Categories
Uncategorized

HHS FAQ 01/27/2022

Calculating Eligible Expenses and Lost Revenue Can a Reporting Entity use a different lost revenues methodology for each reporting period? (Added 1/27/2022) Yes. However, it is important to note that due to the overlapping periods of availability, each time a Reporting Entity changes the method used to calculate lost revenues, the system will recalculate total lost revenues for the entire period of availability. It is important to note that due to the overlapping periods of availability, if a Reporting Entity changes the method used to calculate lost revenues, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues. The system will also require that the Reporting Entity submit a written justification to support and explain the change in lost revenues methodology. Please refer to the Post-Payment Notice of Reporting Requirements for information on the three available methodologies for calculating lost revenues.

 

In subsequent reporting periods, will Reporting Entities be able to change the lost revenues methodology used in a previous reporting period? (Added 1/27/2022) Yes. Reporting Entities that previously reported will be able to choose a different methodology for calculating lost revenues during Reporting Period 2 and any subsequent reporting periods. However, if the Reporting Entity decides to use a different methodology, they must then use the new methodology to calculate lost revenues for the entire period of availability. The Reporting Entity will be required to submit a justification for the change. If a Reporting Entity chooses a different methodology, lost revenues by quarter will not pre-populate from the previous reporting period. It is important to note that due to the overlapping periods of availability, if a Reporting Entity changes the method used to calculate lost revenues, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues. Please refer to the Post-Payment Notice of Reporting Requirements for information on the three available methodologies for calculating lost revenues.

 

In a previous reporting period, a Reporting Entity reported lost revenues that were greater than the PRF payments it received. How will the system account for the unused lost revenues previously reported? (Added 1/27/2022) The PRF Reporting Portal was designed so that each subsequent report will build from the previous completed and submitted report. The Reporting Portal will calculate remaining unused lost revenues that can be reimbursed by PRF payments received during future payment periods. If a Reporting Entity had more lost revenues for the overlapping period of availability than the Entity was able to demonstrate in a previous reporting period, then the Reporting Entity will be able to reimburse the unused lost revenues with payments issued in subsequent periods. It is important to note that due to the overlapping periods of availability, if a Reporting Entity changes the method used to calculate lost revenues from one reporting period to another, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues.

 

In a previous reporting period, a Reporting Entity reported lost revenues that were greater than the PRF payments it received. How will the system account for the unused lost revenues previously reported? (Added 1/27/2022) The PRF Reporting Portal was designed so that each subsequent report will build from the previous completed and submitted report. The Reporting Portal will calculate remaining unused lost revenues that can be reimbursed by PRF payments received during future payment periods. If a Reporting Entity had more lost revenues for the overlapping period of availability than the Entity was able to demonstrate in a previous reporting period, then the Reporting Entity will be able to reimburse the unused lost revenues with payments issued in subsequent periods. It is important to note that due to the overlapping periods of availability, if a Reporting Entity changes the method used to calculate lost revenues from one reporting period to another, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues.

 

What happens when a Reporting Entity changes the lost revenues methodology from one reporting period to the next? (Added 1/27/2022) When a Reporting Entity chooses a different lost revenues methodology from one reporting period to the next, the system requires confirmation of the change by the Reporting Entity. If the lost revenues methodology changes, data submitted in the prior reporting period is not prepopulated into the current report (as it would be if the same methodology was used from one reporting period to the next).

After a change in methodology is saved in the current report, the What happens when a Reporting Entity changes the lost revenues methodology from one reporting period to the next? (Added 1/27/2022) When a Reporting Entity chooses a different lost revenues methodology from one reporting period to the next, the system requires confirmation of the change by the Reporting Entity. If the lost revenues methodology changes, data submitted in the prior reporting period is not prepopulated into the current report (as it would be if the same methodology was used from one reporting period to the next). After a change in methodology is saved in the current report, the

Can Nursing Home Infection Control payments be used to reimburse lost revenues attributable to coronavirus? (Added 1/27/2022) No. Per the payment Terms and Conditions, the Nursing Home Infection Control Distribution (including any Quality Incentive Program payments) may not be used to reimburse lost revenues.

