmit its report within 30 days of notification using either 2019 calendar year actual revenue or 2020 calendar year budgeted revenue to calculate lost revenues attributable to the coronavirus.

One of the big unknowns when proving loss of revenue is if any other CARES Act funds must be applied to the loss-of-revenue calculation.  This would include any PPP loans or EIDL grants you received.  Originally in the Q&A that was released by HHS, it said you had to include CARES Act funds; however, this section has been removed.  We are hopeful that you do not have to include CARES Act funds in the calculation of loss of revenue, but we are awaiting further guidance.

The most important step to take right now is to register in the Provider Relief Fund Reporting portal.  We know it is easy to lose track of what you may or may not have already done regarding grants and loans.  Registration for HHS is new; the requirement just started in January.  Unless you registered for it in the last few weeks, you are likely not yet registered. We encourage you to register as soon as you can.

We will continue to report information as it is released regarding the HHS grant registration and reporting.  We hope you stay safe and healthy.