HHS Publishes Reporting Requirements for Provider Relief Fund Recipients and Changes Lost Revenue Calculation

On September 19, 2020, the Department of Health and Human Services (HHS) published new Post-Payment Reporting Requirements applicable to providers who received payments of more than $10,000 from the Provider Relief Fund*.  Qualifying recipients will be required to report: (1) healthcare expenses attributable to the coronavirus not reimbursed by other sources; (2) general and administrative expenses attributable to the coronavirus; (3) lost revenues attributable to the coronavirus; and (4) additional non-financial data.

Notably, HHS has changed how lost revenues must be calculated.  Formerly, HHS provided that “lost revenues” meant any revenue that a health care provider lost due to the coronavirus, such as the difference between a provider’s budgeted revenue and actual revenue, or comparison to revenues for the same period last year.  The new calculation of “lost revenues” defines it as a year-over-year change in net patient care operating income, which is equal to patient care revenue for the year minus patient care related expenses for the year.  The new guidance also places a cap on how much lost revenue providers can claim.

The HHS reporting portal will open on January 15, 2021. *The Post-Payment Reporting Requirements do not apply to Nursing Home Infection Control grants, Rural Health Clinic Testing grants, or reimbursements from the Health Resources and Services Administration Uninsured Program.