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1
PROVIDER RELIEF FUND
REPORTING PERIOD 2 AND
PHASE 4/ARP PAYMENT UPDATES
into
Future.
Reimagined.
2
Agenda
• Review of Provider Relief Fund
• Reporting Components & Process
• Phase 4 and ARP Rural Payment Review
• Audit Considerations
3
What is the Provider Relief Fund?
The Provider Relief Fund, sometimes referred to as the HHS Stimulus, was created through the
CARES Act to provide much-needed financial assistance to healthcare providers in order to support them
in responding to the COVID-19 public health emergency.
Provider Relief Fund payments were to be used to help providers prevent, prepare for, or respond to
coronavirus. The payments were intended to reimburse providers for healthcare-related expenses and
lost revenue attributable to coronavirus.
Since these funds were distributed, guidance on the use of these funds has been extremely fluid and
often ambiguous.
4
Where We’ve Been
April 2020 Summer 2020 Fall 2020 Winter 2021
Spring/Summer
2021
September 2021 Fall/Winter 2022
PRF
Distributions
Initial PRF
payments are
distributed,
based on 2019
Medicare
activity.
Additional PRF
General
Distribution
payments are
made, as well as
first Targeted
Distributions.
Eligibility for PRF
General
Distributions
broadens and
applications are
accepted for
additional
General
Distribution
payments.
Payments for
Phase 3 of
General
Distribution are
made, with many
providers
receiving
sizeable
payments.
Approximately
$24B remains in
the fund, with
pressure on HHS
to announce
additional
distributions.
First reporting
deadline passes
for fund
distributed from
April 10, 2020
through June 30,
2020.
Deadline for
Phase 4 of the
General
Distribution and
ARP Rural
distribution
passes; HHS
begins
distribution
funds.
Guidance
Changes &
Updates
Terms &
Conditions
released shortly
after initial PRF
payments, but
very little
additional
guidance is
provided on use
of funds.
FAQs begin to be
released,
clarifying some
issues while
raising other
questions. No
clear reporting
guidance is
released.
Initial reporting
guidance is
issued in
September with
major changes
that are then
reversed through
new guidance
issued in
October.
Initial reporting
deadline of
February 15,
2021 is delayed
indefinitely.
Additional
methodologies
for calculating
lost revenue are
announced.
On June 11, HHS
issues updated
reporting
guidance as well
as new FAQs.
New timelines
for using funds
and reporting
are established.
While the
deadline to
report on these
funds was
September 30,
2021, HHS
provided a 60-
day grace period.
The Phase 4
distribution, like
Phase 3,
contemplated
losses incurred
by providers,
however, the
distribution
methodology is
complex.
The guidance surrounding the use and reporting on these funds has been highly variable and vague, creating headaches
for providers as they look to deploy these funds to offset the strain created by the pandemic.
5
Reporting Components & Process
6
Reporting Timeline
The Department of Health and Human Services (“HHS”) has established staggered reporting periods based on when
providers received their funds. For funds received after June 30, 2020, and by December 31, 2020, the deadline to use
the funds is December 31, 2021, and the deadline to report on the funds is March 31, 2022.
Key Considerations
• Providers will use their normal basis of
accounting for determining fund use
(incremental expenses or lost revenues
due to coronavirus).
• For providers who received payments in
multiple periods: As shown in the
highlighted column, the periods of
availability for funds overlap, with all
beginning on January 1, 2020. As such, it
is very important to carefully track fund
uses to ensure no “double counting”
occurs across periods.
Complete
7
Returning and New Reporters
Returning Reporters
• Applies to providers who received PRF payments before June 30, 2020 and reported in Fall 2021
• For these reporters, most of the previously submitted information will be prepopulated.
• These providers will have the opportunity to change the figures they submitted in the fall; however, there is
speculation that such a change may raise flags to HHS.
• Importantly, providers are able to change the lost revenue approach they used in September. Changing the lost
revenue methodology will, however, recalculate revenue losses for the entire period of availability (going back to
January 2020).
• If providers wish to change their lost revenue methodology OR change the revenue figures they submitted in the
fall without changing the methodology, they will need to submit a narrative explanation of up to 1000 characters.
New Reporters
• Applies to providers who did not receive any PRF payments until July 2020
• There are many new provider types who will be reporting this time around (dentists, behavioral health providers,
assisted living facilities, etc.) These providers should bear in mind that some of the data and definitions in
reporting are geared more toward medical care providers (physician practices, hospitals, skilled nursing facilities,
etc.)
• For providers who did not report in September, they will need to provide data for the full period of availability
(going back to January 2020).
8
Targeted Distributions
Reporting Period 2 will include reporting on more Targeted Distributions, which may create additional complexity for
organizations that received those funds. Below, we have listed the Targeted Distributions and some key considerations.
It is critical to remember that the entity to which the Targeted Distribution was made is the entity that must report, even if that entity
transferred the funds to its parent organization. Additionally, expenses/lost revenues assigned to the Targeted Distribution received by the
subsidiary cannot be reported by the parent entity.
Other Targeted Distributions
Nursing Home Infection Control Targeted
Distributions
Other Targeted Distributions
• High Impact Hospitals
• Skilled Nursing Facilities
• Safety Net Hospitals
• Rural Hospitals
• Indian Health Services
These distributions have the same rules
for use as the General Distributions,
meaning they can be used to cover
incremental expenses due to coronavirus
and/or lost revenues due to coronavirus.
In contrast to the other Targeted
Distributions, Nursing Home
Infection Control cannot be used
to cover lost revenues. It can only
be used for expenses associated
with infection control.
Nursing Home Infection Control
Eligible Uses
• Costs associated with COVID-19
testing for staff and residents;
• Reporting COVID-19 test results
to local, state, or federal
governments;
• Hiring staff to provide patient care
or administrative support;
• Infection control mentorship;
• Changes to facilities;
• And providing additional services
to residents
9
Reporting Components
Registration:
At this point, many providers have completed this step. This
will involve entering information such as address and Tax ID.
Subsidiary Questionnaire
For recipient parent organizations that also have subsidiaries
that received PRF General Distribution payments, they will
also provide information on their subsidiaries for which they
will be reporting.
Interest Earned, Single Audit Status, and Other
Assistance Received
Recipients will also provide information on miscellaneous
items such as the amount of interest earned on their PRF
payments as well as other assistance they received.
Expenses due to Coronavirus
Providers will first report on their use of their PRF payments to
cover incremental expenses due to coronavirus.
Unreimbursed Expenses
For providers who fully expend their payments on incremental
expenses due to coronavirus, any additional incremental
expenses due to coronavirus that were not covered by the
PRF or another assistance program.
