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[Music] hello and welcome to today's webinar with dean dortmund the topic is provider release funds reporting requirements with lance mann one of our assurance directors thank you so much we hope you learn a lot and with that being said i would love to introduce lance mann good morning everybody we are grateful that you've joined us today for the provider relief on reporting and compliance requirements um this is only an hour long so we certainly can't cover all 60 pages of the faqs but we'll do the best we can please submit questions throughout julia is going to be monitoring uh the questions and we'll answer as many as we can and those can't answer we will send email responses back to you or you can always reach out to me my contact information is at the end or adam shoemaker if you work with adam as the leader of our health care team my name is lance mann i'm an assurance and consulting director with dean dorton i spend quite a bit of my time working with health care organizations hospitals and physician groups and fqhcs i have been spending the last several months of my life with the provider relief funds and trying to help hospitals navigate all the complexities that is there the objectives today are really to understand the reporting requirements and kind of understand how you're going to get to the information you need to report with the incremental expense and lost revenue calculations and then a high level overview to help you get ready for your single audit or compliance audit when you get to that point as with any cpe related item we've got to have an agenda um we are going to focus mostly on an overview and helping you get ready for those reporting requirements all right provider relief funds overview so for anybody that's been monitoring it it's been a year of changes with the provider relief funds as it has with the rest of the world so in march of 2020 the cares act was signed into law and everybody kind of operated based on what was in the cares act and it was to help prepare prepare for respond to and prevent the spread of the coronavirus along with maintaining health care capacity in essence what the legislature wanted to do was to make sure hospitals didn't lay off a lot of people that needed to be helped with covid because if you remember back in april and may most elective surgeries had to be canceled in june we got our first bit of information about compliance with using these funds and they provided the definition of lost revenue it focused on in essence any reasonable method of calculating lost revenue and then in september of 2020 we received some additional guidance that introduced a two-step process the first step being identifying costs related to responding to preparing for and preventing the spread of the coronavirus and step two lost revenue in october hhs released some post payment notice of reporting requirements that changed the definition of lost revenue to a negative year over year change in net operating income and that was not well received in the marketplace and after a few other changes in december legislator passed another stimulus bill and within that there were two pages related to the provider relief funds one they added three billion dollars to the provider relief funds and they also reverted the definition of lost revenue back to the june definition which is what most providers wanted and there were also some nuances related to targeted distributions that we'll dig into later and then in january we received some additional information from hhs about how they were interpreting the december legislation and more well-defined lost revenue and incremental expenses and how those should be reported cares act you know kind of had four big buckets that were health care related the biggest one was the provider relief funds 175 billion dollars there was 45 billion that was allocated to fema that you can apply for most hospitals can apply for to get fema money um one thing to note is the provider relief fund money is the reimbursement source of last resort so if you got fema money and provider relief on money you have to use all of the fema money first before you can dip into the provider relief funds there were some changes in medicare reimbursement there was a 20 pump temporary suspension of sequestration dish payment cuts delayed and advanced payments for medicare if you applied for those and the fcc received a small amount for government non-profit hospitals in 2021 in december 2020 we got the stimulus bill that we just talked about that changed the definition of lost revenue and it also allowed for multi-hospital systems transfer general and targeted provider relief fund grants within the health system we'll go into that more depth later the provided relief funds were split into different categories of provider relief funds there was a general distribution high impact there were some rural targeted distributions some skilled nursing facility distributions for infection control tribal medicaid safety net and dental distributions all of these different distributions are required to follow the rules that are within the faqs of the provider relief funds i put this together to kind of show the timeline of thoughts as you may have gone through if you're audited currently as you went through your audit last year and if you're not audited some of the thought patterns that go through this year if you're going to require one but for june 30 2020 year ends um depending on when you issued your financials we had to think about subsequent event considerations because of the hhs guidance that was coming out in september and october and determining you know should any of the revenue that you've recognized up that up to that point need to be reversed i'm at that point we didn't know if you were going to be required to have a single on it we knew shortly after june 30 but i don't believe as of june 30 we knew in september we kind of had more information not really much of a subsequent event consideration anymore and we're trying to determine have you met the measurement criteria to recognize revenue and many had not recognized it as that point by december 31 we kind of had our arms around it we knew our calendar year-over-year change in revenue and so you should be able to estimate how