On September 19, 2020, HHS issued instructions for reporting the on the use of PRF distributions. This release placed limitations on the use of PRF distributions that HHS had not previously articulated. An example includes defining lost revenue as largely focusing on lost operating margin from patient care.
On October 22, 2020, HHS issued a Reporting Requirements Policy Update. This policy update indicated that HHS, based on feedback from stakeholders and Members of Congress, HHS was amending its reporting instructions to provide for the full applicability of PRF distributions to lost revenues. Based on the Reporting Requirements Policy Update, it appears HHS is largely reverting to the lost revenue guidance that existed prior to the September 19, 2020 release. The Policy Update does appear to retain some components of the September 19, 2020 release. An example would include reporting of expenses not reimbursed by other sources.