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Tag: CARES Act

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 FAQsHSRA’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:
 
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.  

 

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COVID-19 Funding Update| Toyon’s Covid-19 Funding Resource

 

·  Revised PRF instructions have four different reporting periods.

·  The first reporting deadline is September 30, 2021.

·  The last reporting deadline is March 31, 2023 for funds received July 1, 2021 through December 31, 2021.

 

Toyon is pleased to provide this update on the CARES Act Public Health and Social Services Emergency Fund (PHSSEF).   For more information, or to contact any of our team members, please feel free to visit Toyon’s website or contact Fred Fisher at fred.fisher@toyonassociates.com.

HHS Releases Revised PHSSEF Instructions
On June 11, HHS published revised PHSSEF reporting instructions and FAQs. The Provider Relief Funding Portal will be open July 1, 2021 for the first of four reporting periods.  The reporting periods are in below table. 

Initial Takeaways
Toyon is currently evaluating HHS’ new instructions and FAQs and will be providing comprehensive industry updates, as well as updates to our PHSSEF hospital workbook.  In the meantime, listed below are initial takeaways from HHS’ new reporting instructions:

  • Period four indicates HHS plans on distributing remaining PHSSEF as early as July 1, 2021 through December 31, 2021.
  • Providers now also report “Net Unreimbursed Expenses Attributable to Coronavirus”. It is possible, yet still undetermined, period one information may be used to determine need for future hospital funding. 
  • Per the FAQs, HHS still permits “reimbursement of marginal increased expenses related to coronavirus provided those expenses have not been reimbursed from other sources or that other sources are not obligated to reimburse”. However, HHS has removed the example language using an $85 office visit during the pandemic (the “$85 FAQ”). 
  • COVID-19 expenses, lost revenue and funding is now reported by quarter based on the period of availability (per table above).
  • Through PHSSEF reporting, HHS is now collecting a survey on the impact of PHSSEF payments for each reporting period.
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Provider Call to Action

Action Requested – Medicare Accelerated and Advance Payments

Teaming with national healthcare leaders, Toyon seeks to work with HHS and CMS to amend policy surrounding Medicare Accelerated and Advance Payment (AAP) recoupments. 

The Medicare program graciously loaned $83bn through Accelerated and Advance Payments (AAP) to hospitals across the country to help with cash-flow during the public health emergency (PHE).  Toyon first supports a delay and forgiveness of these loans. In the event hospitals do not receive relief on these loans, Toyon looks to work with CMS, HHS and other federal agencies toward:

Call to Action
Toyon respectfully requests your brief information below as a call to action requesting CMS, HHS and other federal agencies to address these important issues through policy amendment, development, etc.  To demonstrate a critical mass of support, Toyon will be providing CMS and HHS officials a list of signatures, once collected.  

Please contact Fred Fisher at 888.514.9312, fred.fisher@toyonassociates.com with any questions.  Thank you.     

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