On January 15, 2021, the Department of Health and Human Services (HHS) announced that the reporting portal is now open for registration only.   HHS has delayed the previously announced reporting deadline of February 15, 2021 due to a lack of reporting functionality within the portal and Congress passing the Coronavirus Response and Relief Supplemental Appropriations Act on December 27, 2020.  According to HHS, the registration process may take up to 20 minutes to complete and even though there is no new deadline for the reporting, HHS is encouraging every provider who will be required to report on their use of the funds to register and make an account.

Any provider who received more than $10,000 in aggregate from the various distributions of the Provider Relief Fund (PRF) would be required to submit reporting data to support their appropriate use of the funds. That requirement still stands and providers are encouraged by HHS to register into the portal by creating an account here, in anticipation of an eventual reporting deadline.

Also, on January 15, 2021, HHS released a revised Post-Payment Notice of Reporting Requirements, which outlines how the calculations will be made on the appropriate use of the PRF monies. Of note in this latest version is that HHS gives recipients three options regarding how 2020 lost revenue is calculated:

1. The difference between 2019 and 2020 actual patient care revenue
2. The difference between budgeted and actual 2020 patient care revenue (this assumes the budget was approved prior to March 27, 2020)
3. Any reasonable method of estimating revenue

If a provider chooses option 3 to determine their lost revenue in 2020, HHS says it will increase their chances of an audit, and they must also submit to HHS a description of their methodology, an explanation of why this methodology is reasonable, and identify how these lost revenues are attributable to COVID-19. If HHS rejects this methodology, the provider will have 30 days to submit their report under either option 1 or 2.

Key Take-Aways

• HHS has opened the reporting portal for PRF recipients for registration only
• Registrants will receive a notification from HHS when the second step for submitting information in compliance with reporting requirements becomes available
• The previous reporting deadline of February 15, 2021 has been indefinitely delayed
• Providers can now choose between 3 methods of determining their lost revenues when calculating their appropriate use of the PRF monies

No matter what you are facing in 2021, WebsterRogers LLP has a team of experienced accountants and healthcare consultants standing by to help you navigate the changing landscape of healthcare.

If you have questions or would like to strategically discuss your situation relative to any of these items, we are here to help.  Reach out to your WR Partner or your relationship manager.  You can also email our COVID-19 task force for assistance.