Changes to Provider Relief Fund Requirements: What This Means for Anesthesia
Summary:
Anesthesia providers who accessed money from the Provider Relief Fund will have a bit more time to use these funds and to report back to the federal government, as HHS has recently announced that new timelines are now in place.
Sometimes, we receive good news. In a year dominated by distressing stories of mass illness and protracted lockdowns and financial strains, it's refreshing to hear something that provides a modicum of stress relief. You'll recall that the federal government enacted a series of laws, beginning last year, to mitigate the financial impact of the COVID pandemic on healthcare providers. Among these were the Coronavirus Aid, Relief, and Economic Security (CARES) Act; the Paycheck Protection Program and Health Care Enhancement Act; and the Coronavirus Response and Relief Supplemental Appropriations Act of 2021. While these laws made billions of dollars available to providers experiencing lost revenues attributable to COVID, the money did not come without a few conditions.
According to the initial instructions, those accessing the emergency relief funds were directed to meet certain utilization and reporting requirements. Specifically, the U.S. Department of Health and Human Services (HHS) began issuing notices in July, 2020 on post-payment reporting requirements. Then, on January 15 of this year, HHS issued updated guidance that included a portal registration process for fund recipients, as well as a June 30 cut-off date for using the funds. This month, however, the government provided some additional leeway concerning these requirements and deadlines.
Entering the Portal
On June 11, 2021, HHS updated the Post-Payment Notice of Reporting requirements for recipients of Provider Relief Funds (PRF). Complete details of the requirements can be found on the HHS website: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html. Included on this site are instructions concerning an electronic portal that providers must use for reporting purposes, along with information about registration and effective dates. The following is a summary of the registration requirements as found on the HHS website:
· The reporting portal is now open for registration. The portal can be found here: https://prfreporting.hrsa.gov/s/.
· Reporting entities will need to create a username (in the form of an email) and a password during the registration process.
· Registration is encouraged prior to reporting going live. Registration must be completed in one session and will take approximately 20 minutes to complete.
· Information needed to complete the registration includes the following:
* Tax ID Number (TIN) [or other number submitted during the application process (e.g., Social Security Number, Employer Identification Number (EIN)]
* Business name of the reporting entity (as it appears on IRS Form W-9)
* Contact information (i.e., name, phone number, email) of the person responsible for submitting the report
* Address (i.e., street, city, state, five-digit zip code) of the reporting entity as it appears on IRS Form W-9)
* TIN(s) of subsidiaries [if a provider is reporting on behalf of subsidiary(ies) in a list delimited by commas (e.g., 123456789,987654321,135791357)]
* Payment information (for any of the payments received)
-TIN of entity that received the payment
- Payment amount
- Mode of payment (check or direct deposit ACH)
- Check number or ACH settlement date
Making a Report
After registration, the portal will then be used to perform the reporting requirements as specified by HHS. Here are some of the key takeaways concerning the reporting process, according to the agency's website:
· Actual reporting can begin via the portal, beginning July 1.
· Recipients are required to report for each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments). See Summary Table below.
· Recipients will have a 90-day period to complete reporting (rather than a 30-day reporting period). See Summary Table below.
· All recipients of Provider Relief Fund (PRF) payments must comply with the reporting requirements described in the Terms and Conditions and specified in directions issued by the Secretary. Terms and Conditions can be found here: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html#terms-and-conditions
It should be noted that the period of availability of funds is based on the date the payment is received (rather than requiring all payments be used by June 30, 2021, regardless of when they were received). See Summary Table below.
A Final Word
Finally, the new HHS instructions detail certain audit requirements. The following is an excerpt from the HHS website regarding these requirements for expenditures over $750,000 of governmental funds. Please refer to website for full details.
Recipients that expend a total of $750,000 or more in federal funds (including PRF payments and other federal financial assistance) during their fiscal year are subject to Single Audit requirements, as set forth in the regulations at 45 CFR 75 Subpart F.
Non-federal entities must have a Single Audit conducted in accordance with 45 CFR 75.514 that must be submitted electronically to the Federal Audit Clearinghouse.
So, while there always seems to be certain strings attached to getting help from the government, it's nice to know that, every now and then, those strings have a little more slack than previously perceived. If you have further questions about the new deadlines and requirements concerning the Provider Relief Fund, please go to the links listed above or contact us at info@anesthesiallc.com.