Provider Relief Fund Reporting
If you received and accepted COVID Provider Relief Fund (PRF) payments, you will likely be required to report how those funds were used. The original timeline for reporting has been delayed, and while there is currently no new reporting schedule, there are some steps you can take now to be prepared.
Who needs to report?
As the rules currently stand, any agency that received one or more Provider Relief Payments totaling more than $10,000 will be required to submit a report. You may have received a Phase 1 payment, which was automatically deposited into your bank account without an application process. You may have also received payments from Phase 2 or Phase 3 funding. These phases required an application process and payments were based on information in the application. If your agency’s total from all 3 phases is more than $10,000 and you kept all the payments, you will be required to submit a report detailing the use of those funds.
When are you required to report?
The original deadlines for reporting have been lifted, and currently, there are no published deadline dates. Once the reporting process begins, it will be done through an on-line portal, which can be found here. One step you can take right now is to access the portal and complete the registration section. Once you are registered, any announcements regarding the opening of the portal for reporting will be sent to the contact person identified during registration.
This registration step takes about 20 minutes. You will be prompted to create a username and password, and submit the following information:
- Legal Business Name
- Tax ID Number
- Contact Information for person who will submit the report (name, phone number, email)
- Provider Address (street, city, state, 5-digit zip code)
- Payment Information (payment amount for each phase of funding, payment type, check number or ACH date)
What are you required to report?
Reporting will fall into 2 main categories—increased expenses and lost revenue related to COVID 19. The HHS website has a variety of resources on allowable expenses and calculating lost revenue. Here are some links to get started:
Reporting Requirements and Auditing (main page)
This page includes several helpful links. The link to Terms and Conditions will take you to the full text of the agreement accepted for each phase of provider relief funding.
Detailed Reporting Requirements (January 15, 2021)
One-page clarification of Allowable Expenses
While the website has quite a bit of information, there will likely be some unanswered questions. The Health Resources and Services Administration (HRSA), who distributed the provider relief funds, plans to offer webinar question and answer sessions before the reporting deadline. Dates for those webinars have not been announced, so check the Reporting Requirements web page regularly for updated information and webinar dates. Submitting your registration information through the reporting portal will also add you to the mailing list to receive updated information.
As we receive more information on acceptable methods for calculating lost revenue, Systems Design will be able to provide you with the reports and data needed to report those losses.
Medicare Payment for Non-Transports—A Possibility?
The latest stimulus package from Congress includes a new opportunity for ambulance providers. The American Rescue Plan Act allows Medicare to temporarily waive, in limited circumstances, the requirement that an ambulance service must include the transport of an individual. This waiver is limited by 3 requirements. First, the service must be in response to a 911 call. Second, the patient would have normally been transported to a payable destination, such as a hospital emergency room. Third, the transport did not occur as a result of community-wide, public health emergency protocols, requiring that there be no transport.
Throughout this pandemic, many EMS agencies have been asked by their local hospitals and health departments to not transport low-acuity patients to the hospital. This keeps the hospital open for acutely ill patients and keeps the low-acuity patients from either spreading or acquiring COVID-19 in the emergency room. The EMS community has stepped up to that challenge, even though there was very little reimbursement for non-transports. If your agency has been providing this type of service, and you have protocols specific to the public health emergency, you might be able to receive payment from Medicare for non-transports that meet this limited situation.
What types of services would not qualify for payment?
There are some treat, no transport situations that do not qualify for payment under this waiver. The waiver does not apply to patient refusals (AMA), or a patient’s own wish to stay at home. It also does not apply to situations covered through your current community paramedic/ MIH protocols.
When will payment for non-transports be implemented?
While the legislation allows Medicare to waive the rules requiring transport, it is the HHS Secretary who has the authority to implement this waiver or not. It is widely expected that the waiver will be implemented, and we hope to bring you that news soon.
More information will be provided as it becomes available. Please contact admin@sdwems.com or 800-585-5242 if you have any questions.