PRF Reporting and Avoiding Audits
By Jane Ehrhardt
The first Provider Relief Fund (PRF) reporting deadline of September 30 has come and gone. "But they have granted a 60-day grace period. No fines or penalties should be assessed as long as you file within those 60 days," says Bill Bach, CPA and director of the Audit and Assurance Group at Kassouf &Co. "There are probably plenty of people who have not gotten the data entered into the portal yet."
The delays in reporting are not surprising with the diverse and ongoing funding sources offered during the COVID pandemic, including PRF, Paycheck Protection Program (PPP), and state funds. And as quickly as these forgivable loan options arose, the rules for reporting and applying for forgiveness are now just as rapid. "The changes are coming out fast," Bach says. "The applications for the first draw PPP loans have been changed nine different times, and that can cause some confusion. But don't get overwhelmed and stressed out by reporting. There is information out there, and we have a roadmap to help us through the process."
The department overseeing the PRF reporting, Health Resources and Services Administration (HRSA), provides an abundance of guidance on their website (www.hrsa.gov), including not only the spreadsheets for use on filling out the portal report and a how-to webinar, but a 73-page Reporting Portal User Guide, which is basically a workbook. "Before starting your submission, read through the FAQ to gain a better understanding of reporting," Bach says.
HRSA requires reporting for any entity that received at least $10,000. Anyone falling between $10,000 and under $500,000 should use Table A to report their expenses. An entity that received $500,000 or higher is required to provide additional information, which means using Table B that separates expenses into more detail.
The User Guide supplies two categories of eligible expenses, including general and administrative expenses and a lengthy list of healthcare-related expenses. They fall into five categories and cover anything from hand sanitizer to updating the HVAC system. "They are really generous in this list of expenses you can use," Bach says. "You want to be sure you don't double dip, though. You can't use the same expense to satisfy requirements in multiple funding sources. That's the largest caveat I could give."
This may not be hard to do, considering most anything utilized or purchased to accommodate corona-virus protection is covered, including retrofitting the facility, increasing bandwidth, and remote worker expenses. "The last category is a catchall," Bach says. "Expenses here qualify as long as it was spending related to prevent, prepare for, or respond to the coronavirus. So you have a lot of leeway. But documentation must exist to back up any claims."
An audit is automatically required for providers that received at least $750,000 in PRF funds. HRSA offers two options for that audit compliance. "The single audit option is a very complex audit engagement. Usually, for-profit entities have never had those done before," Bach says. "We're advising our clients to stay away from that one and go to the financial statement audit in accordance with Government Auditing Standards option." This second option concentrates the audit on the PRF funds received whereas the first option calls for a full-blown audit covering the provider's entire general ledger.
Be aware that the CPA who performs these audits must meet the eligibility requirements set out by HRSA under Government Auditing Standards and must be Yellow Book compliant. "Government audit standards require additional continuing education requirements above the normal requirements for CPAs," Bach says.
Should the government audit your PRF report, know that the outcome may not be dire if errors are found. "The biggest risk is that you'd have to reimburse HRSA for some of the funds you received," Bach says.
This first reporting deadline, covering funds received between April 10 and June 30 of last year, is only the first of four PRF deadlines. Because healthcare providers can receive funds thru December 2021, reporting deadlines for PRF are set through March 2023. This assumes no further rule changes and that no additional funds are made available.
However, as with the PPP loan forgiveness applications, after this first round of PRF reporting, the process could be become clearer and more concise. "Once HRSA starts seeing reporting coming through, it will allow them to create more meaningful reporting guidance," Bach says.
Mostly, Bach suggests that with the ever-changing landscape and so much revenue on the line, everyone should get the right help. "Seek expertise from those who know," he says. "I would want help with this. I would want a sanity check, and I would not want to go it alone." For direct help from HRSA, call their Provider Support Line at (866) 569-3522 from 8:00 a.m. to 10:00 p.m. Central time, Monday through Friday.