Lost Revenue
For providers who have not fully expended their payments on
expenses, providers will then report their lost revenues due to
coronavirus
Personnel, Patient, and Facility Metrics
Finally, providers will provide HHS with various metrics related
to their staffing, patient encounters, and facility metrics, as
applicable to their organization.
Fund
Use
Information
Organizational
Information
Operational
Information
Below, we have set forth the major sections of the reporting process, as it is ordered in the reporting portal.
10
Phase 4 & ARP Rural Payment Review
11
Phase 4 & ARP Rural Payment Appeals
Payment Appeal Considerations
HHS began distributing ARP Rural Payments and Phase 4 General Distribution Payments at the end of 2021.
• Similar to Phase 3, HHS has stood up an appeals process for providers who believe the payment they
received is inconsistent with the published distribution methodology.
• The deadline to appeal is May 2, 2022.
• Providers must submit a copy of your payment determination letter from HHS; your DocuSign Envelope ID;
the contact information and Tax ID Number (TIN) included on the original Phase 4/ARP Rural application;
and the reason you believe your Phase 4/ARP Rural payment was calculated incorrectly, tied to the PRF
Phase 4 and ARP Rural Payment Methodology.
• At this point, it is difficult to determine the amount providers “should” have gotten paid under ARP/Phase 4,
because of a lack of information around some of the elements of the distribution methodology.
• Providers must be careful in considering whether or not to appeal, as HHS has indicated if a review of a provider’s
application unearths an overpayment, providers will be required to return the excess amount.
12
Phase 4 & ARP Rural Payment Use
Payment Use Considerations
HHS began distributing ARP Rural Payments and Phase 4 General Distribution Payments at the end of 2021.
• Payments received between July 1, 2021, and December 31, 2021, can be used until December 31, 2022, and
carry a reporting deadline of March 31, 2023.
• Though HHS has not updated its deadlines and reporting periods, it is expected that payments received in January
2022 will be eligible for use until June 30, 2023, with a reporting deadline of September 30, 2023.
• Generally, ARP payments and PRF payments have the same eligible uses – increased healthcare related
expenses and lost revenues due to coronavirus.
• Unlike Phase 4 of the Provider Relief Fund, ARP Rural payment recipients must certify that they will allocate the
ARP Rural payment to the provider(s) associated with the applicable subsidiary or billing TIN. The payment cannot
be transferred to non-rural TINs.
• As the pandemic has evolved, providers may not be incurring the same levels of lost revenue/increased
expenses they once were. As such, providers need to verify that they have sufficient uses to retain the full
amount of these new payments
13
Payment Use Considerations Example
PRF Payments Payment Amounts
2020 PRF Payments $100,000
2021 Phase 4 PRF Payments $200,000
Total PRF Payments $300,000
Eligible Uses Eligible Use Amounts
2020 Eligible Expenses $5,000
2021 Eligible Expenses $2,000
2022 Eligible Expenses $2,000
2020 Lost Revenue $175,000
2021 Lost Revenue $50,000
2022 Lost Revenue $10,000
Total Eligible Uses $244,000
Remaining PRF Balance $56,000
Providers should be sure to revisit their
PRF uses claimed to-date to ensure
that there are sufficient lost revenues or
expenses already incurred to claim the
full amount of the Phase 4 payment. If
there are not, providers should begin
strategizing how they will leverage the
Phase 4/ARP payment before the use
deadline.
In this example, a provider received $100K in 2020 PRF payments and an additional $200K in Phase 4
payments in 2021. This provider will have until December 31, 2022 to use the funds.
14
Audit Considerations
15
Audit Reminders
For providers who expended $750K or more (including lost revenues), program or single audits of the Provider
Relief Funds will begin with entities with fiscal year ends of June 30, 2021 and later.
Audits are due the sooner of 30 days of issuance of the financial statements or 9 months after year end,
whichever is sooner.
Fiscal Year End
Funding to report on Schedule of Expenditures of Federal Awards
(“SEFA”)
June 30, 2021 – December 30, 2021
Period 1: Payments received and utilized for lost revenue and
expenditures from April 10, 2020 – June 30, 2020
December 31, 2021 – June 29, 2022
Period 1 (above) and Period 2: Payments received and utilized for lost
revenue and expenditures from April 10, 2020 – December 31, 2020
June 30, 2022 and after
Reporting requirements will be released with the 2022 Compliance
Supplement
16
Single Audit vs Program Audit
• A 2 Code of Federal Regulations (“CFR”) Part 200 audit is required if your organization expends more than
$750,000 in federal funds during your fiscal year or if the federal contract requires a single audit. Therefore it
is important to review the contract to determine if there is an audit requirement, regardless of how much
federal funding was received.
• A program-specific audit is allowed when the grantee or subrecipient expends federal awards under only
one federal program and when the conditions of the federal award do not require a financial statement audit
of the auditee.
• A single audit is an audit that includes both an entity's financial statements and its federal awards (from all
applicable federal programs) and is required if you have more than one federal program as noted on the
previous slide.
• If a grantee or subrecipient expends less than $750,000 a year in federal awards, it is exempt from the audit
requirements for that year; however, records must be available for review or audit by appropriate officials of
the federal agency, pass-through entity, and the Government Accountability Office.
17
Auditee Responsibilities
1. Procure or otherwise arrange for the audit required in accordance with 2 CFR section
200.509 Auditor selection, and ensure it is properly performed and submitted when due in accordance
with 2 CFR Section 200.512 Report submission.
➢ In requesting proposals for audit services, the objectives and scope of the audit must be made clear, and the non-
Federal entity must request a copy of the audit organization's peer review report, which the auditor is required to
provide under Generally Accepted Government Auditing Standards.
➢ Factors to be considered in evaluating each proposal for audit services include the responsiveness to the request
for proposal, relevant experience, availability of staff with professional qualifications and technical abilities, and the
results of peer and external quality control reviews.
➢ An auditor who prepares the indirect cost proposal or cost allocation plan may not also be selected to perform the
audit required by this part when the indirect costs recovered by the auditee during the prior year exceeds $1 million.
This restriction applies to the base year used in the preparation of the indirect cost proposal or cost allocation plan
and any subsequent years in which the resulting indirect cost agreement or cost allocation plan is used to recover
costs.
18
Auditee Responsibilities (continued)
2. Prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards in
accordance with 2 CFR section 200.510 Financial statements.
3. Promptly follow up and take corrective action on audit findings, including preparation of a summary schedule
of prior audit findings and a corrective action plan in accordance with 2 CFR section 200.511 Audit findings
follow-up, paragraph (b) and section 200.511 Audit findings follow-up, paragraph (c), respectively.
