Provider Relief Funding Reporting Requirements for Dental Practices

The U.S. Department of Health and Human Services (HHS) has reporting requirements for the Provider Relief Fund (PRF) program that many dental practices received. There are deadlines for use of the funds as well as reporting deadlines. You will want to make sure you report correctly to ensure you are in compliance with the reporting rules.

Background: Provider Relief Fund

In the summer of 2020, HHS rolled out phase two of the Provider Relief Fund program in which dental practices were included in the eligibility to receive assistance for the increased expenses and revenue losses resulting from COVID-19.

Provider relief funds are meant to be used for healthcare-related expenses to prevent, prepare for, and respond to COVID-19. These funds can also help cover the lost revenues attributable to COVID-19.

Many dental practices received these funds in late 2020. If a practice receives the funds by December 31, 2020, they must report on those funds through the online portal. The reporting portal is opening on January 1, 2022 with the reporting for payments received through this phase due on March 31, 2022.

Through the reporting process, a practice will report the expenses, lost revenues, and then ultimately determine if any of these funds need to be paid back. A practice can keep the funds if they are used for the purposes that are allowed through the terms and conditions of the program.

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Key Terms to Know

As dental practices are preparing to report their provider relief fund payments, there are important terms to keep in mind.

• Payment Received Period: The period in which one or more PRF payments were received. If multiple payments were received, it's important to know the dates of each of those payments. The timing and amount(s) of the payment(s) received will dictate what and when reporting is required – these dates and amounts are what drive the reporting deadlines and period of availability.
• Receipt Date: The date the funds were direct deposited into the practice’s bank account. If you received a physical check, the date that you deposited the check in the bank is your payment receipt date.
• Period of Availability: The time frame in which eligible expenses and/or lost revenues can be “used” for reimbursement by the PRF payment(s).
• Reporting Time Period: The time frame in which the reporting must be submitted in the portal.

Reporting Requirements

Reporting is required for PRF recipients who received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period. There are four different reporting periods that are applicable to provider relief funds. These periods are based on the Payment Received Period.

The period most likely applicable to dental practices is Period 2 where payments were received between July 1, 2020 and December 31, 2020. This then means that the Period of Availability for which the funds could be used for COVID purposes, or to help offset lost revenue due to COVID-19, is January 1, 2020 through all of 2021. Once that period of availability ends, the reporting portal opens and a practice has 90 days to complete the reporting.

Important Reminder! Failure to submit the reporting by the deadline may result in recoupment and exclusion from future payments.

Unused Provider Relief Fund Payments

Any unused funds from the Period of Availability must be returned within 30 days after the end of the reporting period. For most dental practices, the decrease in revenue experienced because of COVID was substantial so many aren’t expected to have unused PRF payments to the point where they would need to pay them back.

However, it is important to know the Period of Availability to ensure all funds are used by the deadline. The deadlines for returning unused funds for each of the four reporting periods are as follows:

The Provider Relief Fund Reporting Process

Step 1: Create a Login in the Portal

The very first step in the reporting process is to create a login in the portal at https://prfreporting.hrsa.gov/s/. Only one login can be created per tax ID. Then register your TIN (Taxpayer Identification Number).

Before you click the register button, take notice of the resources at the bottom of the screen. There are several resources to help as you navigate through this process. Examples are frequently asked questions, user guides for both logging into the portal and for completing the reporting process, and a portal worksheet that has several tabs that mirror the reporting requirements.

Step 2: Register Your Business

The next step in the PRF reporting process is to register your business in the portal. Registration must be done in one session which should take approximately 20 minutes (if you have all the information gathered ahead of time, it will likely take you about half that time). Also note that the website portal is compatible with the most current versions of Microsoft Edge, Google Chrome, and Mozilla Firefox. Don't try to use Internet Explorer because it will cause some issues.

