On October 22, HHS released updated CARES Act PRF guidance related to reporting and reverted back to the June 19th FAQs that based the amount of PRF a provider is entitled to on “lost revenue” as opposed to also looking at a reduction in “net income”. See HMA blog posting: (CLICK HERE)
As excerpted from the “Reporting Requirements Policy Updates” (CLICK HERE)
On September 19, 2020, HHS issued instructions for reporting on the use of PRF distributions. These instructions, reflecting the Department’s balancing of dual objectives, limited the applicability of funds to an amount that would allow most providers to be no more profitable in 2020 than in 2019. At the time, HHS concluded that it would be inequitable to allow some providers to be more profitable in 2020 than 2019, while so many other providers struggled to remain viable…This decision to prohibit most providers from using PRF payments to become more profitable than they were pre-pandemic, in order to conserve resources to allocate to providers who were less profitable, has generated significant attention and opposition from many stakeholders and Members of Congress. There is consensus among stakeholders and Members of Congress who have reached out to HHS that the PRF should allow a provider to apply PRF payments against all lost revenues without limitation. In consideration of this feedback, HHS has amended its reporting instructions to provide for the full applicability PRF distributions to lost revenues.
This is good news for HMA clients as it provides much more clarity. We still await instructions on how to demonstrate “lost revenues”. For a full reading of the updated Post Payment Reporting Requirements, (CLICK HERE):