By Yann Reichelt, CPA, Business Assurance & Advisory Services Manager
Article 3 in our 3 part series on Provider Relief Fund audit and reporting requirements
Two Reporting Categories for Recipients of Provider Relief Funds
In our previous two articles, we discussed what the Provider Relief Fund is and the related auditing requirements issued by the Department of Health and Human Services. This article focuses on the reporting requirements under the Provider Relief Fund and what healthcare organizations should do to prepare.
Recipients of Provider Relief Funds are required to report funds to reimburse eligible healthcare providers for healthcare related expenses or lost revenues attributable to COVID-19. Healthcare related expenses are those that are attributable to COVID-19 and may be incurred both in treating confirmed or suspected cases of COVID-19, preparing for possible or actual COVID-19 cases, maintaining healthcare delivery capacity, etc. Lost revenue is represented as a negative change in year-over-year actual revenue from patient care related sources. Furthermore, the reporting requirements are broken out into two categories depending on the amount of funding received.
For Recipients of Provider Relief Fund Payments between $10,000 and $499,999
- Required to report healthcare related expenses attributable to COVID-19, net of other reimbursed sources (e.g., payments received from insurance and/or patients, and amounts received from federal, state or local governments, etc.) in two categories (1). G&A expenses and (2) Other healthcare related expenses. These are the actual expenses incurred over and above what has been reimbursed by other sources.
- Total revenue/net charges from patient care related sources (2019 and 2020)
- Revenue from Patient Care Mix (2019 and 2020). Other Assistance received during 2020 – e.g., Paycheck Protection Program loans, FEMA CARES, business insurance, etc.
For Recipients of Provider Relief Fund Payments $500,000 or More
- The reporting requirements are the same for healthcare expenses and lost revenue for organizations that received more than $500,000 of PRF payments, except that they must also include more detailed information within the two categories of G&A expenses and other healthcare related expenses.
- Additional G&A expenses required to be reported:
- Fringe benefits
- Lease payments
- Other G&A expenses considered to be part of overhead structure
- Additional healthcare related expenses attributable to COVID-19 incurred over and above what has been reimbursed:
- Information technology
- Other healthcare related expenses
Additional non-financial data will also be reported by quarter
- Facility, staffing and patient care
- Change in ownership
What should healthcare entities be doing to prepare?
- Follow accounting policies and procedures for COVID-19 expenses and ensure proper record retention.
- Maintain internal controls over compliance by documenting any changes in internal control due to COVID-19 funding. Focus on the following areas: payroll, non-payroll, and procurement.
- Understand compliance requirements promulgated by the Department of Health and Human Services.
READ OUR FULL SERIES OF ARTICLES ON THE PROVIDER RELIEF FUND FOR HEALTHCARE ENTITIES
The information contained within this article is provided for informational purposes only and is current as of the date published. Online readers are advised not to act upon this information without seeking the service of a professional accountant, as this article is not a substitute for obtaining accounting, tax, or financial advice from a professional accountant.