4. Provide the auditor with access to personnel, accounts, books, records, supporting documentation, and other
information as needed for the auditor to perform the audit required by this part.
19
Testing Requirements
Activities Allowed or Unallowed and Allowable costs
• To prevent, prepare for, and respond to coronavirus, domestically or internationally, for necessary expenses to
reimburse, through grants or other mechanisms, eligible healthcare providers for healthcare related expenses or lost
revenues that are attributable to coronavirus.
• Payments may not be used to reimburse expenses or losses that have been reimbursed from other sources or that
other sources are obligated to reimburse.
• Examples include: supplies, equipment, workforce training, reporting test results, building or constructing temporary
structures for COVID patient care, acquiring additional resources such as facilities, supplies, or staff, and developing
emergency operation centers, among others.
Reporting
• Auditors are required to test the reporting that was completed in HHS PRF Reporting Portal for all periods covered
under the SEFA. For 12/31/21 year ends, this will cover Period 1 and Period 2 reporting.
Special Tests and Provisions
• Under the terms and conditions of the award, the recipient certifies that it will not seek to collect from the patient out-
of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care
had been provided by an in-network provider, for patients with presumptive or actual case of COVID-19 from January
31, 2020, through the end of the Public Health Emergency (Balance Billing Testing)
COVID -19 UPDATE
FOR MORE INFORMATION
Kate Broderick, MBA, MSIS
Director
kbroderick@citrincooperman.com
419.367.6334
Amber Bichun
Audit Director
abichun@citrincooperman.com
401.421.4800
21
Appendices
22
Component Details | Organizational Information
Reporting Sections Information Requirements Considerations
Registration
Contact information, Tax ID Many providers have already completed this step, as
registration opened in January 2021.
Subsidiary Questionnaire
For organizations who will be reporting on behalf of their
subsidiaries for General Distribution payments, Tax ID of
subsidiaries
If you have a subsidiary that received a Targeted
Distribution, such as High Impact Hospitals, the subsidiary
itself will need to report on the use of that Targeted
Distribution.
Interest Earn on PRF Payments
If PRF payment(s) were held in an interest-bearing account,
amount of interest earned on the PRF payment from the date of
receipt to the date of expenditure
If the payment was held in a non-interest-bearing account,
no interest needs to be reported. The amount of interest
must be used on eligible uses (expenses & lost revenue) or
returned to HHS.
Federal Tax Information
Federal tax classification (e.g., C Corporation, S Corporation,
LLC) and fiscal year end date (e.g., December 31)
This information should mirror what is reported on your tax
return, if applicable.
Single Audit Status
For organizations that expended (including lost revenue) more
than $750K in federal funds during the fiscal year: indication of
whether PRF payments were included in the organization’s
single audit
If your organization received federal funds from other
programs (excluding PPP loans), including federal funds
that passed through state programs, you may be subject to
single audit requirements, even if your PRF payment was
less than $750K.
Other Assistance Received
Reported Quarterly for the full period of availability; amount of
assistance, by quarter, received from other sources, such as
PPP loans, business insurance, or state/local funding
While guidance around this issue has changed since the
creation of the PRF, HHS has confirmed that funds reported
here are not used in subsequent calculations in the portal,
such as lost revenue calculations.
23
Component Details | Fund Use Information
Reporting Sections Information Requirements Considerations
Expenses due to
Coronavirus
Reported Quarterly for the full period of
availability; marginal increased expenses related
to coronavirus provided those expenses have not
been reimbursed from other sources or that other
sources are not obligated to reimburse.
Depending on the amount of funding received, the
level of granularity required in expense reporting
differs. See Appendix A for detail on expense
categories.
While providers do not need to submit substantiating
documentation related to expenses, HHS is able to audit
any recipient for up to 3 years and the burden of proof is
on the provider to ensure that documentation is
maintained to show that expenses are to prevent,
prepare for, and respond to coronavirus. As such, while
substantiating documentation does not need to be
submitted, it needs to be maintained by the organization.
Unreimbursed Expenses
Reported Quarterly for the full period of
availability; if recipients claim the full amount of
their PRF payment through expenses due to
coronavirus, the amount of any additional
expenses due to coronavirus that were not
reimbursed by another program will report those
expense amounts here.
From our understanding of HHS’ guidance, providers
who have PRF payments remaining after submitting
their expenses due to coronavirus should enter $0 here.
Lost Revenue
Reported Quarterly for the full period of
availability; lost patient care revenues attributable
to coronavirus are eligible to be reimbursed by the
Provider Relief Fund. There are three
methodologies for calculating lost revenue; see
Appendix B for details on lost revenue
calculations
While HHS does allow for three different methodologies
for calculating lost revenue, we recommend choosing
the simplest option that allows you to claim the funds
and properly characterize the economic injury caused by
coronavirus.
24
Component Details | Operational Information
Reporting Sections Information Requirements Considerations
Personnel Metrics
Reported Quarterly for the full period of
availability; personnel metrics, divided by clinical
and non-clinical for the following categories: full-
time, part-time, contractor, furloughed, separated,
and hired. For additional detail, see Appendix C.
Not every metric will apply to every organization; if it
does not apply to you, you must enter “0”
Patient Metrics
Reported Quarterly for the full period of
availability; patient volume metrics, by category:
inpatient admissions, outpatient visits, emergency
department visits, and facility stays. For additional
detail, see Appendix D.
Not every metric will apply to every organization; if it
does not apply to you, you must enter “0”
Facility Metrics
If your organization supports staffed beds:
Reported Quarterly for the full period of
availability; Medical/Surgical Beds, Critical Care
Beds, Other Beds. For additional detail, see
Appendix E.
This question only appears if you indicate affirmatively
that your organization supports staffed beds.
25
Appendix A | Expense Categories
General & Administrative Expenses
a. Mortgage/Rent: Payments related to mortgage or rent for a facility.
b. Insurance: Premiums paid for property, malpractice, business insurance, or other insurance relevant to operations.
c. Personnel: Workforce-related actual expenses paid to prevent, prepare for, or respond to coronavirus during the
reporting period, such as workforce training, staffing, temporary employee or contractor payroll, overhead employees,
or security personnel.
d. Fringe Benefits: Extra benefits supplementing an employee’s salary, which may include hazard pay, travel
reimbursement, and employee health insurance.
e. Lease Payments: New equipment or software leases, such as fleet cars and medical equipment that is not purchased
and will be returned to the owner.
f. Utilities/Operations: Lighting, cooling/ventilation, cleaning, or additional third-party vendor services not included in the
“Personnel” sub-category.
g. Other General and Administrative Expenses: Expenses not captured above that are generally considered part of
general and administrative expenses.
