The U.S. Department of Health & Human Services (HHS) released new reporting requirements and guidance for the billions of dollars distributed to health care providers battling the pandemic. Hospice providers and advocates are calling for clarification around allowable expenses as the first reporting deadline looms in the horizon. Wading through these murky waters will take careful revenue reporting from providers as updates continue to evolve.
Intended to alleviate financial pressures brought on by the weight of the COVID-19, the CARES Act was enacted on March 27 and earmarked $175 billion to health care providers through the Provider Relief Fund. Since then, several rounds of funding have been distributed to more than 70,000 health care providers across the United States, with the portion of funds allocated to hospices remaining unclear as COVID-19 pummels organizations’ operations and finances.
Hospice providers have worked to untangle the guidelines while continuing to adapt their revenue cycle management processes.
“Many people are looking at the funds they got and how they want to use that,” said Meg Pekarske during a Husch Blackwell LLP podcast. Pekarke is a health care and hospice law attorney at the hospice law firm and chair of its hospice and palliative care practice group. “The expense side has been a little bit easier for people to think about, but the lost revenue has been the thing that’s been moving around most and I think very challenging for people to understand.”
HHS released guidance for allocating Provider Relief Funds in the fall, but the list of reimbursable expenses fell short, with many in the hospice space and beyond calling for clarification.
Updated reporting requirements were released Jan. 15 intended to inform recipients of the data elements that they will be required to report as part of the post-payment reporting process, according to the notice. Yet, Hospices are still working to unwrap Provider Relief Fund rules as more updates roll out, including grey areas around when reports will be due.
Recipients of PRF payments exceeding $10,000 in aggregate must register in the Provider Relief Fund Reporting Portal. The deadline for completing registration has not yet been announced. Recipients will receive a notification about when they should complete the second step of the reporting requirements governing the use of funds. HRSA will send a broadcast email to the email address provided during the registration process.
Questions abound regarding the ways hospices can allocate these funds.
“One of the things [about] the Provider Relief Fund reporting that has been a source of huge confusion is lots of changes in what the requirements are for reporting,” said Judi Lund Person, vice president of regulatory and compliance for the National Hospice & Palliative Care Organization (NHPCO). “That deadline has been adjusted, we don’t really yet have a deadline for when the reports are going to be required to be submitted.”
Along with an unclear deadline, defining the parameters around pandemic-related lost revenue is a “very weedy thing” for hospice providers to navigate, according to Person, who is leading a forthcoming webinar.
Fundraising and philanthropy are often a primary source of financing for programs such as complementary therapies, hospice houses, programs for those experiencing homelessness and palliative care services. Reduced fundraising dollars brought on by the pandemic has led to a considerable drop in revenue.
HHS indicated that lost fundraising income was applicable in a letter to NHPCO. The industry group had requested the clarification from the agency on behalf of its members. According to Person, HHS provided feedback late December indicating that lost fundraising revenue could be included in Provider Relief Fund reporting.
Definitions of lost revenue during will vary from hospice to hospice, which could cause some confusion. Providers can check in on HHS’s frequently asked questions site for continued updates on riding out pandemic-related revenue storms.
“I don’t know that the priority really matters so much in terms of how much of your total payment you’re going to be able to use, but for purposes of your reporting, HHS does say that first you calculate your increased expenses, and then, assuming you still have some leftover relief fund payment, then you can apply any lost revenue that you may have,” said Andrew Brenton, associate attorney at Husch Blackwell, during the podcast.