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FW: HHS Updates Provider Relief Fund Reporting Requirements


  • Today, HHS announced a revision to Provider Relief Fund (PRF) reporting requirements that broadens the definition of “lost revenue” for the purposes of reporting.
  • HHS’ reporting guidance published in September required that recipients show a negative change in YOY net patient care operating income.
  • Argentum and ASHA advocated for and sent letters to HHS requesting that the definition of lost revenue be redefined as “any revenue that…a health care provider lost due to coronavirus,” as originally outlined by HHS in June.
  • This revision will help communities adequately account for revenue losses associated with COVID-19.
  • Argentum is continuing to review these changes to ensure that they are not overly burdensome for providers.

In September, HHS issued its final PRF reporting guidance, which included an update to its FAQs “to clarify that for purposes of relief payments for lost revenues attributable to COVID-19, recipients must submit information showing a negative change in year-over-year net patient care operating income.” This revision overrode the original reporting requirements outlined by HHS on June 19. Argentum sent a letter and co-signed a letter with ASHA this week to HHS Secretary Azar, requesting a reinstatement of the original reporting requirements and that the definition of lost revenue be redefined as “any revenue that … a health care provider lost due to coronavirus,” as originally outlined.

Today, HHS issued an announcement that it has revised the reporting requirements and broadened the definition of “lost revenue”. They indicated: “In response to concerns raised, HHS is amending the reporting instructions to increase flexibility around how providers can apply PRF money toward lost revenues attributable to coronavirus. After reimbursing healthcare related expenses attributable to coronavirus that were unreimbursed by other sources, providers may use remaining PRF funds to cover any lost revenue, measured as a negative change in year-over-year actual revenue from patient care related sources.” This restoration will assist communities in adequately accounting for revenue losses associated with COVID-19. The amended reporting requirements guidance can be found here. Argentum will continue to review these changes to ensure that they are not overly burdensome for providers.

As a reminder, on October 1, HHS announced the next phase of funding from the PRF, for which assisted living providers are eligible. The Phase 3 distribution is meant to bring all qualified providers to a “baseline” distribution equivalent to 2% of revenue for a single year. Once that threshold has been met for all applicants, HHS will develop a methodology to disburse the remaining funds. The goal of the methodology is to distribute the remaining dollars in a proportionate manner based on revenue losses and increased expenses due to COVID-19. Applications for the Phase 3 disbursement are due no later than November 6 at 11:59 p.m. ET. Approximately 10-14 days after all applications are received, HHS will announce the methodology and proportion of losses that applicants are to receive.

Please note: It is important that you apply for Phase 3 even if you haven’t had your first payment processed from the Phase 2 General Distribution. You do not have to wait until your Phase 2 application is processed or funds are received before you can apply for the next round of funding. We strongly urge you to complete your application before the November 6 deadline to ensure that you will be eligible to receive this round of funding. You can read more here about the Phase 3 distribution and how to apply. There is a hotline number available (877-620-6194) for providers who may have questions about TIN verification or PRF applications. Please be sure to let us know if you still have not received TIN verification from your Phase 2 application.



North Carolina Assisted Living Association

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