Healthcare Expenses
a. Supplies: Expenses paid for purchase of supplies (e.g., single use or reusable patient care devices, cleaning supplies,
office supplies, etc.) used to prevent, prepare for, and/or respond to coronavirus during the reporting period. Such
items may include PPE, hand sanitizer, supplies for patient screening, or vaccination administration materials.
b. Equipment: Expenses paid for purchase of equipment, such as ventilators, refrigeration systems for COVID-19
vaccines, or updates to HVAC systems.
c. Information Technology (IT): Expenses paid for IT or interoperability systems to expand or preserve coronavirus
care delivery during the reporting period, such as electronic health record licensing fees, telehealth infrastructure,
increased bandwidth, and teleworking to support remote workforce.
d. Facilities: Expenses such as lease or purchase of permanent or temporary structures, or to retrofit facilities to
accommodate revised patient treatment practices, used to prevent, prepare for, and/or respond to coronavirus during
the reporting period.
e. Other Healthcare-Related Expenses: Expenses, not previously captured above, that were paid to prevent, prepare
for, and/or respond to coronavirus.
Reminders
• Providers who received under
$500K will report in two broad
categories: General &
Administrative and Healthcare
Expenses; providers who
received over $500K will need
to report according to the
more detailed categories.
• These expenses MUST be
incremental to coronavirus.
For example, normal rent
expense that would have been
incurred had the pandemic
never occurred is not eligible.
26
Appendix B | Lost Revenue Calculation
Lost Revenue Calculation
Methodology Option
Overview Details Example
Option I: Actual-to-Actual
Comparison
Comparison actual patient care revenue for
each quarter in 2020 and the first two quarters
of 2021 to the corresponding quarter in 2019.
Must be reported by payor class (Medicare
A&B, Medicare C, Commercial, etc.)
Patient care revenue for Q1-Q4 2020 and Q1-Q2 2021
will be compared to the corresponding quarter in 2019.
For quarters where revenue increased versus 2019, lost
revenue for that quarter will be $0; it will not offset losses
in other quarters.
Relative to 2019, a practice loses $100K
in each quarter for Q1, Q2, and Q3
2020. In Q4 2020, revenue increased by
$50K relative to 2019. The $50K
increase in Q4 does not offset losses in
Q1-Q3; total losses for the year are still
$300K.
Option II: Actual-to-Budget
Comparison
Comparison of actual patient revenue for
each quarter in 2020 and the first two quarters
of 2021 to the budgeted revenue for that
quarter.
Must be reported by payor class.
Patient care revenue for Q1-Q4 2020 and Q1-Q2 2021
will be compared to the budget for that quarter. To use
this method, the budget for the entire period (through
June 30, 2021) must have been established and
approved by March 27, 2020. Recipients using this
method will need to provide their budget document and
certify that it meets the timing requirements.
Relative to budget, a practice loses
$100K in each quarter for Q1, Q2, and
Q3 2020. In Q4 2020, revenue increased
by $50K relative to budget. The $50K
increase in Q4 does not offset losses in
Q1-Q3; total losses for the year are still
$300K.
Option III: Any other
reasonable methodology
Providers may calculate lost revenue through
any other reasonable methodology. HHS will
review methodologies and alert providers if it
deems the methodology unreasonable and
the provider will have 30 days to resubmit its
report using Option I or Option II.
Recipients must provide a narrative document describing
the methodology, an explanation of why the methodology
is reasonable, and a description establishing how lost
revenues were attributable to coronavirus, as opposed to
a loss caused by any other source. They must also
provide a calculation of lost revenues attributable to
coronavirus using the methodology described in the
narrative document.
This methodology offers providers
maximum flexibility, however, it carries
an explicitly higher risk of audit by HHS,
so providers using this method should
ensure that their methodology is sound,
measures baseline revenue and lost
revenue consistently, and does not
double count losses.
27
Appendix C | Personnel Metrics
• Clinical: Total number of clinical personnel providing direct patient care by labor category (full-time, part-time, contract, furloughed,
separated, hired). Clinical staff provides direct patient care and may provide direct diagnosis, treatment, or care for the patient.
Clinical roles often require certifications or licensure. Clinical personnel may include physicians, hospitalists, physician assistants,
nurse practitioners, registered nurses, nursing assistants, patient care technicians, social workers, and therapists. Personnel must be
categorized as clinical if 50% or more of their time is spent delivering direct patient care.
• Non-Clinical: Total number of non-clinical personnel by labor category (full-time, part-time, contract, furloughed, separated, hired).
Personnel must be categorized as nonclinical if less than 50% of their time is spent delivering direct patient care. Non-clinical
personnel may support patient care. Non-clinical personnel may include medical billers and coders, transcriptionists, hospital
executives, and receptionists.
• All clinical and non-clinical personnel employed at any point and in any capacity during a calendar year quarter by the Reporting
Entity (or its subsidiaries included in the report) must be categorized into one of the following labor categories. The labor categories
are mutually exclusive, and each employee should only be included in one labor category per quarter. If a hiring action (e.g.,
furloughed, separated, hired) occurred during the quarter, personnel should be considered non-clinical if less than 50% of their time
does not involve direct patient care. The employee should be identified in the category that occurred closest to the end of the quarter.
All full-time, part-time, or contractor personnel should be those who experienced no hiring action during the respective quarter.
• Full-time: Number of personnel employed on average 30 hours of service per week, or 130 hours for a calendar month. However,
healthcare practices may have exceptions to this, such as nursing shifts.
• Part-time: Number of personnel employed any time between 1 and 34 hours per week, whom may or may not qualify for benefits.
• Contractor: Number of personnel employed as an individual or under organizational contracts and do not receive direct benefits or
compensation from the employer/provider.
• Furloughed: Number of personnel on temporary, involuntary, or unpaid leave of absence.
• Separated: Number of personnel who 1) voluntarily submit a written or verbal notice of resignation or 2) the employer/provider
decided to terminate its relationship with the employee(s) (including lay-offs and expired contracts).
• Hired: Number of personnel 1) not previously employed by the employer or 2) that left an employer due to voluntary or involuntary
separation and are brought back to work by employer.
28
Appendix D | Patient Metrics
• Inpatient Admissions: Number of hospital admissions on a clinician’s order (i.e., direct admit) or formally admitted from the
emergency department to the hospital (i.e., emergency admission).
• Outpatient Visits (in-person and virtual): Number of in-person or virtual patient encounters with a clinician in an office-based,
clinic, or hospital outpatient department setting that do not require an inpatient admission.
• Emergency Visits: Number of emergency department encounters for care or treatment. This may include patients on
observation status who are cared for no longer than 72 hours and not formally admitted to a hospital.