much revenue you should be able to recognize as of december 31st and then you fiscal years after december 31st is when you're going to have to start requiring a single audit so we're going to go into the the single audit reporting requirements in a minute but you for those who are a fiscal year end you won't have to include it in a single audit until your 2021 year end and i've got a slide that describes that in more depth later we just included a few links for you all in the presentation julia will send out slides later and you can go to some of this guidance around accounting for the provider relief funds and your omb compliance supplement for the single audit so how are we allowed to use provider relief funds there's only two two ways you could use the money if you can't use it for those two reasons you have to send it back to hhs so the first way is to spend it on um expenses incurred to respond to to prepare for and to prevent the spread of cova-19 and those can only be incremental expenses to what you would typically spend and so you take your incremental expenses attributable to covet 19 you subtract any incremental reimbursement you may have received for those expenses and then you add to it your lost revenue and that's your total amount that you can use hopefully it's all of the funds you received that you're not sending back um i added in the specific text from the stimulus bill in december it just points out there at the bottom where the provider may calculate lost revenues using the faqs released in june of 2020. in addition the stimulus bill included information that you could transfer targeted distributions within your health system and there's some audit there's some you know potential compliance things you need to know about that we'll dig into in a moment so i'd like to spend a little bit of time on the january 15th post payment notice of reporting requirements because it's you know right now sort of the driver uh behind how we're helping our clients get ready for these reporting requirements and so included in the release were six big categories the first was some of the options for calculating lost revenue uh the second was how you're going to be expected to report your incremental expenses the next is reporting data elements and hospital operating metrics to be reported how other assistance should be reported and other assistance or things like fema money that you received paycheck protection program loans that you may have received and there's a list of many other things within the guidance that we can get to you if you need it and then also details on how targeted distribution transfers should be reported and who's responsible for those reporting requirements if you transfer distributions within your health system so i'm going to start with lost revenue because most people have been focusing on that component of it and so with the release and then these next few slides are quite wordy um because words matter right now with some of these things and i didn't want to i didn't want to remove any words and try to summarize it using my own words and so these are copied and pasted right out of the reporting notice that they came and so you've got three options for reporting lost revenue the first is the difference between calendar year 2019 and calendar year 2020 actual patient care revenue this is net patient service revenue net of all of your contractual allowances and bad debts compared for both years the second is the difference between your 2020 net patient service revenue compared to your 2020 budgeted net patient service revenue and if there's a difference between those two if there's a negative difference between those two you can report that as lost revenue um there's a note your budget needed to be established and approved prior to march 27 2020 and you are required to submit additional documentation at the time of reporting um and your and your ceo or cfo will have to certify that the budget was approved prior to that date the third one is really the one that most people have been focusing on and it is to calculate it by any reasonable method of estimating lost revenue um this this option comes with some higher risk i've kind of bolded a sentence there in the middle that if you do plan to use an alternate methodology you may face an increased likelihood of an audit by herself if you do plan to go down this approach you need to you're going to have to you know draft a memo describing the approach that you're taking to calculating lost revenue you know why you believe the methodology is reasonable and and provide the calculation to versa when you do the reporting person will review your methodology in your calculation and they will let you know if they believe that it's reasonable and if you if they don't believe it's reasonable you have 30 days to resubmit your report using either the calendar year actual option or the budget to actual option and so if you do plan to use this any reasonable method just know you only get one shot at it as it stands today and so if you try the approach you're not going to get another option of using a different reasonable method you've got to go to one of the other two options so in addition to lost revenues incremental expense reporting is actually your your first source of reimbursement for provider relief funds it's step one in the approach and there's two categories of incremental expense reporting the first is for everybody who received prf funds between ten thousand dollars and five hundred thousand dollars you only have to report health care related expenses in two buckets general and administrative expenses and other health care related expenses if you received more than five hundred thousand dollars in prf funds you've got to break it down into uh in a more granular level and i've listed those here so within general and administrative expenses you've got to list incremental expenses into these seven buckets listed there and the same for health care related expenses attributable to the coronavirus you've got to list it out in these five buckets there and so you'll need to make sure that your records are such that you can you can pull the information out into these categories and again this is copied and pasted verbatim right out of the guidance so in terms of accounting guidance you know i know