Finding 20288 (2022-001)

FINDING 2022-001 ? LOST REVENUE REPORTING Criteria As published in the June 11, 2021 Post-Payment Notice of Reporting Requirements, Health and Human Services (HHS) guidelines require that recipients of Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Program funding select from one of three approved options to determine their methodology for calculating their lost revenue reimbursement. The data utilized and submitted to HHS must follow the selected approved option. Condition The System selected Option 3 for calculating their lost revenue reimbursement. HHS defined lost revenue under Option 3 to be calculated by any reasonable method of estimating revenues. In addition to providing patient care revenues, alternative methodology for calculating lost revenues attributable to coronavirus Reporting Entities must submit: 1) a narrative document describing methodology, an explanation of why the methodology is reasonable, and a description establishing how lost revenues were attributable to coronavirus, as opposed to a loss caused by any other source; and 2) A calculation of lost revenues attributable to coronavirus using the methodology described in the narrative document. The System has incorrectly entered the lost revenue data (2020 Q1, 2020 Q2, 2020 Q3, and 2022 Q2) within the Reporting Period 3 HHS portal submission. Cause Personnel responsible for preparation and review of the System?s portal submission failed to perform a detail review of the lost revenue calculation prior to submitting it to the HHS portal. Effect The lost revenue calculations submitted in the HHS portal for Period 3 did not agree with the underlying data, which resulted in lost revenue calculation being understated by approximately $3 million. Recommendation The Company should ensure the underlying data used to calculate lost revenue agrees to amounts submitted within in the HHS portal. This calculation and the submission should be reviewed by an individual with the appropriate knowledge of the HHS requirements.