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Association Asks HHS to Withdraw PRF Reporting Guidance

In a letter to Department of Health and Human Services (HHS) Secretary Alex Azar, America’s Essential Hospitals requested that HHS withdraw its recent Provider Relief Fund (PRF) post-payment reporting guidance. The Sept. 19 guidance defined in more detail the data elements that must be reported by providers who receive PRF funds.

Under the terms and conditions associated with the receipt of PRF funds, providers can only use these funds for lost revenues and expenses attributable to COVID-19. Any funds in excess of these lost revenues and expenses could be recouped by HHS. In the guidance, HHS further defined the terms “lost revenue” and “expense” in ways that contradicts its previous definitions and could have adverse consequences for essential hospitals.

In its letter, the association stressed that any new guidance should be consistent with HHS’ previous definitions, as defined in its June 19 PRF FAQs. The new guidance severely restricts the definition of lost revenue by removing the comparison of budgeted to actual revenue in 2020 as an acceptable interpretation of lost revenue. Additionally, the guidance is burdensome, confusing, and inconsistent, which will result in unreliable and non-uniform data reported by hospitals. The new guidance could not only result in HHS recouping money, but also in a high level of uncertainty for hospitals for which fiscal years already ended and audit or financial statements are underway.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Shahid Zaman is a senior policy analyst at America's Essential Hospitals.

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