HHS has yet to declare a revised deadline for healthcare providers to report their Provider Relief Fund grants after scrapping the original one late last week.
The agency had originally planned to open its reporting portal on Jan. 15, 2021, with the first submissions required by Feb. 15. That all changed with Congress' passage of the Coronavirus Response and Relief Supplemental Appropriations Act in late December, which poured another $3 billion into the PRF pot and tweaked reporting requirements. HHS said it's reworking its rules so they're consistent with the law.
Providers are generally happy about the change, said Aparna Venkateswaran, a senior manager with Moss Adams.
"I think the more time everybody has, it's just helpful to be able to gather everything," she said.
Some providers were concerned about only having a month between the portal opening and the initial reporting deadline, which originally applied to reporting on eligible expenses and lost revenue recognized in calendar 2020. A second deadline at the end of July applies to funds spent in the first half of 2021, but Venkateswaran said that may be pushed back, too.
Providers could log into and register with an HHS portal starting Jan. 15, even though they can't yet start reporting the grants they spent. Registration requires providing straight-forward information like tax identification numbers, contact information, subsidiary information and payment information, said Lori Laubach, a partner with Moss Adams.
Registering early might give providers access to any notifications sent through the portal, Venkateswaran said.
"There's no harm in doing it as soon as is practical," she said.
While finance leaders are happy to have more time to report, the new reporting guidance further muddies the waters on certain questions that will determine how much of the money they keep, said Rick Kes, a partner and senior industry analyst with RSM. Chief among them is whether the grants can be used to offset expenses related to maintaining healthcare delivery capacity. That language was omitted from the most recent guidance, but is still included in a frequently asked questions document on the department's website. While the guidance says providers can count money spent on supplies, equipment, facilities, personnel and information technology necessary to respond to the pandemic, Kes said the broader definition would allow providers to count the money used to "keep the lights on," including areas not directly affected by COVID-19.
"A lot of healthcare organizations are taking that statement to use a broad definition of what expenses are included," he said.
HHS didn't return a request for comment on why that section was omitted from the new guidance. Moss Adams' Laubach said it was generic and HHS may have wanted to refine the instructions. Her firm advised clients to track areas directly affected by COVID. Those who interpret the guidance more broadly should be able to support it in their documentation, she said.
The appropriations act passed last month also omits a rule that previously barred targeted PRF distributions from being shared across an organization, such as between a single hospital and its parent health system. That rule never existed for general PRF distributions.
"So you're able to pass the distributions around within a consolidated entity or a corporate group based on the need, whether it's targeted or general distributions that they got," Venkateswaran said.
Kes said some providers, especially not-for-profits, were hoping for more clarity on the definition around parent and subsidiary organizations for the purpose of recording the grant money. Barring a specific definition, many organizations are adopting a broad interpretation that allows them to keep more of the grant money, he said.
"That's a precarious situation they find themselves in: Do we interpret this to our best advantage or our worst?" he said.
As of Jan. 11, HHS said it has distributed nearly $117 billion in Provider Relief Fund grants to about 644,000 provider tax identification numbers. Of that, about unique 400,000 provider IDs have accepted the terms and conditions on almost $102 billion in payments.
Even though providers have more time to report on their PRF grants, Laubach said they shouldn't stop examining how they'll track the funds.
"I think they should keep on full press," she said, "and then make sure they have controls to add additional expenses as they move forward if they haven't used all the funds."