• Facility Stays (for Long- and Short-term Residential Facilities): Number of stays (defined as unique admissions) for patients
residing in a long-term or short-term care or treatment facility.
29
Appendix E | Facility Metrics
• Medical/Surgical Beds: Number of general medical/surgical beds, which are the beds used for routine care or “ward”
beds.
• Critical Care Beds: Number of beds in intensive care units (ICUs), critical care units (CCUs) or intensive therapy units
(ITUs).
• Other Beds: Number of any other type of staffed bed that the facility has physically available and licensed to operate.
Reminder
Only recipients who answer affirmatively to the question: “Does the Reporting Entity or its
subsidiaries operate or support staffed beds?” will be required to complete this section

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How About Provider Relief Funds: Deadlines, Reporting, and Auditing Nuances

  • 1. 1 PROVIDER RELIEF FUND REPORTING PERIOD 2 AND PHASE 4/ARP PAYMENT UPDATES into Future. Reimagined.
  • 2. 2 Agenda • Review of Provider Relief Fund • Reporting Components & Process • Phase 4 and ARP Rural Payment Review • Audit Considerations
  • 3. 3 What is the Provider Relief Fund? The Provider Relief Fund, sometimes referred to as the HHS Stimulus, was created through the CARES Act to provide much-needed financial assistance to healthcare providers in order to support them in responding to the COVID-19 public health emergency. Provider Relief Fund payments were to be used to help providers prevent, prepare for, or respond to coronavirus. The payments were intended to reimburse providers for healthcare-related expenses and lost revenue attributable to coronavirus. Since these funds were distributed, guidance on the use of these funds has been extremely fluid and often ambiguous.
  • 4. 4 Where We’ve Been April 2020 Summer 2020 Fall 2020 Winter 2021 Spring/Summer 2021 September 2021 Fall/Winter 2022 PRF Distributions Initial PRF payments are distributed, based on 2019 Medicare activity. Additional PRF General Distribution payments are made, as well as first Targeted Distributions. Eligibility for PRF General Distributions broadens and applications are accepted for additional General Distribution payments. Payments for Phase 3 of General Distribution are made, with many providers receiving sizeable payments. Approximately $24B remains in the fund, with pressure on HHS to announce additional distributions. First reporting deadline passes for fund distributed from April 10, 2020 through June 30, 2020. Deadline for Phase 4 of the General Distribution and ARP Rural distribution passes; HHS begins distribution funds. Guidance Changes & Updates Terms & Conditions released shortly after initial PRF payments, but very little additional guidance is provided on use of funds. FAQs begin to be released, clarifying some issues while raising other questions. No clear reporting guidance is released. Initial reporting guidance is issued in September with major changes that are then reversed through new guidance issued in October. Initial reporting deadline of February 15, 2021 is delayed indefinitely. Additional methodologies for calculating lost revenue are announced. On June 11, HHS issues updated reporting guidance as well as new FAQs. New timelines for using funds and reporting are established. While the deadline to report on these funds was September 30, 2021, HHS provided a 60- day grace period. The Phase 4 distribution, like Phase 3, contemplated losses incurred by providers, however, the distribution methodology is complex. The guidance surrounding the use and reporting on these funds has been highly variable and vague, creating headaches for providers as they look to deploy these funds to offset the strain created by the pandemic.
  • 6. 6 Reporting Timeline The Department of Health and Human Services (“HHS”) has established staggered reporting periods based on when providers received their funds. For funds received after June 30, 2020, and by December 31, 2020, the deadline to use the funds is December 31, 2021, and the deadline to report on the funds is March 31, 2022. Key Considerations • Providers will use their normal basis of accounting for determining fund use (incremental expenses or lost revenues due to coronavirus). • For providers who received payments in multiple periods: As shown in the highlighted column, the periods of availability for funds overlap, with all beginning on January 1, 2020. As such, it is very important to carefully track fund uses to ensure no “double counting” occurs across periods. Complete
  • 7. 7 Returning and New Reporters Returning Reporters • Applies to providers who received PRF payments before June 30, 2020 and reported in Fall 2021 • For these reporters, most of the previously submitted information will be prepopulated. • These providers will have the opportunity to change the figures they submitted in the fall; however, there is speculation that such a change may raise flags to HHS. • Importantly, providers are able to change the lost revenue approach they used in September. Changing the lost revenue methodology will, however, recalculate revenue losses for the entire period of availability (going back to January 2020). • If providers wish to change their lost revenue methodology OR change the revenue figures they submitted in the fall without changing the methodology, they will need to submit a narrative explanation of up to 1000 characters. New Reporters • Applies to providers who did not receive any PRF payments until July 2020 • There are many new provider types who will be reporting this time around (dentists, behavioral health providers, assisted living facilities, etc.) These providers should bear in mind that some of the data and definitions in reporting are geared more toward medical care providers (physician practices, hospitals, skilled nursing facilities, etc.) • For providers who did not report in September, they will need to provide data for the full period of availability (going back to January 2020).
  • 8. 8 Targeted Distributions Reporting Period 2 will include reporting on more Targeted Distributions, which may create additional complexity for organizations that received those funds. Below, we have listed the Targeted Distributions and some key considerations. It is critical to remember that the entity to which the Targeted Distribution was made is the entity that must report, even if that entity transferred the funds to its parent organization. Additionally, expenses/lost revenues assigned to the Targeted Distribution received by the subsidiary cannot be reported by the parent entity. Other Targeted Distributions Nursing Home Infection Control Targeted Distributions Other Targeted Distributions • High Impact Hospitals • Skilled Nursing Facilities • Safety Net Hospitals • Rural Hospitals • Indian Health Services These distributions have the same rules for use as the General Distributions, meaning they can be used to cover incremental expenses due to coronavirus and/or lost revenues due to coronavirus. In contrast to the other Targeted Distributions, Nursing Home Infection Control cannot be used to cover lost revenues. It can only be used for expenses associated with infection control. Nursing Home Infection Control Eligible Uses • Costs associated with COVID-19 testing for staff and residents; • Reporting COVID-19 test results to local, state, or federal governments; • Hiring staff to provide patient care or administrative support; • Infection control mentorship; • Changes to facilities; • And providing additional services to residents
  • 9. 9 Reporting Components Registration: At this point, many providers have completed this step. This will involve entering information such as address and Tax ID. Subsidiary Questionnaire For recipient parent organizations that also have subsidiaries that received PRF General Distribution payments, they will also provide information on their subsidiaries for which they will be reporting. Interest Earned, Single Audit Status, and Other Assistance Received Recipients will also provide information on miscellaneous items such as the amount of interest earned on their PRF payments as well as other assistance they received. Expenses due to Coronavirus Providers will first report on their use of their PRF payments to cover incremental expenses due to coronavirus. Unreimbursed Expenses For providers who fully expend their payments on incremental expenses due to coronavirus, any additional incremental expenses due to coronavirus that were not covered by the PRF or another assistance program. Lost Revenue For providers who have not fully expended their payments on expenses, providers will then report their lost revenues due to coronavirus Personnel, Patient, and Facility Metrics Finally, providers will provide HHS with various metrics related to their staffing, patient encounters, and facility metrics, as applicable to their organization. Fund Use Information Organizational Information Operational Information Below, we have set forth the major sections of the reporting process, as it is ordered in the reporting portal.