this is more compliance around it but if you know we do a disservice if we didn't tell you how to account for these funds um the provider relief fund should be accounted for as deferred revenue or refundable advances until you meet the criteria to keep the money and so until you have spent the money on either incremental expenses or lost revenue there has been some question about you know since there's a calendar year to calendar year reporting requirement as it relates to comparing um actual 2020 to actual 19 and actual 2020 to your actual budget should you have recognized any of it prior to december 31st 2020 i think we're past that for you all for any non-calendar year companies here but it was a question earlier in the year um that that never got answered in a real meaningful way i think there was just a mixed bag of who recognized revenue early and who did it so reporting so for all of the funds that you used by december 31st 2020 you will have to report on those funds how you use them the date for that has not been said yet it was supposed to be february 15th the window was supposed to be january 15th to february 15th and um hhs has come out and said that is no longer the reporting window and we we don't have a new window reporting window to give you yet so it's yet to be determined uh please monitor our thought leadership that we put out and we'll notify you when that is um is released there is a link on this slide that takes you to the reporting and auditing web page of the provider relief funds within hhs and then there's going to be another reporting requirement so any unspent funds you have as of december 31st you have until june 30 2021 to use them and on july by july between july 1 and july 31st you'll have to report on how you use those remaining funds any funds you're unable to use by june 30th you'll be required to return back to hhs i know that's very complicated so obviously let us know if you have any questions what can you do now as it relates to getting ready for your reporting requirements you can register with the reporting portal hhs and hersa are recommending you go ahead and get registered so you understand how to use the system we have included a link here to where you can go and register for the for the portal okay so one of the reasons i wanted to do this webinar is i think there's um some confusion around incremental expense calculations um in addition to all the questions we've gotten about lost revenue i think there's more options for incremental expense calculations than some people think and so i wanted to dig in on some of those so the next few slides are a little wordy because i've copied and pasted a few of the faqs directly out of the faqs because again words matter and so within the frequently asked questions for the provider relief funds hhs has provided some examples on how you can calculate your incremental expenses and so you'll notice this first one here you know they should calculate incremental dna expenses that were occurred or incurred that were attributable um to coven 19 and estimate the portion of those expenses that were not covered through operational revenues and they provided some examples and the same for expenses attributable to the coronavirus not reimbursed by other sources these things apply to each type of healthcare expense attributable to the coronavirus next one is you know how do i calculate expenses attributable not reimbursed by other sources this is a very long faq and so this is the first part of it the part i want to focus on is on the next slide so they've shown a specific example of how to calculate incremental expenses that i think many providers have have ignored and i wanted to highlight a little bit so the example given in the faqs is you know five dollar increase in the expense or cost to provide an office visit is calculated in this way so what were your average expenses or cost to provide an office visit pre-pandemic and post pandemic and as you can see here there's a five dollar difference and there's an so that's the first step is calculating what were your incremental expenses the next step is what were your incremental revenues associated with those additional expenses and as you go through the examples you'll notice for everyone except for um example four there's a five dollar incremental expense and step four it was a five dollar insurer supplemental coronavirus related embarrassment of five dollars and so that would be an incremental revenue but all the rest you get to report five dollars and it's very much a high level analytical approach to this and you'd have to take those five dollars and allocate it amongst the various expense buckets that we previously talked about so let me let me take you through an example that i created here well first let me go through what what are the multiple options for calculating incremental expenses and so i think the option most people are taking is they're accumulating covet 19 specific purchases and expenses they've got an expense code in their gl and they're recording everything to it and that's what they plan to use for their incremental expense calculation and that is a fine way of doing it examples of that would be personnel assigned to new coven 19 specific tasks temperature checks door screeners um covered 19 tests for every patient that has to come in lots of different things personal protective equipment hand sanitizer all the extra things you bought this year coven 19 capital purchases additional cova 19 supplies and and a lot more you know everybody's going to have different there was food supplies that had to be purchased and packaged in a different way there were corridors that had to be renovated and you know ventilations that had to occur and just a lot of different things that you could have tracked so that's one way to do it the second way to do it is to calculate incremental expenses on a line item by line item basis you could go through each of your expense categories within your gl and determine where are incremental expenses that are covered related and the final version in my mind is to calculate your incremental expense per patient visit and extrapolate that across all patient visits for 2020 which is the approach i'm going to show you now and i think you should hospitals and physician groups should look at all of the