MDNews - Long Island

January 2021

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BY MARC LION, CPA, CFP Cares Act Provider Relief Fund Reporting Requirements IF YOU ARE LIKE MANY OTHER LOCAL HE ALTHCARE ORGANIZ ATIONS, YOU HAVE LIKELY PARTICIPATED IN ONE OR MORE GOVERNMENTAL A SSISTANCE PROGR AMS OFFERED THIS PA ST YE AR, SUCH A S THE PAYCHECK PROTECTION PROGR AM (PPP), CARES ACT TESTING, GOVERNMENT A SSISTANCE (LOCAL, STATE OR TRIBAL) AND THE PROVIDER RELIEF FUND (PRF). THE FOCUS OF THIS ARTICLE IS TO ALERT YOU TO THE PRF REPORTING REQUIREMENTS THAT YOU WILL BE RESPONSIBLE FOR FULFILLING BY FEB. 15, 2021. THE PRF, WITH its $175 billion of allocated funds, was estab- lished as part of the CARES Act to provide support to healthcare providers in the battle against the COVID-19 pandemic. Qualified healthcare providers were able to receive PRF payments for healthcare-related expenses or to cover lost revenue due to COVID-19. The grants received are considered income for income tax purpose. In addition, the distributions do not need to be repaid to the government, assuming providers comply with the terms and conditions. Recipients of PRF payments must attest to the payment by accepting or rejecting the funds within 90 days of receipt through the Provider Relief Fund Application and Attestation Portal. Note that not actively attesting within the 90-day period is viewed as acceptance. For Phase 1 and 2 distribution recipients the 90-day period has passed. For those who recently received funds in the Phase 3 General Distribution the 90-day window to attest is currently open. To reject payment, the recipient must return the funds to HHS within 15 calendar days of attestation. On Nov. 2, the Department of Hea lth & Human Services released its Final Reporting Data Elements PDF. This document updates and supplements the Oct. 22, Sept. 19 and July 20 General and Targeted Distribution Post-Payment Notice of Reporting Requirement. Providers who receive PRF payments exceeding $10,000 in aggregate are required to report their use of funds as part of the post-payment reporting process. Failure to comply could result in the repayment of the funds received. THE KEY DATES TO BE AWARE OF ARE AS FOLLOWS: + Jan. 15, 2021: reporting portal opens for providers + Feb. 15, 2021: first reporting deadline for all providers on use of PRF funds + July 31, 2021: final reporting deadline for providers who did not fully expend PRF funds prior to Dec. 31, 2020 REPORTING GUIDANCE ON THE USE OF PRF FUNDS CAN BE APPLIED IN THE FOLLOWING MANNER AND ORDER: + Healthcare-related expenses attributable to coronavirus that another source has not reimbursed (e.g. PPP) and is not obligated to reimburse, which may include general and admin- istrative (G&A) or healthcare-related operating expenses. EXAMPLES OF G&A EXPENSES INCLUDE: + Mortgage or rent for a clinical setting + Direct employee expenses (wage limits apply) + Fringe benefits + L e a s e p a y m e nt s (d i a g n o s t i c e q u ipm e nt , c l i n i c a l care software) + Utilities/operations (HVAC services, environmental services for cleaning) EXAMPLES OF HEALTHCARE-RELATED EXPENSES INCLUDE: + Specific medical supplies (surgical masks, temperature monitoring devices) + Equipment (ventilators, HVAC systems, upgrades to filtra- tion systems) + Information technology (upgraded internet, remote working support, new EMR) + Facility upgrades (improvements to waiting rooms to accommodate COVID-19 safety protocols) + PRF payment amounts not fully expended on healthcare- related expenses attributable to coronavirus are then applied to patient care lost revenues. Recipients may apply PRF payments toward lost revenue up to the amount of the difference between their 2019 and 2020 actual patient care revenue. + If recipients did not expend PRF funds in full by the end of calendar year 2020, they will have an additional six months in which to use remaining amounts toward expenses attributable to the coronavirus pandemic. The specific methodology for reporting the above information has not currently been released. In preparation for a timely and accurate submission of the requested data, it is advisable for recipients of PRF payments to proactively analyze their coronavirus-related expenses. Contact a professional advisory services firm for guidance on COVID-19 regulatory and financial relief programs before it's too late. n Marc Lion , CPA , CFP, is a Partner/Practice Leader with Entrepreneurial Business Services, Mazars USA LLP. For more information, visit mazarsusa.com. M D N E W S . C O M /// M D N E W S L O N G I S L A N D ■ 2 0 21 G O V E R N M E N TA L A S S I S TA N C E P R O G R A M S ❰❰❰❰❰ 1 1

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