  • 10. 10 Phase 4 & ARP Rural Payment Review
  • 11. 11 Phase 4 & ARP Rural Payment Appeals Payment Appeal Considerations HHS began distributing ARP Rural Payments and Phase 4 General Distribution Payments at the end of 2021. • Similar to Phase 3, HHS has stood up an appeals process for providers who believe the payment they received is inconsistent with the published distribution methodology. • The deadline to appeal is May 2, 2022. • Providers must submit a copy of your payment determination letter from HHS; your DocuSign Envelope ID; the contact information and Tax ID Number (TIN) included on the original Phase 4/ARP Rural application; and the reason you believe your Phase 4/ARP Rural payment was calculated incorrectly, tied to the PRF Phase 4 and ARP Rural Payment Methodology. • At this point, it is difficult to determine the amount providers “should” have gotten paid under ARP/Phase 4, because of a lack of information around some of the elements of the distribution methodology. • Providers must be careful in considering whether or not to appeal, as HHS has indicated if a review of a provider’s application unearths an overpayment, providers will be required to return the excess amount.
  • 12. 12 Phase 4 & ARP Rural Payment Use Payment Use Considerations HHS began distributing ARP Rural Payments and Phase 4 General Distribution Payments at the end of 2021. • Payments received between July 1, 2021, and December 31, 2021, can be used until December 31, 2022, and carry a reporting deadline of March 31, 2023. • Though HHS has not updated its deadlines and reporting periods, it is expected that payments received in January 2022 will be eligible for use until June 30, 2023, with a reporting deadline of September 30, 2023. • Generally, ARP payments and PRF payments have the same eligible uses – increased healthcare related expenses and lost revenues due to coronavirus. • Unlike Phase 4 of the Provider Relief Fund, ARP Rural payment recipients must certify that they will allocate the ARP Rural payment to the provider(s) associated with the applicable subsidiary or billing TIN. The payment cannot be transferred to non-rural TINs. • As the pandemic has evolved, providers may not be incurring the same levels of lost revenue/increased expenses they once were. As such, providers need to verify that they have sufficient uses to retain the full amount of these new payments
  • 13. 13 Payment Use Considerations Example PRF Payments Payment Amounts 2020 PRF Payments $100,000 2021 Phase 4 PRF Payments $200,000 Total PRF Payments $300,000 Eligible Uses Eligible Use Amounts 2020 Eligible Expenses $5,000 2021 Eligible Expenses $2,000 2022 Eligible Expenses $2,000 2020 Lost Revenue $175,000 2021 Lost Revenue $50,000 2022 Lost Revenue $10,000 Total Eligible Uses $244,000 Remaining PRF Balance $56,000 Providers should be sure to revisit their PRF uses claimed to-date to ensure that there are sufficient lost revenues or expenses already incurred to claim the full amount of the Phase 4 payment. If there are not, providers should begin strategizing how they will leverage the Phase 4/ARP payment before the use deadline. In this example, a provider received $100K in 2020 PRF payments and an additional $200K in Phase 4 payments in 2021. This provider will have until December 31, 2022 to use the funds.
  • 15. 15 Audit Reminders For providers who expended $750K or more (including lost revenues), program or single audits of the Provider Relief Funds will begin with entities with fiscal year ends of June 30, 2021 and later. Audits are due the sooner of 30 days of issuance of the financial statements or 9 months after year end, whichever is sooner. Fiscal Year End Funding to report on Schedule of Expenditures of Federal Awards (“SEFA”) June 30, 2021 – December 30, 2021 Period 1: Payments received and utilized for lost revenue and expenditures from April 10, 2020 – June 30, 2020 December 31, 2021 – June 29, 2022 Period 1 (above) and Period 2: Payments received and utilized for lost revenue and expenditures from April 10, 2020 – December 31, 2020 June 30, 2022 and after Reporting requirements will be released with the 2022 Compliance Supplement
  • 16. 16 Single Audit vs Program Audit • A 2 Code of Federal Regulations (“CFR”) Part 200 audit is required if your organization expends more than $750,000 in federal funds during your fiscal year or if the federal contract requires a single audit. Therefore it is important to review the contract to determine if there is an audit requirement, regardless of how much federal funding was received. • A program-specific audit is allowed when the grantee or subrecipient expends federal awards under only one federal program and when the conditions of the federal award do not require a financial statement audit of the auditee. • A single audit is an audit that includes both an entity's financial statements and its federal awards (from all applicable federal programs) and is required if you have more than one federal program as noted on the previous slide. • If a grantee or subrecipient expends less than $750,000 a year in federal awards, it is exempt from the audit requirements for that year; however, records must be available for review or audit by appropriate officials of the federal agency, pass-through entity, and the Government Accountability Office.
  • 17. 17 Auditee Responsibilities 1. Procure or otherwise arrange for the audit required in accordance with 2 CFR section 200.509 Auditor selection, and ensure it is properly performed and submitted when due in accordance with 2 CFR Section 200.512 Report submission. ➢ In requesting proposals for audit services, the objectives and scope of the audit must be made clear, and the non- Federal entity must request a copy of the audit organization's peer review report, which the auditor is required to provide under Generally Accepted Government Auditing Standards. ➢ Factors to be considered in evaluating each proposal for audit services include the responsiveness to the request for proposal, relevant experience, availability of staff with professional qualifications and technical abilities, and the results of peer and external quality control reviews. ➢ An auditor who prepares the indirect cost proposal or cost allocation plan may not also be selected to perform the audit required by this part when the indirect costs recovered by the auditee during the prior year exceeds $1 million. This restriction applies to the base year used in the preparation of the indirect cost proposal or cost allocation plan and any subsequent years in which the resulting indirect cost agreement or cost allocation plan is used to recover costs.
  • 18. 18 Auditee Responsibilities (continued) 2. Prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards in accordance with 2 CFR section 200.510 Financial statements. 3. Promptly follow up and take corrective action on audit findings, including preparation of a summary schedule of prior audit findings and a corrective action plan in accordance with 2 CFR section 200.511 Audit findings follow-up, paragraph (b) and section 200.511 Audit findings follow-up, paragraph (c), respectively. 4. Provide the auditor with access to personnel, accounts, books, records, supporting documentation, and other information as needed for the auditor to perform the audit required by this part.