options because you may find that your incremental expenses are higher in one rather than the other and so the example i've got here and we've done it on on a couple hospitals and physician groups and it's shown higher incremental expenses than you would have expected and so your operating expenses for 2019 14 million dollars your number of admissions were 4500 admissions so your average cost per admission for 2019 was 3 111 your operating expenses for 2020 were 15 million dollars number of admissions were only 4 300 and so your cost per admission in 2020 is 3488. you'll notice an increase in cost per admission of 377 dollars multiply that by your number of admissions in 2020 and you get total incremental expense of 1.6 million dollars you may be saying well that's more than our total operating expense increase you're right because if you had if you were operating your business as an efficient hospital you likely would have had cost reductions because you had you know admission and patient volume reductions but you actually had to spend more to see fewer patients and so in this example we're saying you get credit for 1.6 million dollars of incremental expenses however we need to look at incremental revenue that you've received for those expenses and so in 2019 over to the right you had 18 million dollars of net patient service revenue you had the same 4 500 admissions your revenue per admission was 4 000 in 2020 you received 17.5 million dollars total number of admissions are 4 300 your revenue per admission is four thousand seventy dollars so you're receiving more per patient visit in twenty twenty of seventy dollars seventy dollars times your total admissions of forty three hundred equals three hundred thousand dollars of incremental revenue we're gonna deduct that three hundred thousand dollars of incremental revenue from the 1.6 of incremental expense and your net unreimbursed incremental expenses are 1.3 million dollars then you would take this 1.3 million dollars and allocate it amongst the applicable expense categories that we covered earlier you'll also notice here there's also likely a case for lost revenue because your net patient service revenue went down five hundred thousand dollars so that would be an additional amount that you would add to this there are some adjustments that you'll be required to make there's a salary limitation on what expenses can be included uh in your incremental expense calculation and so they hhs did not want any expenses to be paid to employees that earn over 197 300 they're not saying you can't pay people more than that they're just saying they didn't want grant funds to be used to pay people over 197 300 and so what we've done in our calculations is looked at employees receiving over 197.3 in both 2020 and 2019 determined if they had incremental compensation paid to them during the year we removed that incremental amount or if you had an employee that made over 197.3 in the current year but not in the prior year you would limit their the the cost you're including in your provider relief fund costs to that 197.3 property and expense calculations so originally in the original faqs you could only take into account depreciation uncovered 19 specific capital purchases but they've within the last few months i'm clarified that if you bought coven 19 specific capital purchases and i've got a list of those on the next page you can include the full cost of those in your incremental expenses not just the depreciation you do want to be cautious that you don't include any operating expenses for facilities that are not critical to providing patient care and so if you've got storage facilities or other spaces that you may lease you just need to be conscientious of what operating expenses you're including in here do not include any revenue or expenses from durable medical equipment was a specific faq and cost reimbursed hospitals will be limited in their incremental expenses and so there was an faq that clarified that in essence if you think of critical access hospitals you're reimbursed at cost already and so you would have incremental revenues associated with all of your incremental expenses if your cost reimbursement if anybody has any questions on that we can dig into it on a case-by-case example because each cost reimbursed hospital is going to have a different set of criteria to look at i mentioned covid 19 specific capital items these items are pulled directly out of the faqs as items that would qualify to count all of it in your incremental expense calculation and it's the stuff that you would expect disinfectant supplies ventilators masks suits ppe reconfiguring facilities to create a cove award things like that we've had a few questions come in about taxes can you pay can we pay taxes associated with provider relief funds yes provider relief funds are taxable to for-profit tax-paying organizations but you can also use the funds to pay your taxes except with the nursing home infection control distribution payments okay so for the next 10 minutes or so we're going to dig in on single audit major program guidance provider belief on compliance audit however you want to call it it used to be called an a133 audit for those familiar with those there's going to be a lot of organizations that are subject to a single audit for the first time and we'll work through it all together so from a grant perspective the provider relief funds are considered a government grant and so you're required to have some audit procedures performed around it and so when when the government provides a grant they assign it a cfda number and we're going to go through that definition in a moment the provider relief funds were assigned cfda number 93.498 and so let's do some level setting here cfda is the catalog of federal domestic aid cifa is your schedule of expenditures of federal awards omb is the office of management and budget they're the ones who create the rules for single audits uniform guidance is the guidance that auditors follow to do your audit gas is government auditing standards gagas is generally accepted government auditing standards gao was the government accountability office and so we non-federal entity is could be a non-profit or a commercial entity we'll talk about a little bit of program audits and gas audits and single audits as we move