By Natalie Hilfiker Roberts
The Department of Health and Human Services (HHS) recently released the reporting standards, timelines and submission guidelines for healthcare providers working with COVID-19 provider relief funds.
Facing a deadline of September 30, healthcare providers have little more than two months remaining to meet the reporting requirements, which require a sizable investment of time and energy.
To meet the tight deadline, providers should start working now to plan, prepare and submit their data to The Provider Relief Portal, which opened July 1.
While each provider has a unique set of circumstances, the phased, iterative approach below will help you to plan, prepare and submit your data in an efficient manner.
1. Learning and understanding
There are many pages of FAQs, reporting guides and supporting information that HHS has released over the past 18 months. While this is valuable information in the aggregate, there are a few key actions you can take to better understand the process before you.
- Review the Notice of Post-Reporting Requirements document released on June 11. In 11 pages, you will get the framework for the data elements required.
- Discern exactly how much HHS Provider Relief Funding that your organization received from April 2020 through today. You will need both the amounts and date of deposit to more fully plan for your required reporting period(s).
- Make sure you are registered through Health Resources & Services Administration (HRSA) for all entities in your operation who will report on funds received. Also, take the time to watch the HRSA Portal walk-through video.
For additional information, watch this one hour, free on-demand webcast where we reviewed key components of the reporting requirements and address numerous questions.
2. Data collection and documentation
This is one of the most challenging steps for many providers. Some components of the reporting will be simple data pulls from your systems or conversations with your department leaders. However, other elements will likely require significant effort to gather appropriately.
Here is how you can get started:
- Start working on data elements (metrics, survey questions, budget documentation, subsidiary info) where further clarifications and updates by HHS are not needed and/or unlikely. These will be areas that you won’t have to worry about later.
- Start thinking deeply about your COVID-19 expenses incurred over the previous 18 months. Have discussions with department leaders about all those items and expenses that may not be as obvious as items such as PPE, ventilators and hero pay, but which are clearly associated with the pandemic.
It's important to note that how you file data in Period 1 could impact your ability to retain funds received in the remaining periods or be eligible for possible future distributions.
To help, we created a data collection guide notebook that incorporates all the HHS and HRSA information. You can download it here to streamline your efforts.
3. Data review and discussion
It can be a confusing and daunting dig through all the data so you can retain as much of the provider relief funds as possible, yet still meet HRSA terms and conditions.
You don’t have to wait until all your data is collected. You can start analyzing the information and how it impacts your claims for the different fund types while other teams are gathering other pieces of data.
- Designate a small group to be involved in discussions about COVID expenses and make sure your methodology is sound, well documented and complete. Involve individuals who are both functional subject matter experts that are willing to present alternate points of view and able to assist with any needs that arise.
- We highly recommend having outside support these efforts. Accounting and consultative costs associated with HHS reporting should be considered valid COVID-related expenses. Developing this relationship early in the process will ensure that sufficient staff resources are available to help meet your needs and objectives.
4. Data revision
Once you feel confident that you’ve arrived at the overall plan and methodology for reporting, you will want to make any revisions to your data that are deemed prudent or necessary.
- If your organization is subject to Single Audit, proper process and documentation of this phase will be especially important to streamline the ease of that activity in the future.
- Update your workbooks and preparatory data entry materials to make sure you’ve covered all the areas required by the portal.
- Review and double check your numbers and data for accuracy.
5. Data entry and submission
While this may seem like the simplest step of all, there are a few things that can save you time.
- You may start entering data or responses in the portal at any point in time, and you can save your work at each step. That means you can get the data entry for more simple elements out of the way early.
- Do “print screens” or “screen captures” for every section of the portal. This will serve as good internal documentation and a mechanism for you to note questions you may have or if you need to make adjustments in the future.
- DO NOT HIT SUBMIT RIGHT NOW. HHS is still actively providing updates and clarifying FAQs. Once you submit, you cannot recall the submission. We highly recommend waiting until mid to late September before you submit your final Period 1 report in the event that guidance changes impact the amount of funds you may retain.
We will continue to monitor HRSA for updates and will share additional guidance to help you retain as much COVID-19 relief funds as requirements allow.
How Wipfli can help
Our dedicated healthcare team can help to focus your efforts and build a strategy that spans all the reporting periods that may impact you.
Contact us today to get started or check out these additional resources to help you: