10/6/2020 Hospital & Health System Town Hall Helping leaders navigate HHS Post-Payment Notice of Reporting Requirements October 5, 2020 Introductions Danielle Solomon Kevin Gore Kimberly McKay National Industry Partner Partner Managing Partner Audit & Advisory AICPA Health Care Expert Panel FASB NFP Advisory Committee 1
10/6/2020 Agenda PRF & FAQ Summary Post-Payment Notice - 9.19.20 Revenue Recognition Guidance Questions with Post-Payment Guidance 5 Recommendations/Actions 6 Q&A DISCLAIMER › Information in this presentation is as of October 5 › At this time, HHS has not issued any guidance or clarification on the September Notice › The AICPA has issued guidance for revenue recognition for proper accounting for Provider Relief Funds › HFMA, AHA, the AICPA Health Care Expert Panel and others are reviewing the Notice and looking to provide guidance and insight › Stay tuned for further developments through BKD Thoughtware TM bkd.com/hc 2
10/6/2020 PRF & FAQ Summary The information contained in these slides is presented by professionals for your information only & is not to be considered as accounting advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered. Provider Relief Fund Summary Phase 1 & 2 General Distribution ($68 Billion in total) April / June COVID-19 T Skilled Indian Safety Net High Nursing Medicaid A Rural Nursing Health & Impact Home & CHIP R Facilities Services Children’s Area G E T May May May May May June June July E D $1 $11B 1B $22B $4.9B $500M $14.4B $2.5B $15B Phase 3 General Distribution ($20 Billion) October The information contained in these slides is presented by professionals for your information only & is not to be considered as accounting advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered. 3
10/6/2020 Provider Relief Fund Terms & Conditions › The terms & conditions of Provider Relief Funds (PRF) state that relief fund payments will only be used to prevent, prepare for, & respond to coronavirus & shall reimburse the recipients only for healthcare-related expense or lost revenue attributed to coronavirus › The Recipient certifies that it provides or provided after January 31, 2020 diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 › The Recipient certifies that it will not use the Payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse The information contained in these slides is presented by professionals for your information only & is not to be considered as accounting advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered. bkd.com/hc HHS Issued Frequently Asked Questions to Address Terms & Conditions The information contained in these slides is presented by professionals for your information only & is not to be considered as accounting advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered. bkd.com/hc 4
10/6/2020 HHS FAQ Answers Impacted by HHS Post-Payment Notice of Reporting Requirements › If a provider secures COVID-19-related funding separate from the Provider Relief Fund, such as the Small Business Administration’s Paycheck Protection Program, does that affect how they can use the payments from the Provider Relief Fund? Does accepting Provider Relief Fund payments preclude a provider organization from seeking other funds authorized under the CARES Act? (Added 5/29/2020) › There is no direct ban under the CARES Act on accepting a payment from the Provider Relief Fund & other sources, so long as the payment from the Provider Relief Fund is used only for permissible purposes & the recipient complies with the Terms & Conditions. By attesting to the Terms & Conditions, the recipient certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. The information contained in these slides is presented by professionals for your information only & is not to be considered as accounting advice. Applying specific information to your situation requires careful consideration of facts & circumstances. bkd.com/hc Consult your BKD advisor or legal counsel before acting on any matters covered. HHS FAQ Answers Impacted by HHS Post-Payment Notice of Reporting Requirements › Is there a set period of time in which providers must use the funds to cover allowable expense or lost revenues attributable to COVID-19? (Modified 7/30/2020) › As explained in the notice of reporting requirements on the Provider Relief Fund website, reports on the use of Provider Relief Fund money must be submitted no later than July 31, 2021, & accordingly HHS expects that providers will fully expend their payments by that date. HHS will provide directions in the future about how to return unused funds. HHS reserves the right to audit Provider Relief Fund recipients in the future & collect any Relief Fund amounts that were used inappropriately. All payment recipients must attest to the Terms & Conditions, which require the submission of documentation to substantiate that these funds were used for increased healthcare-related expenses or lost revenue attributable to coronavirus. The information contained in these slides is presented by professionals for your information only & is not to be considered as accounting advice. Applying specific information to your situation requires careful consideration of facts & circumstances. bkd.com/hc Consult your BKD advisor or legal counsel before acting on any matters covered. 5
10/6/2020 HHS FAQ Answers Impacted by HHS Post-Payment Notice of Reporting Requirements › The Terms & Conditions state that Provider Relief Fund payments will only be used to prevent, prepare for, & respond to coronavirus & shall reimburse the Recipient only for healthcare-related expenses or lost revenues that are attributable to coronavirus. What expenses or lost revenues are considered eligible for reimbursement? (Modified 6/19/2020) › The term “healthcare-related expenses attributable to coronavirus” is a broad term that may cover a range of items & services purchased to prevent, prepare for, & respond to coronavirus. The information contained in these slides is presented by professionals for your information only & is not to be considered as accounting advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered. bkd.com/hc HHS FAQ Answers Impacted by HHS Post-Payment Notice of Reporting Requirements › The term “lost revenues that are attributable to coronavirus” means any revenue that you as a healthcare provider lost due to coronavirus. This may include revenue losses associated with fewer outpatient visits, canceled elective procedures or services, or increased uncompensated care. Providers can use Provider Relief Fund payments to cover any cost that the lost revenue otherwise would have covered, so long as that cost prevents, prepares for, or responds to coronavirus. Thus, these costs do not need to be specific to providing care for possible or actual coronavirus patients, but the lost revenue that the Provider Relief Fund payment covers must have been lost due to coronavirus. HHS encourages the use of funds to cover lost revenue so that providers can respond to the coronavirus public health emergency by maintaining healthcare delivery capacity. The information contained in these slides is presented by professionals for your information only & is not to be considered as accounting advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered. bkd.com/hc 6
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