through this so here's a few common questions i'm a for-profit health care company what should i do and so we're going to go through that in a moment but if you're a for-profit healthcare company that received an excess of 750 000 you will be subject to some form of audit as it relates to the provider relief funds i i hope this is not the first time you were hearing that but there will be some audit you will have to do what is a program specific audit and how do i qualify we're going to go through a table that will help you determine if you're eligible for program specific audit at the moment what does it mean to have an audit conducted in accordance with government auditing standards the government just like non-government audits occur have their own set of auditing standards which tell me how many samples i got to pick and do i need to be independent of you and what are appropriate audit steps to take there's rules for the for-profit world and there's rules in the government space the government space is a little more strict and what is a single audit you know a single audit is a as an audit that we perform to make sure that organizations spend their grant money how they were told they could spend their grant money typically there's a list of um when you get your grant document there's a list of you know 10 or 15 or 20 items you're allowed to spend your money on so long as you spend it on those things and you spend it within the right amount of time you're fine this one's a little more complicated because how you can spend your money is a little more vague within the faqs so government auditing standards are issued by the gao they apply to all audits performed to satisfy a federal audit requirement it builds on generally accepted auditing standards certain for-profit entities may be able to satisfy the hhs audit requirement with a financial audit of the federal award which is a program-specific audit where the uniform guidance wouldn't apply but government auditing standards would apply um and we're still going to be the audit steps are likely going to be the same they just may cost a little less for some of the compliance requirements we'll have to follow there's still more guidance waiting to come out on how the program audits will work for this if you're a non-profit typically doing a single audit or typically doing a financial statement on it the difference between a single audit and a program auditor likely not very much so most of those organizations will likely proceed with a general single audit so what are my options i'm a non-federal non-commercial entities i'm a non-profit organization yes and then the next bug is did you expend federal awards under more than one federal program yes or no if no if you only got provider relief funds that's your only federal program then you may be able to do a program audit i will tell you if you're already doing a financial statement audit the difference between a program audit a single audit is very little but you may have that option and it's based on what we currently know i'm a commercial for-profit entity you have a few more options so did you expend federal awards under more than one federal program and this is going to be key because most for-profit organizations don't track their gut government grant funds and so did you get any fema money did you get any other cares act or grant money during the year that's federal if yes you need to go to the bucket on the left where you choose between a single audit and a gas financial audit of each individual award if no if provided relief funds are your only one that you've got then you can decide between a program audit and a gas audit not going to be a lot of difference between the two likely as you consider your government grants one thing to know is the paycheck protection loan money is not subject to single audit or includable on your schedule of expenditures of federal awards so just know that i have been using the term schedule of expenditures of federal awards um let me walk you through what that means and so typically we would be able in a in a single audit you would hand us a list of expenses we spent a million dollars of xyz grant and here's how we spent it and there would be a list of them that's not necessarily the case here because you've got lost revenue that you are applying it towards and so whatever information you put on that reporting requirement i i discussed earlier today the hersa reporting requirement for how you use the funds through december 31st whatever you input into those boxes is what is going to show up on your schedule of expenditures of federal awards for your single audit or your program on it so it's crucial that you spend a lot of time making sure you get the right numbers and the reporting requirement the same will go for your next you know for funds expended between january 1 and june 30. those will show up on your next schedule of expenditures and federal rewards so other potential oversight that you need to be aware of the office of inspector general is is welcome to come and audit these funds from you um hersa has said that they're going to be doing some audits in this and other federal agency desk reviews and other people other watchdogs that may be coming to look and so just make sure you've dotting all your eyes and crossing all your teams so i did want to talk about fiscal year end entities because this was a big deal it's probably about a month old big deal so most of you should already know if this applies to you but if your fiscal year end is on or before december 30th 2020 you will include nothing on a schedule of expenditures of federal awards for your 2020 year-end so if you're june 30 2020 year end you do not include anything for 2020 if you're september 30 2020 you're in you include nothing for 2020 if you're a december 31 2020 year end excuse me excuse me you will include your december 31st what you report to hersa on your december 31st schedule of expenditures of federal awards if you have a fiscal year end between january 1 2021 and june 29 2021 you will base what you report off of your december 31st 2020 reporting requirement to herself if you have a june 30 2021 or after fiscal year end um you will likely report your december 31st and june 30 numbers uh both numbers in your schedule of expenditures of federal