After finally receiving much-needed Provider Relief Fund dollars, senior living operators are raising concerns about new reporting requirements related to the aid, saying they create confusion and potential barriers to retaining it, according to two industry trade organizations.

The American Seniors Housing Association and Argentum sent a letter Monday to Department of Health and Human Services Secretary Alex Azar asking for revisions and guidance on HHS’s Post-Payment Notice of Reporting Requirements, issued Sept. 19.

“It is crucial that senior living communities receive funding from the Provider Relief Fund, and it’s equally important that the industry is allowed to retain these funds in order to continue its valiant efforts to keep nearly 2 million older Americans safe, socially engaged and out of the hospital,” ASHA President David Schless said.

In its recent guidance, HHS “significantly modified the calculation of ‘lost revenues’ attributable to COVID-19,” according to the organizations. In earlier guidance from June 19, lost revenue was defined as “any revenue that you as a healthcare provider lost due to coronavirus.” The updated guidance changes that definition to year-over-year negative change in net patient care operating income.

The new guidance, Schless and Argentum President and CEO James Balda said in their letter, creates “significant challenges” for senior living communities by penalizing organizations “in the midst of growth in facility capacity” with newly constructed or recently expanded communities. It also penalizes organizations “that made prudent efforts to reduce operating expenses” in response to financial challenges created by the pandemic, according to the associations. The new guidance reduces the amount of funds that can be retained based on improvement in operating performance made later in the year.

The associations also are seeking clarification on the new reporting guidance related to Step 1 expenses, general and administrative expenses attributable to coronavirus, coronavirus expenses not reimbursed by another source, coronavirus-related supply expenses, Step 2 payments applied to lost revenues, and expenses to maintain healthcare delivery capacity.

“Retaining the June 19, 2020, definition of lost revenue and providing further clarifications in their calculation are essential to support senior living providers’ response to the COVID-19 pandemic in a thoughtful and sustainable way,” Schless and Balda wrote.