Then gather the registration information needed before starting the process. You will need:

• Federal tax ID of the reporting entity
• Legal entity name (as registered with the IRS)
• Legal entity address (as registered with the IRS)
• Contact information for person responsible for submitting the report – Note there is only one contact person allowed for each reporting entity
• PRF payment information such as the amount, date received, and whether a physical check or ACH was received

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Step 3: Gathering the Reporting Information

Gathering the reporting information before you begin is key to making sure the reporting goes smoothly. Here are the items you need to gather ahead of time to ensure a straightforward process:

• Amount of interest earned on PRF payments if they are deposited into an interest-bearing account. If PRF payments are deposited into an account with other funds that are also interest-bearing, you will need to calculate the interest earned specifically on the PRF payments. This interest is for the latest fiscal year-end, so December 31, 2021, for this reporting period.
• Other assistance received during the Period of Availability (such as grants, PPP payments, dental grants, etc.) will need to be reported. The Period of Availability is January 1, 2020 through December 31, 2021.
• COVID-related expenses, separated by quarter, for all of 2020 and all of 2021.
• Annual amounts of actual patient care revenue for calendar years 2019 and 2020.
If the amount of the PRF payments exceed the COVID-related expenses incurred, complete the Lost Revenues section (see below for more information on this calculation).
• Personnel metrics (number of employees separated by clinical vs. non-clinical, full-time, part-time, contracted, furloughed, separated, and newly hired by quarter for all years), patient metrics (number of outpatient visits by quarter), and facility metrics for 2019, 2020, and 2021.
• COVID-related expenses that have not been reimbursed by other sources. For example, if you received a grant from another entity or government agency, those expenses are not allowable under this reporting. Also, it is imperative to only include expenses incurred to prevent, prepare for, and respond to COVID that are above and beyond the quantities that are normally purchased for the day-to-day operations of the practice.
• Receipts (net of refunds), by quarter, by payor for calendar years 2019, 2020, and 2021. Payor buckets included in the reporting portal are Medicare A/B, Medicare C, Medicaid, Commercial, Self-Pay, and a general Other bucket. It is important to only include patient receipts/revenues. Do not include other revenues such as stipends, on-call revenues, medical directorships, interest/investment income, PPP, etc.

Pro Tip! Download and utilize the "Portal Worksheets" from the login screen under Resources to assist in this process.

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Lost Revenues Calculation

The PRF payments can also be used as reimbursement for lost revenues. If your COVID-related expenses did not exceed the amount of payments you have received, then you can use lost revenues as reimbursement.

As dental practices are pulling information together for this calculation, they should keep in mind that the lost revenues calculation is done on a quarter-by-quarter basis. For example, quarter 1 in 2021 or 2020 is compared to 2019 and if there's a loss in that quarter, it counts as a straight loss for calculation purposes. Even if you recognized positive revenue in a quarter, when compared to the same quarter in 2019, that won’t count towards the lost revenue calculation. It's strictly a quarter-by-quarter difference so increases in revenue for a quarter are not counted (or they are counted as $0), and increases do not offset losses.

Once you have gathered your quarterly revenues and entered them online, the portal itself does the calculations on whether or not you have revenue losses. It will only count those quarters where there is a revenue loss. If you have a quarter where there was a revenue increase, the portal will count that as zero or no contribution towards the calculations.

Summary Calculation

Once you have entered all the information into the portal, the system then tallies the eligible COVID-related expenses and the eligible lost revenues total. If your expenses and lost revenues cover the amount of the payment(s) you received, you’re done! If your expenses and lost revenues do not cover the amount of the payment(s) you received, the unused funds need to be returned to the HRSA (Health Resources and Services Administration) within 30 days after the end of the reporting period.

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The Finish Line

At the end of the reporting process through the portal, there will be a few survey questions you must answer prior to completing your report. Once you finish these survey questions, you can review the report for accuracy and then submit. You will receive an automatic email confirmation that your reporting has been submitted.

Retain all supporting documentation, receipts, and calculations for three years as that is the time period HRSA can choose to audit you. If you received total PRF payments (or combined with other federal grants) over $750,000, you will be subject to a single audit in the future. If this applies, please reach out to SVA. We are well versed in the entire reporting process and are here to help.

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