The PRF reporting portal opened last Thursday as previously announced. There’s a lot to review but the biggest update was to the lost revenues calculations, which will hopefully be welcomed news for many providers.
Weekly Insights
The lost revenues calculation has once again been updated, per the details on Period 1 calculations provided by the HHS. The reporting portal will calculate lost revenues based on information you enter into the website.
The biggest change is this: in quarters where revenues increased, $0 will be reported as lost revenues. What this means is that quarters with gains over baselines will not be used to offset quarters with losses. Only quarters with actual lost revenues are accumulated and applied against your PRF payments.
Remember, there are three options for reporting lost revenues:
- 2019 actual to 2020 actual
- 2020 budget to 2020 budget
- Any reasonable method
For options 1 and 2: Enter in 6 quarters of actual revenue information spanning Q1 2020 through Q2 2021 to start. Option 1 will have you report Q1 – Q4 2019 revenue matched up to Q1 – Q4 2020 revenue. But on Q1 2021 and Q2 2021 you will again compare to Q1 and Q1 2019 revenue.
For option 2: Compare Q1 2020 – Q2 2021 budgeted revenue matched up to Q1 2020 – Q2 2021 actual revenue. The standard still exists that the budget had to be approved by 3/27/2020 and a copy of the budget needs to be approved. What is not mentioned is how this affects the 2021 budget numbers. It appears only the 2020 budget has to be approved. This also leads to questions in future reporting periods of what will be required to support budgeted revenues.
For option 3: Enter quarters with lost revenues for Q1 – Q2 2021.
Here is an example of how option 1 & 2 would look in calculating lost revenues:
With all of these changes to lost revenues, we also recommend that this week you go back and recalculate lost revenues using the examples above as a starting point. This is different than previous calculations from HHS and will have an impact into how much of your PRF payments you are able to keep.
Recommendations
Our recommendation for this week is to log into the reporting portal and work through the first few items and make your way to Step 4, where HHS confirms what payments they have on record and that you are reporting on in Period 1. We have already seen instances where General or Targeted Distribution payments are missing from this confirmation screen. Correcting this will require a call into the HRSA helpline.
In the reporting portal, you have to start at Step 1 and complete each step fully before moving on.
You cannot jump to other areas and fill out information. Your COVID expenses, facility and personnel, and lost revenues metrics have to be entered by quarter. To assist you with submitting your information, our team has prepared a workbook that will compliment your own internal records and help you to accumulate your information as HHS will have you report on it. Click here to download the workbook.
Information entered as Other Assistance (PPP loan, state and local grants, FEMA funds)
This information will not be used directly in the calculation of COVID expenses or lost revenues. It is informational only at this time.
When reporting expenses attributable to COVID-19 to support General & Targeted Distributions,
Those expenses have to be entered as only the amounts not reimbursed by other sources. In other words, it needs to be net of any other grants, FEMA funds, business interruption insurance or PPP loan forgiveness amounts. It’s implied in the FAQs that these expenses would also be net of any patient reimbursement but not specified in the instructions.
A new requirement from June 11 is to report “Net Unreimbursed Expenses due to Coronavirus.”
It’s now further explained that this step in the reporting process is to include any expenses incurred by your organization that are related to Coronavirus but were not reimbursed at all, even including PRF payments. This differs from expenses used to support General and Targeted Distributions (which are entered in a separate step) as these are after applying your organization’s PRF payments to your coronavirus expenses. Again, this is new and HHS expects that this may be $0 for many organizations.
Friday July 9th PRF Update Webinar
To access resources from this webinar, please fill out the form below.
Please reach out to your local Blue & Co. advisor or Michael Alessandrini if you have any questions.
