October 19, 2021

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Let’s Talk Compliance Recap: Supplier Aid Fund Reporting Necessities & Compliance Issues | Foley & Lardner LLP

In the newest installment of our “Let’s Chat Compliance” series, Foley & Lardner’s Alexis Bortniker and PYA’s Martie Ross answered many issues regarding Company Aid Fund (PRF) reporting requirements. A recording of the celebration is accessible below.

Unfortunately, there had been far more thoughts from attendees than we could deal with in 45 minutes, so as a complement to the July 16 event, we have compiled those queries to present the following responses.

What “official” assets are readily available to aid with reporting?

HHS’ Reporting Demands and Auditing webpage involves links to the June 11, 2021, Post-Payment Discover of Reporting Necessities pertinent FAQs recordings of the three webinars HHS presented in July 2021 addressing reporting prerequisites the Portal Reporting Consumer Guidebook and the very helpful PRF Reporting Tutorial video clip. Also, you can get hold of simply call the Service provider Support Line at (866) 569-3522 among 8 a.m. to 10 p.m. CT, Monday through Friday.

Do the costs have to be entered as properly as the shed profits? Or can we just post the misplaced earnings info?

HHS resolved this concern through its 7/20 webinar, stating a single has the solution of reporting no bills for which PRF payments have been applied. Notice, nevertheless, this may preclude the Reporting Entity from professing COVID-associated bills incurred prior to 7/1/21 at a later on date (e.g., report on subsequent PRF payments).

Is misplaced revenue centered on gross earnings or net revenue? What payments must or should really not be included in individual care revenues?

Centered on our evaluate of all out there steering, we believe that the most defensible definition of “patient treatment revenue” for functions of PRF reporting of misplaced revenue is the marketplace regular “net individual company profits,” i.e., gross earnings considerably less profits deductions fewer implicit cost concessions. To guarantee a legitimate comparison between time intervals (i.e., 2019, 2020, and Q1 and Q2 of 2021), HHS has instructed vendors to subtract any profits relating to client services not furnished through the time period (e.g., supplemental payments, expense report settlements, A/R changes relating to prior years). (Observe that no adjustment should really be manufactured to 2020/2021 affected individual treatment revenue to account for bigger payment charges thanks to COVID-19 (e.g., suspension of Medicare sequestration, HRSA COVID-19 promises reimbursement for testing, remedy and vaccine administration for the uninsured) no client treatment revenue—including these bigger payment rates—should be integrated under “Other Guidance Received”). Any added changes intended to “normalize” patient care profits for functions of comparing time periods would demand just one to use the 3rd alternative for calculating missing profits (alternate fair process).

We be aware the recent July 15 FAQ introduces some confusion regarding prices, payments, and contractual changes. The FAQ implies the definition of profits is gross rates, which is not consultant of readily available dollars to deal with expenses. We observe this FAQ is inconsistent with references in HHS’ Reporting Portal User Information, which takes advantage of the phrase “actual revenues/net costs acquired … for patient care” regularly. By using the word “received” rather than “billed,” HHS evidently indicates web earnings – not gross income – ought to be claimed.

Do capitation payments count as patient treatment earnings?

We imagine that entities should really adhere to their historical basis of accounting (which include income recognition guidelines) to account for capitation payments and other benefit-based mostly care payments.

Are Medicare State-of-the-art/Accelerated Payments gained, but essential to be repaid, integrated in “Other Guidance”?

Medicare Progress payments are NOT involved in Other Guidance Received. The identical is legitimate for Paycheck Safety Method resources that have not been forgiven.

Selection 3 for lost revenues only asks for losses in total, although choices 1 and 2 ask for losses by payor. Is HHS anticipating solution 3 to also report by payor?

The portal requires input of a single range for misplaced earnings for a given quarter there is no choice to report by payor. HRSA has not positioned any precise prerequisites on choice 3, apart from to point out it is the Reporting Entity’s load to display reasonableness.

What constitutes obligated funds for FEMA? Is it when the applicant gets resources or when the grant is approved?

In accordance to the FAQs, “[i]f a supplier has submitted an software to FEMA, but has not nonetheless obtained the FEMA funds, the company must not report the requested FEMA amounts in the Provider Aid Fund report. If FEMA cash are obtained throughout the exact same Payment Acquired Period of time in which supplier is reporting on use of Provider Aid Fund payments, the receipt and software of each payment sort is essential in the Provider Relief Fund reporting course of action. If an entity gets a retroactive payment from FEMA that overlaps with the time period of availability, the entity should not use the FEMA payment on expenses or missing revenues by now reimbursed by Company Reduction Fund payments.”

Our organization obtained cash 08/04/2020. Really should we wait around until eventually soon after September 30, 2021, to report?

The group must use these resources by December 31, 2021, and ought to report on the use of resources between January 1, 2022, and March 31, 2022. These money are unable to be integrated in the report relating to funds been given by June 30, 2020.

What if our basis raised cash for “COVID”?

If the donations were precisely earmarked for COVID reduction and can’t be employed for any other objective, they should really be bundled as “Other.”

Is subsidiary defined by GAAP or tax return consolidated?

To establish irrespective of whether an entity is the dad or mum organization, the entity will have to stick to the methodology used to decide a subsidiary in their economical statements. If none, the entity with a the greater part possession (bigger than 50%) will be regarded as the parent business.

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