The federal Health Resources & Services Administration on Wednesday offered additional information to clarify reporting requirements for Provider Relief Fund payments.

CCRCs

For instance, regarding exactly how patient/resident care revenue is defined for continuing care retirement / life plan communities that provide independent living, assisted living and skilled nursing services under a single tax identification number, HRSA said that the parent organization can report all revenue losses that fall under their umbrella of care, regardless of the level of service provided.

“This response seems to say that LPCs should report patient care revenue across all their service lines including their independent living. This makes sense, as PRF payments were based off patient care revenues for all these service lines,” LeadingAge said Wednesday. 

Assisted living

LeadingAge also asked HRSA how assisted living communities should calculate revenue from patient/resident care. The answer to this frequently asked question, the association said, had been removed from the HRSA website.

The definition of patient/resident care for reporting purposes continues to include healthcare, services and supports but not “non-patient care revenue such as insurance, retail, or real estate revenues (exception for nursing and assisted living facilities’ realestate revenues where resident fees are allowable); prescription sales revenues (exception when derived through the 340B program); grants or tuition; contractual adjustments from all third party payers; charity care adjustments; bad debt; and any gains and/or losses on investments.”

According to LeadingAge, “This is good news for assisted living providers and resolves a long-standing concern we’ve had that the policy had changed. It is good to hear it has not changed and the original definition of patient care revenue as applied to assisted living stands.”

Lost revenue payments

The organization also asked HRSA, “if a provider opts to report ‘0’ coronavirus expenses in the first reporting period, and only uses PRF payments to cover lost revenues, can they report coronavirus expenses for the full period of availability (Jan. 1, 2020 – Dec. 31, 2021) in Period 2?”

The agency said yes, and LeadingAge described the response as “important” for two reasons.

“First, it reinforces that a provider can report that it used PRF payments to solely fund lost revenue in a given quarter even if they incurred coronavirus expenses. It also says that those incurred expenses could be applied to future PRF payments reported upon in subsequent reporting periods,” the association said. “However, it very clearly states that this approach can only be taken if that is how the PRF payments were used. This seems to indicate that providers should give considerable thought to how they used the particular funds received.”

HRSA also clarified that providers must use the same lost revenue calculation option for each reporting period.