  • 19. 19 Testing Requirements Activities Allowed or Unallowed and Allowable costs • To prevent, prepare for, and respond to coronavirus, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible healthcare providers for healthcare related expenses or lost revenues that are attributable to coronavirus. • Payments may not be used to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. • Examples include: supplies, equipment, workforce training, reporting test results, building or constructing temporary structures for COVID patient care, acquiring additional resources such as facilities, supplies, or staff, and developing emergency operation centers, among others. Reporting • Auditors are required to test the reporting that was completed in HHS PRF Reporting Portal for all periods covered under the SEFA. For 12/31/21 year ends, this will cover Period 1 and Period 2 reporting. Special Tests and Provisions • Under the terms and conditions of the award, the recipient certifies that it will not seek to collect from the patient out- of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider, for patients with presumptive or actual case of COVID-19 from January 31, 2020, through the end of the Public Health Emergency (Balance Billing Testing)
  • 20. COVID -19 UPDATE FOR MORE INFORMATION Kate Broderick, MBA, MSIS Director kbroderick@citrincooperman.com 419.367.6334 Amber Bichun Audit Director abichun@citrincooperman.com 401.421.4800
  • 22. 22 Component Details | Organizational Information Reporting Sections Information Requirements Considerations Registration Contact information, Tax ID Many providers have already completed this step, as registration opened in January 2021. Subsidiary Questionnaire For organizations who will be reporting on behalf of their subsidiaries for General Distribution payments, Tax ID of subsidiaries If you have a subsidiary that received a Targeted Distribution, such as High Impact Hospitals, the subsidiary itself will need to report on the use of that Targeted Distribution. Interest Earn on PRF Payments If PRF payment(s) were held in an interest-bearing account, amount of interest earned on the PRF payment from the date of receipt to the date of expenditure If the payment was held in a non-interest-bearing account, no interest needs to be reported. The amount of interest must be used on eligible uses (expenses & lost revenue) or returned to HHS. Federal Tax Information Federal tax classification (e.g., C Corporation, S Corporation, LLC) and fiscal year end date (e.g., December 31) This information should mirror what is reported on your tax return, if applicable. Single Audit Status For organizations that expended (including lost revenue) more than $750K in federal funds during the fiscal year: indication of whether PRF payments were included in the organization’s single audit If your organization received federal funds from other programs (excluding PPP loans), including federal funds that passed through state programs, you may be subject to single audit requirements, even if your PRF payment was less than $750K. Other Assistance Received Reported Quarterly for the full period of availability; amount of assistance, by quarter, received from other sources, such as PPP loans, business insurance, or state/local funding While guidance around this issue has changed since the creation of the PRF, HHS has confirmed that funds reported here are not used in subsequent calculations in the portal, such as lost revenue calculations.
  • 23. 23 Component Details | Fund Use Information Reporting Sections Information Requirements Considerations Expenses due to Coronavirus Reported Quarterly for the full period of availability; marginal increased expenses related to coronavirus provided those expenses have not been reimbursed from other sources or that other sources are not obligated to reimburse. Depending on the amount of funding received, the level of granularity required in expense reporting differs. See Appendix A for detail on expense categories. While providers do not need to submit substantiating documentation related to expenses, HHS is able to audit any recipient for up to 3 years and the burden of proof is on the provider to ensure that documentation is maintained to show that expenses are to prevent, prepare for, and respond to coronavirus. As such, while substantiating documentation does not need to be submitted, it needs to be maintained by the organization. Unreimbursed Expenses Reported Quarterly for the full period of availability; if recipients claim the full amount of their PRF payment through expenses due to coronavirus, the amount of any additional expenses due to coronavirus that were not reimbursed by another program will report those expense amounts here. From our understanding of HHS’ guidance, providers who have PRF payments remaining after submitting their expenses due to coronavirus should enter $0 here. Lost Revenue Reported Quarterly for the full period of availability; lost patient care revenues attributable to coronavirus are eligible to be reimbursed by the Provider Relief Fund. There are three methodologies for calculating lost revenue; see Appendix B for details on lost revenue calculations While HHS does allow for three different methodologies for calculating lost revenue, we recommend choosing the simplest option that allows you to claim the funds and properly characterize the economic injury caused by coronavirus.
  • 24. 24 Component Details | Operational Information Reporting Sections Information Requirements Considerations Personnel Metrics Reported Quarterly for the full period of availability; personnel metrics, divided by clinical and non-clinical for the following categories: full- time, part-time, contractor, furloughed, separated, and hired. For additional detail, see Appendix C. Not every metric will apply to every organization; if it does not apply to you, you must enter “0” Patient Metrics Reported Quarterly for the full period of availability; patient volume metrics, by category: inpatient admissions, outpatient visits, emergency department visits, and facility stays. For additional detail, see Appendix D. Not every metric will apply to every organization; if it does not apply to you, you must enter “0” Facility Metrics If your organization supports staffed beds: Reported Quarterly for the full period of availability; Medical/Surgical Beds, Critical Care Beds, Other Beds. For additional detail, see Appendix E. This question only appears if you indicate affirmatively that your organization supports staffed beds.
  • 25. 25 Appendix A | Expense Categories General & Administrative Expenses a. Mortgage/Rent: Payments related to mortgage or rent for a facility. b. Insurance: Premiums paid for property, malpractice, business insurance, or other insurance relevant to operations. c. Personnel: Workforce-related actual expenses paid to prevent, prepare for, or respond to coronavirus during the reporting period, such as workforce training, staffing, temporary employee or contractor payroll, overhead employees, or security personnel. d. Fringe Benefits: Extra benefits supplementing an employee’s salary, which may include hazard pay, travel reimbursement, and employee health insurance. e. Lease Payments: New equipment or software leases, such as fleet cars and medical equipment that is not purchased and will be returned to the owner. f. Utilities/Operations: Lighting, cooling/ventilation, cleaning, or additional third-party vendor services not included in the “Personnel” sub-category. g. Other General and Administrative Expenses: Expenses not captured above that are generally considered part of general and administrative expenses. Healthcare Expenses a. Supplies: Expenses paid for purchase of supplies (e.g., single use or reusable patient care devices, cleaning supplies, office supplies, etc.) used to prevent, prepare for, and/or respond to coronavirus during the reporting period. Such items may include PPE, hand sanitizer, supplies for patient screening, or vaccination administration materials. b. Equipment: Expenses paid for purchase of equipment, such as ventilators, refrigeration systems for COVID-19 vaccines, or updates to HVAC systems. c. Information Technology (IT): Expenses paid for IT or interoperability systems to expand or preserve coronavirus care delivery during the reporting period, such as electronic health record licensing fees, telehealth infrastructure, increased bandwidth, and teleworking to support remote workforce. d. Facilities: Expenses such as lease or purchase of permanent or temporary structures, or to retrofit facilities to accommodate revised patient treatment practices, used to prevent, prepare for, and/or respond to coronavirus during the reporting period. e. Other Healthcare-Related Expenses: Expenses, not previously captured above, that were paid to prevent, prepare for, and/or respond to coronavirus. Reminders • Providers who received under $500K will report in two broad categories: General & Administrative and Healthcare Expenses; providers who received over $500K will need to report according to the more detailed categories. • These expenses MUST be incremental to coronavirus. For example, normal rent expense that would have been incurred had the pandemic never occurred is not eligible.
