CARES PRF Reporting Update

1. HRSA to Hold Two Stakeholder Calls Tomorrow 8/26 / HRSA Website Change

2. OMB Releases Updated PRF Audience Guidance

3. Toyon’s Workbook for CARES PRF Reporting

4. Toyon’s Article on Complexities with CARES PRF Reporting

1. HRSA to Hold Two Stakeholder Calls Tomorrow 8/26 / HRSA Website Change

Tomorrow HRSA is holding two calls on PRF reporting for reporting period one covering PRF received from April 10, 2020 to June 30, 2020 (due September 30th). Register here for the call at 11 AM ET | 8 AM PT. Register here for the call at 3 PM ET | 12 PM PT.

The HRSA CARES PRF Website has also recently changed, including links to resources and FAQs. HSRA’s updated website includes new guides on lost revenue and reporting period one. The lost revenue guide includes examples of reporting under each option (quarterly actual, quarterly actual vs. budget, or other). HHS recommends providers consider revenue reporting options based on the following:

Option i: Quarterly actual revenue amounts. Consider reporting under this option when actual revenues from 2019 are comparable to 2020 and 2021 (i.e., apple-to-apples)

Option ii – Quarterly actual to budget comparison. Consider this reporting option when providers have:

an approved budget prior to March 27, 2020 which covers the entire period of availability
budgeted revenues that are comparable to 2020 and 2021 actual revenues (i.e., apples-to-apples)
an executive level attestation that the budget was approved prior to March 27, 2020

Option iii – other revenue comparison. HHS cites

examples of “adding a new service, which made revenue appear higher than an apples-to-apples comparison, major changes in response to COVID-19 preventing planned changes that would have generated more revenue, etc.”.
a hypothetical instance removing revenue related to new service lines from all reporting periods to achieve an “apples to apples” comparison of 2019 and 2020 quarterly revenue.

2. OMB Releases Updated PRF Audience Guidance

The Office of Management and Budget (OMB) recently released its July 2021 Compliance Supplement with additional audit instruction on CARES PRF[1]. Listed below are highlights under Department of Health and Human Services, Assistance Listing 93.498:

Auditors should consider delaying the commencement of the compliance audit of the PRF program until recipients have completed the PRF report.
Listed under “Alternate Method of Calculating Lost Revenues Attributable to Coronavirus” OMB notes the auditor is not responsible for determining the reasonableness of the alternative method described in the provider’s narrative.
OMB provides an audit objective to determine whether a provider billed out-of-network patients with a presumptive or actual case of COVID-19, for out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider. The audit review may include:
- A review of the recipient’s billing and collection policies and procedures applicable to patient out-of-pocket expenses for patients with a presumptive or actual case of COVID-19.
- A test a sample of out-of-network patients with a presumptive or actual case of COVID-19 to determine whether the patient was assessed an out-of-pocket charge for services and ascertain if the charge was in compliance with terms and conditions of the award.
OMB states “as a best practice, the recipients may wish to include a footnote disclosure on the Schedule of Expenditures for Federal Rewards (SEFA) to identify which providers by TIN are included in the audit”.
OMB aligns HRSA PRF reporting requirements with Schedule of SEFA reporting in the following table:

Further on SEFA reporting, OMB states:

For a FYE of June 30, 2021, and through FYEs of December 30, 2021, recipients should report in the SEFA, the expenditures and lost revenues from the Period 1 PRF report.
For a FYE of December 31, 2021 and through FYEs of June 29, 2022, recipients should report in the SEFA, the expenditures and lost revenues from both the Period 1 and Period 2 PRF reports.
For FYEs on or before June 29, 2021, no PRF expenditures or lost revenues should be reported by recipients on the SEFA until the specified timeframe described in the reporting requirements summarized in the table above.

[1] HHS only provides audit guidance through the OMB Compliance Supplement.

3. Toyon’s Workbook for CARES PRF Reporting

Toyon is pleased to provide our clients and industry colleagues an optional complimentary workbook designed to evaluate and support COVID-19 expenses and lost revenues applied against CARES Provider Relief Fund (PRF) payments. This workbook reflects Toyon’s best understanding of the HHS PRF Guidance released June 11, 2021 and subsequent FAQs.

For access to this workbook, please register and download on our website here. It is recommended users of the workbook schedule a brief meeting with Fred Fisher,

Fred can be reached at fred.fisher@toyonassociates.com. Users of the Workbook are highly encouraged to ensure the results are consistent with internal amounts, expectations, etc.

4. Toyon’s Article on Complexities with CARES PRF Reporting

Toyon is also happy to share an article highlighting the complexities of CARES PRF reporting here. This article addresses three specific categories of CARES PRF reporting concerns:

Vulnerability of CARES funding due to potential variation in audit determinations
Complexities in hospital reimbursement determining patient care revenue
Use and reporting of “Targeted” PRF payments between parent companies and subsidiaries

Please feel free to share and comment on this article with other concerns with PRF reporting. Toyon is happy to update this article inclusive of other significant industry issues. We hope this article gains traction and promotes further clarity in PRF reporting.

Please feel free to contact Fred Fisher at fred.fisher@toyonassociates.com with any questions.

Thank you.

CARES PRF Reporting Update

Here TO HELP