 

If a nursing home or skilled nursing facility received Nursing Home Infection Control Distribution payments in addition to General Distribution payments and other Targeted Distribution payments, how may these payments be applied toward expenses and lost revenues? (Added 1/27/2022) PRF recipients have the flexibility to identify how to use their multiple payments toward expenses and lost revenues, but must abide by the Terms and Conditions associated with each of the payments and follow the requirements for determining allowable expenses and lost revenues. The Nursing Home Infection Control Distribution, which includes the Quality Incentive Program payments, may only be used to reimburse infection control expenses. This type of Targeted Distribution payment may not reimburse lost revenues. PRF payments may be used as described in the relevant payment Terms and Conditions for expenses and lost revenues, as appropriate, dating back to January 1, 2020. Because of the overlapping periods of availability, providers have the flexibility to identify which payments they will use to reimburse allowable expenses and lost revenues incurred during the period of availability. Duplication of reimbursement for expenses and lost revenues is not permitted.

 

When completing a report, are Reporting Entities required to submit documentation to support Nursing Home Infection Control Distribution expenses? (Added 1/27/2022) No. Documentation to support Nursing Home Infection Control Distribution expenses is not required to be uploaded to the PRF Reporting Portal at the time of reporting. However, Reporting Entities are required to maintain supporting documentation, per the Terms and Conditions, that demonstrates that any allowable expenses were incurred during the period of availability. Supporting documentation must be made available upon the request of the Secretary of the Department of Health and Human Services.

 

If the original recipient of a Targeted Distribution payment is a subsidiary, and the recipient transferred that payment to a parent entity, how does the original recipient (i.e., subsidiary) demonstrate the use of funds in its report? Is it sufficient for the subsidiary to report the amount transferred to the parent entity? (Added 1/27/2022) For any subsidiary that was the original recipient of a Targeted Distribution payment reporting on a payment spent by a parent entity, the expense worksheet(s) in the subsidiary report must include any expenses applied to the payment, whether those were the expenses of the subsidiary or the entity to which the payments were transferred. For any subsidiary Reporting Entity reporting on how a payment was used to reimburse lost revenues, the subsidiary Reporting Entity can use the alternative method for calculating lost revenues and demonstrate in their method how the lost revenues of the parent or other subsidiary entity to which the payment was transferred was considered in the lost revenues calculation. Using the alternative reasonable methodology will allow Reporting Entities to reduce the parent entity’s report by the amount of lost revenues accounted for by the Targeted Distribution payment originally received by the subsidiary. The subsidiary Reporting Entity that originally received the Targeted Distribution should report the exact amount of lost revenues as the Targeted Distribution payment and the same dollar amount by which the parent entity’s lost revenues were reduced. The deductions and reconciliations must be accounted for in each methodology calculation for the parent and subsidiary that originally received the Targeted Distribution payment. Both reports together should be sufficient for audit purposes.

 

If a Reporting Entity plans to report on General Distribution payments that were transferred from a subsidiary that received the initial payment, how should patient care revenue or lost revenues be aggregated and reported in the portal? (Added 1/27/2022) HRSA does not prescribe which method Reporting Entities should use to calculate lost revenues. However, Option iii, “alternate reasonable methodology,” provides the greatest flexibility in unique circumstances.

 

If a Reporting Entity returned funds and the returned funds are not reflected in the “Payments to Recipients” page in the PRF Reporting Portal, what should the Reporting Entity do? (Added 1/27/2022)

There may be a delay between the time a payment is returned by a PRF recipient and the time the payment is reconciled by HRSA. If a Reporting Entity does not see a returned payment reflected in the Payments to Recipients page of the PRF Reporting Portal, the Reporting Entity should contact the Provider Support Line at 866-569-3522 (for TTY, dial 711) to provide information about the return (e.g., original payment date, amount returned, date of return, method of return) to assist HRSA in the reconciliation of the returned payment amount.

 

If a Reporting Entity returns unused funds in excess of the amount owed, will HRSA repay the Entity the difference between what was owed and returned? (Added 1/27/2022) HRSA will not repay Reporting Entities the difference in unused funds that were owed and the amount that was returned.