As APTA reported on Sept. 23, the U.S. Department of Health and Human Services is continuing to provide details on how providers who received relief funds need to account for how the money was spent, with the latest details including a change in how lost revenue should be calculated. That shift has raised concerns, with critics saying that the new approach may increase the number of recipients who have to return funds, and could make it hard for some smaller businesses to even come up with the calculations in the first place.
The change is part of a recently announced shift in HHS' plans for how relief fund recipients are to report use of the money, from a quarterly reporting system to a one-time accounting delivered via an online portal. HHS later confirmed that the portal will open on Jan. 15. Feb. 15 will be the first reporting deadline for all providers on the use of funds, and July 31 will be the final reporting deadline for providers who did not fully expend the funds before Dec. 31, 2020.
Information providers can expect to provide for the reporting requirements include lost revenues, expenses attributable to coronavirus, basic organization information, other assistance received in 2020, and non-financial information (employees, patients, etc.).
Among the reporting requirements released with the updated guidance on Sept. 19 is a change that has sparked criticism from the American Hospital Association and other organizations — a new definition of "lost revenue" no longer based on revenue lost due to the pandemic, but instead represented as a negative change in year-over-year net patient care operating income.
According to a letter submitted to HHS by AHA, the new formula is "unfair and unrealistic." AHA believes organizations that moved aggressively to reduce costs during the pandemic may find that the comparison between 2019 and 2020 reflects a difference that's lower than the payments they received, requiring them to return money to HHS. The AHA letter states that this problem is likely to affect "rural hospitals and those serving high numbers of low-income, elderly, and severely ill patients, particularly in vulnerable communities."
Smaller organizations could face a different challenge, according to an article in Inside Health Policy: Besides the possibility that their cost-saving actions essentially would be penalized in the new system, they may not have been tracking their operations and finances in the ways now required by HHS.
The Lesson: Stay Informed
"The recent shift in calculation requirements is another reminder that providers who received relief funds under the CARES Act need to stay on top of changes," said Kara Gainer, APTA's director of regulatory affairs. "As we've seen over and over, HHS can release guidance one day, and modify or change it completely the next, and providers will be required to comply with whatever's been put in place most recently."
To do that, Gainer recommends that PT providers monitor APTA’s weekly Wednesday and Friday email alerts, regularly check the HHS CARES Act Provider Relief Fund webpage, and sign up to receive HHS press releases, an option available near the bottom of the HHS News webpage.