HHS Offers New Clarifications on Provider Relief Fund Lost Revenue

Categories: Policy.

On December 2, 2020, National Hospice and Palliative Care Organization received confirmation from the Department of Health and Human Services that lost fundraising and thrift store revenue may qualify as reimbursable lost revenue for purposes of Provider Relief Fund reimbursement and reporting. 

On November 17,  NHPCO sent a letter to Department of Health and Human Services (HHS) Secretary Azar requesting consideration for lost fundraising and thrift store revenue to be counted as lost revenue attributable to COVID-19, citing hospice-specific examples of losses due to cancelled fundraising events and thrift store closures, both sources of income which supports direct patient care.

On December 2, 2020, NHPCO received a letter from HHS confirming that lost fundraising and thrift store revenue may qualify as reimbursable lost revenueThe letter states, in part: 

Additionally, your letter inquired about using PRF [Provider Relief Fund] funds to reimburse lost fundraising and thrift store revenue. PRF funds may be used to reimburse lost revenue attributable to coronavirus, and lost fundraising and thrift store revenue may qualify as reimbursable lost revenue. To calculate lost revenues attributable to coronavirus, providers are required to report revenues received from Medicare, Medicaid, commercial insurance, and other sources for patient care services. Providers should report fundraising and thrift store revenue in 2019 and 2020 as a revenue source if it was raised to fund patient care services. 

In March 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act and subsequent legislation provided $175 billion in relief funds in a Provider Relief Fund to support healthcare-related expenses or lost revenue attributable to COVID-19. NHPCO has been analyzing the HHS guidance on Provider Relief Fund reporting since the original guidance was released in June 2020. In particular, in the early days after the PRF was distributed, hospice providers raised concerns about lost fundraising and thrift store revenue counting as lost revenue due to COVID-19 which we discussed in our March 31, 2020 letter to the Administration.

Guidance issued by HHS in September 2020 explicitly focused on lost patient care revenue.  NHPCO objected to the strict interpretation of patient care revenue and with other organizations convinced HHS to loosen restrictions which were included in their October 2020 revised guidance. On November 17, NHPCO sent an additional letter requesting guidance that Provider Relief Funding may be used to reimburse lost fundraising and thrift store revenue and on December 2, NHPCO received confirmation.

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