  • 26. 26 Appendix B | Lost Revenue Calculation Lost Revenue Calculation Methodology Option Overview Details Example Option I: Actual-to-Actual Comparison Comparison actual patient care revenue for each quarter in 2020 and the first two quarters of 2021 to the corresponding quarter in 2019. Must be reported by payor class (Medicare A&B, Medicare C, Commercial, etc.) Patient care revenue for Q1-Q4 2020 and Q1-Q2 2021 will be compared to the corresponding quarter in 2019. For quarters where revenue increased versus 2019, lost revenue for that quarter will be $0; it will not offset losses in other quarters. Relative to 2019, a practice loses $100K in each quarter for Q1, Q2, and Q3 2020. In Q4 2020, revenue increased by $50K relative to 2019. The $50K increase in Q4 does not offset losses in Q1-Q3; total losses for the year are still $300K. Option II: Actual-to-Budget Comparison Comparison of actual patient revenue for each quarter in 2020 and the first two quarters of 2021 to the budgeted revenue for that quarter. Must be reported by payor class. Patient care revenue for Q1-Q4 2020 and Q1-Q2 2021 will be compared to the budget for that quarter. To use this method, the budget for the entire period (through June 30, 2021) must have been established and approved by March 27, 2020. Recipients using this method will need to provide their budget document and certify that it meets the timing requirements. Relative to budget, a practice loses $100K in each quarter for Q1, Q2, and Q3 2020. In Q4 2020, revenue increased by $50K relative to budget. The $50K increase in Q4 does not offset losses in Q1-Q3; total losses for the year are still $300K. Option III: Any other reasonable methodology Providers may calculate lost revenue through any other reasonable methodology. HHS will review methodologies and alert providers if it deems the methodology unreasonable and the provider will have 30 days to resubmit its report using Option I or Option II. Recipients must provide a narrative document describing the methodology, an explanation of why the methodology is reasonable, and a description establishing how lost revenues were attributable to coronavirus, as opposed to a loss caused by any other source. They must also provide a calculation of lost revenues attributable to coronavirus using the methodology described in the narrative document. This methodology offers providers maximum flexibility, however, it carries an explicitly higher risk of audit by HHS, so providers using this method should ensure that their methodology is sound, measures baseline revenue and lost revenue consistently, and does not double count losses.
  • 27. 27 Appendix C | Personnel Metrics • Clinical: Total number of clinical personnel providing direct patient care by labor category (full-time, part-time, contract, furloughed, separated, hired). Clinical staff provides direct patient care and may provide direct diagnosis, treatment, or care for the patient. Clinical roles often require certifications or licensure. Clinical personnel may include physicians, hospitalists, physician assistants, nurse practitioners, registered nurses, nursing assistants, patient care technicians, social workers, and therapists. Personnel must be categorized as clinical if 50% or more of their time is spent delivering direct patient care. • Non-Clinical: Total number of non-clinical personnel by labor category (full-time, part-time, contract, furloughed, separated, hired). Personnel must be categorized as nonclinical if less than 50% of their time is spent delivering direct patient care. Non-clinical personnel may support patient care. Non-clinical personnel may include medical billers and coders, transcriptionists, hospital executives, and receptionists. • All clinical and non-clinical personnel employed at any point and in any capacity during a calendar year quarter by the Reporting Entity (or its subsidiaries included in the report) must be categorized into one of the following labor categories. The labor categories are mutually exclusive, and each employee should only be included in one labor category per quarter. If a hiring action (e.g., furloughed, separated, hired) occurred during the quarter, personnel should be considered non-clinical if less than 50% of their time does not involve direct patient care. The employee should be identified in the category that occurred closest to the end of the quarter. All full-time, part-time, or contractor personnel should be those who experienced no hiring action during the respective quarter. • Full-time: Number of personnel employed on average 30 hours of service per week, or 130 hours for a calendar month. However, healthcare practices may have exceptions to this, such as nursing shifts. • Part-time: Number of personnel employed any time between 1 and 34 hours per week, whom may or may not qualify for benefits. • Contractor: Number of personnel employed as an individual or under organizational contracts and do not receive direct benefits or compensation from the employer/provider. • Furloughed: Number of personnel on temporary, involuntary, or unpaid leave of absence. • Separated: Number of personnel who 1) voluntarily submit a written or verbal notice of resignation or 2) the employer/provider decided to terminate its relationship with the employee(s) (including lay-offs and expired contracts). • Hired: Number of personnel 1) not previously employed by the employer or 2) that left an employer due to voluntary or involuntary separation and are brought back to work by employer.
  • 28. 28 Appendix D | Patient Metrics • Inpatient Admissions: Number of hospital admissions on a clinician’s order (i.e., direct admit) or formally admitted from the emergency department to the hospital (i.e., emergency admission). • Outpatient Visits (in-person and virtual): Number of in-person or virtual patient encounters with a clinician in an office-based, clinic, or hospital outpatient department setting that do not require an inpatient admission. • Emergency Visits: Number of emergency department encounters for care or treatment. This may include patients on observation status who are cared for no longer than 72 hours and not formally admitted to a hospital. • Facility Stays (for Long- and Short-term Residential Facilities): Number of stays (defined as unique admissions) for patients residing in a long-term or short-term care or treatment facility.
  • 29. 29 Appendix E | Facility Metrics • Medical/Surgical Beds: Number of general medical/surgical beds, which are the beds used for routine care or “ward” beds. • Critical Care Beds: Number of beds in intensive care units (ICUs), critical care units (CCUs) or intensive therapy units (ITUs). • Other Beds: Number of any other type of staffed bed that the facility has physically available and licensed to operate. Reminder Only recipients who answer affirmatively to the question: “Does the Reporting Entity or its subsidiaries operate or support staffed beds?” will be required to complete this section