awards but that guidance isn't out yet the guidance that out only goes through june 29th 2021 and so more guidance will come out next year around what you will be reporting but my guess is those june 30 and after fiscal year ends will include both which you included as of your december 31st reporting requirement and as of what you included in your june 30 reporting requirement so whenever a single audit is required to occur the omb office of management budget put out compliance requirements and these are the things that your auditor is required to test and for provider relief funds there's only three buckets that have been marked with a y you've got activities allowed or unallowed allowable cost and cost principles and reporting the reporting part should be pretty easy did you comply with your december 31st reporting requirement did you comply with your june 30 2021 reporting requirement those should be pretty straightforward the activities allowed are unallowable and allowable costs and cost principles meaning did you spend the money on what you're allowed to spend it on based on what you reported in those reporting requirements the faqs are going to drive a lot of how this is audited so just just know that so here the activities allowed and allowable costs you've got to spend the money to prevent prepare for them respond to the coronavirus and it can only be payments shall reimburse recipient only for health care related expenses or lost revenues they may not be used to reimburse expenses or losses that have been reimbursed from another source so that's the key so fema dollars go first if you got a ppp loan you've got to use those before you can use any of the provider relief fund and there's other other reimbursement sources that you've got to consider there are some separate criteria for the skilled nursing facility infection control distribution on how you're allowed to spend it and we can go over those with anybody who who did get those monies but it's there's five or ten specific faqs for the infection control dollars so what you what should you be doing now um if you've not dug into the terms and conditions of the provider relief funds along with the faqs i would encourage you to read those the faq document is a 60 page document there's probably about 25 pages that that affect most health care providers and so i would make sure you're reading those and understanding them understand the reporting requirement document that came out there's a link within our slides about that ensure your transaction cycle controls are well documented make sure you've got a memo uh or or evidence to say here was our thought pattern as it relates to how we identified incremental expenses and here's our methodology for calculating lost revenue make sure you're tracking your expenses and your lost revenues if you need help consider an audit readiness provider which would be a consulting firm that comes in to say you know here's what the faqs are here's you know your facts and circumstances and help get them to help you prepare for the reporting requirements and and start if you don't have an audit firm already make sure you've contacted an audit firm that can help make sure that you're meeting all the right timelines and deadlines for getting it done if you need help finding an audit firm and you know dean norton maybe your afo person you reach out to us we can help if we're not able to do it for you good news most of the time your single audits would be nine months after your year end you do have a three month extension for that and so for december 31st year end you have until december 31st 2021 to finish your single audit so you've got some time but make sure you're you're taking some time to prepare so we've only received one question but um we still have 11 minutes so we welcome as many questions as we can get in um and i apologize if you've answered this already but what if a provider received a large settlement or mass adjustment during the 2020 revenue period and without that settlement they can easily show the lost revenue due to covid do you think that settlement can be excluded maybe so if this if the settlement related two years to years prior to 2019 i think it's very cut and dry whether or not you included or excluded is there's an faq specific to medicaid settlements for years prior to 2019 and that can be excluded from all revenue and i know there was some large settlements that came out in march of 2020 at least for some of our clients that we have removed from revenue when calculating lost revenues and incremental expenses i also know that the kentucky hospitals have been the benefit of the hospital rate improvement program that they started receiving additional payments in march april of this year for patient service days dating back to um third and fourth quarters of 2019. i think there's a case to be made to remove those from revenue because most folks had not included those revenues in their budget but i think hospitals need to know that there's risk there and they need to make sure that they're well documenting why they're removing those funds from their actual revenues when um calculating these lost revenues and incremental expenses and i know that there's a large settlement that's planned and is almost ready for kentucky hospitals to be paid out that's significantly larger than the one that started to come out in march that will relate to i believe second and third quarter or third and fourth quarters of 2020 and i believe those um you know there's a question and i've talked to two other large public accounting firms about this is do you need to include those in your actual patient service revenue for 2020 and and i don't have an answer i think there's a case to not include it and i think there's a strong case to include it and so each individual provider is going to have to take a stand on whether or not they include it and try with the alternative methodology of calculating lost revenues we got another question do ppp funds received and forgiven impact iec calculation they do well they do not they do not impact incremental expense calculations no but they do impact lost revenue calculations thank you everybody for joining us today um we are grateful to to work with many of you and obviously we thank you for taking the time to visit with us today you