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Tag: CARES Act

CARES PRF Update

CARES Phase 4 / Rural ARP Consideration

CARES PROVIDER RELIEF FUND (PRF)

Phase 4 and Rural ARP Reconsideration Update
Toyon is pleased to provide this update on the CARES Provider Relief Fund (PRF). Please feel free to contact Fred Fisher at 888.514.9312, fred.fisher@toyonassociates.com with any questions.
 
Providers in receipt of CARES Phase 4 and/or rural payments from the American Rescue Plan (ARP) have until May 2, 2022 to request a payment reconsideration. The reconsideration process is available to any provider looking to correct potential errors in their Phase 4 and/or Rural ARP payment according to HRSA’s methodology. HRSA will only consider correction of any errors; and will not consider changes to its payment methodology or policy in the reconsideration process. To request a Phase 4 and/Rural ARP reconsideration, providers must:
 
1) Review HRSA’s methodology. Providers may also contact HRSA at 866.569.3522 (TTY dial 711) to receive additional information on how Phase 4/Rural ARP payments were determined. 
 
2) Gather the following documents:
a. Payment determination letter from HRSA
b. DocuSign envelope ID for the ARP Rural/Phase 4 application
c. The contact information and Tax ID Number (TIN) included on the original Phase 4/ARP Rural application
d. The reason believed the Phase 4/Rural ARP payment was calculated incorrectly, (related to the PRF Phase 4 and ARP Rural Payment Methodology)
 
3) Complete and submit the PRF Reconsideration Request Form by 11:59:59 pm EST on May 2, 2022. HRSA states not to include any supplemental information or documentation beyond completing the PRF Reconsideration Request Form and uploading your Phase 4/ARP Rural payment determination letter. HRSA will only review your original submitted application and will request any clarifying information directly, as needed.
 
Providers expecting, but not yet in receipt of, CARES Phase 4 and/or Rural ARP payments will have 45 days to apply for reconsideration after receipt of a payment determination notice from HRSA. More information is available at HRSA’s PRF Reconsideration site as well as HRSA’s PRF Reconsideration FAQ site. Please also see Toyon’s updated CARES PRF Presentation (February 4) for information on recent CARES PRF allocationsPeriod 2 Reporting, and new FAQs issued January 27, 2022.
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CARES PROVIDER RELIEF FUND (PRF) Phase 4 Funding Update

 

 

1.  Begins Distributing Phase 4 Payments

2.  Toyon’s Template is Available to Assist Providers Reconcile Phase 4 Base Payments.

3.  Providers have until December 20, 2021 (11:59 PM ET) to correct errors related to PRF Reporting Period 1.

 

 
Toyon is pleased to provide this update on the CARES Provider Relief Fund (PRF). For more information, please contact Fred Fisher at 888.514.9312, fred.fisher@toyonassociates.com.
 
1.  HRSA is Distributing Phase 4 Funds
Today, December 16, 2021, HRSA began distributing $9 billion, out of $17 billion, in Phase 4 Funding to more than 69,000 providers.    
 
Phase 4 Base Payments
75% of Total Phase 4 Funding ($12.75 billion)
 
Phase 4 Funding is broken down into two parts, with the first being the Base Phase 4 payment. Phase 4 base payments are adjusted depending on annual patient care revenue. Funding percentages range from 20% (for large providers) to 45% (for small providers). These funding percentages are significantly less than the 88% funding percentage applied in Phase 3.
  • Small sized providers receive 45% of Phase 4 losses. Small providers have less than or equal to $10 million in annual patient care revenue. The current average payment is $58,000.
  • Medium sized providers receive 25% of Phase 4 losses. Medium providers have more than $10 million and less than $100 million in annual patient care revenue. The current average payment is $289,000.
  • Large sized providers receive 20% of Phase 4 losses. Large providers have $100 million or more in patient care revenue. The current average payment is $1.7 million.
HRSA’s Phase 4 methodology takes additional steps to flag aberrant data, and offset losses for “PRF payments not previously deducted in Phase 3.” Toyon believes HRSA is carrying forward PRF in excess of Phase 3 losses and reducing Phase 4 payments by this amount.
 
Bonus Payments
25% of Total Phase 4 Funding (~$4.25 billion)
 
In addition to the Base Phase 4 payment, HRSA is also disbursing “bonus” Phase 4 payments. Similar to rural payments from the American Rescue Plan (ARP), Phase 4 bonus payments are based on Medicare, Medicaid, and CHIP administrative claims data from January 1, 2019 through September 30, 2020 (Phase 4 bonus payments uses all claims as compared to the Rural ARP which uses rural claims). 
 
HRSA calculates Phase 4 bonus payments by determining the difference between payments at Medicaid rates versus payments at Medicare rates. The difference in payments is then reduced in a budget neutral manner to fit “the portion of funding set aside for bonus payments.” Based on eligibility criteria to apply for Phase 4 payments, it is believed HRSA used inpatient and outpatient claims from both Fee for Service and Managed Care payors. 
 
2.  Toyon’s Template to Reconcile Phase 4 Base Payments
Please feel free to use Toyon’s template to reconcile Base Phase 4 payments. The template is available here for download on Toyon’s website. 
  • The first of the two tabs is populated with hypothetical information to show how the provider’s Phase 4 payment was determined. 
  • The second tab is a template for provider input. 
  • To use this tab, input information into the grey cells and the formulas will calculate throughout the spreadsheet. 
  • Please note the current template utilizes thresholds to determine aberrant data, and potential “flags”, from thresholds established in Phase 3.  
  • To avoid amounts from being adjusted from any flags, please ensure “Yes” is populated in key columns AD and AJ. 
3.     CARES PRF Reporting Period 1 Correction and Period 2 Reporting
The PRF Period 1 Reporting Portal is now open through December 20, 2021 (11:59 PM ET) for any provider that still needs to register or submit | correct information related to PRF Reporting Period 1. PRF recipients looking to correct an error must contact the Provider Support Line (866-569-3522) to gain access to their submitted report.
 
The PRF Period 2 Reporting Portal is slated to open on January 1, 2022 and close March 31, 2022. PRF Reporting Period 2 will cover PRF amounts received from July 1, 2020 through December 31, 2020 and expenses and lost revenues incurred during the “period of availability” of January 1, 2020 through December 31, 2020 (excluding any amounts that were already applied towards PRF Reporting for Period 1). 
 
Toyon is committed to apprising providers with important reimbursement updates and will keep you updated with the latest COVID-19 funding and documentation news. Please feel free to visit Toyon’s COVID-19 Resources for more information.  
 
Thank you
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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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