On October 22, 2020, the U.S. Department of Health and Human Services published this reporting requirements policy update. On September 19, 2020, HHS issued instructions for reporting on the use of PRF distributions. These instructions, reflecting the Department’s balancing of dual objectives, limited the applicability of funds to an amount that would allow most providers1 to be no more profitable in 2020 than in 2019. At the time, HHS concluded that it would be inequitable to allow some providers to be more profitable in 2020 than 2019, while so many other providers struggled to remain viable. The September . . .
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