For anyone who received money through the Provider relief fund (PRF) from HHS, it has been quite the ride.
To give some history, these funds were first released in April 2020, awarded as part of the CARES Act that was signed into law in March 2020. Since the release of these funds, it has been a wild ride of unclear guidance, guidance changes, information releases for upcoming deadlines that have been changed - and the ride is continuing.
In January, the portal for reporting opened for registration as the first step of the process to complete the reporting with an original deadline date of February 15, 2021. Currently, the portal is ONLY open for registration - we encourage you to complete the registration but there is not an updated deadline date for the 2020 reporting, https://prfreporting.hrsa.gov/s/. We are hopeful that once that deadline is released that there will be clearer guidance released for the use of funds.
Here are some important points that we want to share as you continue to think about the use of these funds:
Remember – if you are applying these funds to salaries - DO NOT exceed Federal salary cap for ALL funds combined (HRSA & PRF).
As these funds are being used it is very important to have clear and complete documentation justifying any use of the funds.
These funds are still not straightforward, and we should be prepared to change what we have assumed as final guidance is released.
These monies are Federal Funds and considered “Other Direct Assistance” – these are NOT grant funds.
There are two ways to use the funds – expenses and lost revenue. The use of funds for expenses must be evaluated first before looking at lost revenues.
Interpreting the current guidance, the safest use of funds is clear and direct COVID-19 related expenses that another source has not reimburse and is NOT obligated to reimburse.
For the lost revenue calculation, the revenues include go beyond just patient service revenue and the following must be included in the calculation (PRF funds are excluded)
340B revenues
PPP
Grants
Other revenues that attribute to patient care revenue
Currently, you have until June 30, 2021 to utilize these monies
HHS can audit PRF expenses up to 3 years after reporting submission
So as of this writing – March 5, 2021 - we are still riding the wave of unknown deadlines and unclear guidance. Hopefully we will get some clarity in the near future.
In the meantime, keep your eye out for added guidance coming from HHS here: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/provider-relief-fund-general-info/index.html
If you would like guidance on the PRF, CLC can help. Please reach out to amyb@communitylinkconsulting.com for more information.