Finding Text
2023-001: Provider Relief Fund Reporting
Cluster: Not applicable
Federal Granting Agency: DHHS Health Resources and Services Administration (HRSA)
Award Name: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Assistance Listing Number: 93.498
Assistance Listing Title: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Award Year: January 1, 2020 – June 30, 2023
Criteria:
Per the HRSA Provider Relief Fund (PRF) Lost Revenues Guide, PRF payment amounts may be applied to patient care lost revenues that have not been reimbursed by other sources. Patient care includes health care, services and supports, as provided in a medical setting, at home/telehealth, or in the community. Items not considered to be patient care include, but are not limited to, insurance, non-patient care, dining services, fundraising events, prescription sales revenues, grants or tuition, amounts of charity care adjustments, bad debt, retail, auxiliary or parking services, real estate revenues, amounts of contractual adjustments from all third-party payers and any gains and/or losses on investments.
Condition:
The Hospital completed two separate Period 5 PRF Reporting Portal submissions (one for AHS Hospital Corp and one for AMG). In both submissions, the Hospital attested to calculating lost revenues using Option (ii) per the HRSA User Guide – the difference between budgeted and actual patient care revenues for each quarter during the period of availability. However, within the AMG submission, management included approximately $3.3 million of other operating revenue that does not meet the HRSA User Guide definition of patient care lost revenues as noted above in the Criteria.
Cause:
Management erroneously included other operating revenue in the AMG submission in conjunction with the preparation and completion of the Period 5 PRF Reporting Portal submission.
Effect:
As management chose Option (ii) for the AMG submission and the budgets for July 1, 2022 to June 30, 2023 were not approved prior to March 27, 2020, the budget in those periods for the AMG submission was appropriately reported as zero. Although the actual patient care revenue reported was inaccurate, there was no impact to the amount of lost revenues reported for those periods as actuals exceeded the budget. Additionally, there were sufficient lost revenues related to the initial reporting period of January 1, 2020 to December 31, 2020 to cover the PRF amounts received and reported in Period 5, consistent with the AMG submission.
Questioned Costs:
Although the actual patient care revenue reported was inaccurate, there was no impact to the amount of lost revenues reported for those periods as actuals exceeded the budget. Additionally, there were sufficient lost revenues related to the initial reporting period of January 1, 2020 to December 31, 2020 to cover the PRF amounts received and reported in Period 5, consistent with the AMG submission.
Recommendation:
If future PRF funding is received, we recommend management enhance its control around the review of HRSA guidance to ensure proper review of all elements and inclusion of appropriate information (i.e. lost revenues) prior to any required future submissions to the portal.
Management’s Views and Corrective Action Plan:
Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report.