CARES Archives

September 30 Deadline for CARES PRF Reporting Period 3

September 21, 2022

CARES Provider Relief Fund Reporting Period 3

Reminder – providers have until Friday, September 30, to file for Reporting Period 3 (RP3) of the CARES Provider Relief Fund (PRF). Even if $0 PRF was received in RP3, HRSA still requires confirmation (of $0 payments) in the PRF Reporting Portal.

PRF received in RP3 relates to payments (>$10K) received from January 1, 2021 through June 30, 2021. The period of availability associated with these payments is January 1, 2020 through June 30, 2022. The period of availability reflects COVID-19 expenses and lost revenues that may be used toward recognizing RP3 PRF payments (provided these expenses and lost revenues were not previously used towards PRF in RP1 or RP2). Additional resources for RP3 reporting can be found here on HRSA’s website.

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

CARES PRF Update

February 5, 2022

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 allocations, Period 2 Reporting, and new FAQs issued January 27, 2022.

CARES PROVIDER RELIEF FUND (PRF)Period 2 Reporting Update

January 15, 2022

Register HERE

to participate in Toyon’s open CARES PRF webinar Thursday 1/27 at 11 AM PST

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Today’s Reporting Update Includes:

I. HRSA Provides Additional Resources for PRF Period 2

II. Period 2 Allows Carry-forward of Unused Expenses and Lost Revenues from Period 1

III. Providers May Change Amounts and Methodologies for Determining Lost Revenue in Period 2

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, or fred.fisher@toyonassociates.com with any questions.

Providers in receipt of PRF related to Period 2 are now able to report on the use of the funding. Period 2 represents PRF received from July 1, 2020, through December 31, 2020 and is aligned with COVID-19 expenses and lost revenues from January 1, 2020 through December 31, 2021 (with no duplication of expenses and lost revenue reported in Period 1). The Period 2 reporting deadline is March 31, 2022.

I. HRSA Provides Additional Resources

HRSA’s website has new resources for PRF Period 2, including:

Notably, the Parent-Subsidiary Reporting Fact Sheet highlights flexibilities for reporting on the use of General Funds, while reiterating the complexities of transferring Targeting Funds between Parents and their respective Subsidiaries.

On the reporting of Targeted Funds between Parent and Subsidiary providers, HRSA explains:

“A parent TIN cannot report on a subsidiary’s Targeted Distribution payments. The original recipient of a Targeted Distribution payment must always be the Reporting Entity for that payment.”

However, although a Parent cannot report on a Subsidiary’s Targeted Funds, Targeted Funds may be transferred between the Parent and its Subsidiaries (increases the likelihood of HRSA audit). Providers are required to enter Targeted Funds transferred to/by the Parent entity in the Period 2 portal. The Parent-Subsidiary Fact Sheet states:

“Parent entities may transfer and re-distribute Targeted Distribution payments to, between, and among its eligible health care provider subsidiaries^[1]

…The entity that ultimately receives the transferred Targeted Distribution funds should provide the original recipient with necessary information on its use of the funds. This information should be included in the reporting submission completed by the original recipient.”

II. Period 2 Reporting Supports the Carryforward of Unused Expenses and Lost Revenues from Period 1

Reporting Period 2 COVID-19 Expenses

The period of availability to report expenses towards PRF in Period 2 overlaps with Period 1. Accordingly, with no duplication^[2] from amounts reported in Period 1, providers may report expenses from January 1, 2020 through June 30, 2021. Furthermore, in PRF Period 2, providers may report an additional six months of expenses from July 1, 2021 through December 31, 2021.

Reporting Period 2 Lost Revenues

PRF in excess of COVID-19 expenses will then be applied against quarterly losses to operating revenue from January 1, 2020 through December 31, 2021, that were not previously applied in Period 1. This is highlighted in Example 1 of Lost Revenues Guide – Reporting Period 2, stating:

“When the provider comes in to report in Reporting Period 2, if the provider did not already apply the entire $60M (losses from January 1, 2020 through June 30, 2021) to payments in Reporting Period 1, the provider will be able to apply the remaining unreimbursed lost revenues up to the PRF payments received and not used on expenses attributable to coronavirus in Reporting Period 2.”

Providers may also change amounts of reported losses in the pre-populated cells from Reporting Period 1 (i.e., losses from January 1, 2020 through June 30, 2021) “if there was a change

to patient care revenue since the RP1 report was filed”^[3^]. Providers revising losses from Reporting Period 1 are required to enter a justification limited to 1,000 characters. HRSA is also permitting providers to switch Lost Revenue Methodologies, as discussed in item #3 below.

III. Providers May Switch the Methodology for Determining Lost Revenue

Providers reporting lost revenues against residual PRF (after expenses) will be asked to select the Lost Revenue Methodology: Actual (Option i), Budget (Option ii), or Alternate (Option iii). Providers may change the methodology that was used in Reporting Period 1, provided the change is used across the entire Period 2 period of availability (lost revenues from January 1, 2020 to December 31, 2021). Any provider wishing to change its Lost Revenue Methodology must submit a “justification for change in lost revenues calculation method” with a narrative limited to 1,000 characters.

Providers reporting lost revenues under Alternate Methodology (Option iii) must confirm prepopulated information is accurate and are able to provide new documentation appliable to Reporting Period 2.

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^[1] The Targeted Distribution payment allocation may not exceed the Parent entity’s pro rata ownership share of the Subsidiary. Further, transferred Targeted Distribution payments face an increased likelihood of HRSA audit.

^[2]Per the What’s New in Period 2 Fact Sheet: “The Period of Availability for RP2 payments overlaps with payments received in RP1. Therefore, providers will need to show how payments were applied to expenses and lost revenues from Q1 2020 through Q4 of 2021. The expenses and lost revenues for Q3 2021 and Q4 2021 must not be duplicative of those included in the RP1 report for Q1 2020 through Q2 2021.”

^[3] What’s New in Reporting Period 2 Fact Sheet

Tag: CARES

September 30 Deadline for CARES PRF Reporting Period 3

CARES PRF Update

CARES PROVIDER RELIEF FUND (PRF)Period 2 Reporting Update

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