Nonprofits, are you up to date on your UFR requirements? There are some changes in light of COVID-19 and other updates you’ll want to be aware of. Effective for Fiscal Years ending on or after 2020, the Center for Health Information and Analysis (CHIA) requires that Applied Behavior Analysis (ABA) Service Providers, including Intensive Early Intervention (IEI), must also file a UFR. Make sure your organization is in compliance.

ABA Service Providers

ABA Service Providers are required to separately disclose and identify each ABA service on Schedule B. The ABA services must be reported on a single Schedule B and the Cover page should list each ABA program that should be characterized by using “ABA” as a precursor. Do not combine other services that are similar to ABA on the Schedule B, such as those services that are purchased by the Department of Developmental Services, they need to be disclosed and identified on a separate Schedule B.

Exemptions:

In general, the Operational Services Division (OSD) provides a list of exemptions/exceptions; however, there are certain instances when CHIA requires UFR-filing when OSD does not. For example, some organizations may fall below the total dollar value under the OSD filing threshold but serve MassHealth clients. CHIA requires that the UFR filing is complete to obtain industry costs and other data to inform the review of clinic payment rates.

If you started a new program in the reporting year (less than a full year of operations), you are not required to complete any of the CHIA special schedules for that program year.

COVID19 Update

PPP Loan Payable or PPP Loan Forgiveness Reporting:

If your organization received a PPP loan and elected to follow the Conditional Grant Model, whereby the PPP loan is recorded as revenue, those funds should be reported on either Line 1R Contributions, Gifts, Legacies, Bequests or Line 48R – Other Revenue of Schedule B for the program in which the related expenses were incurred.

If your organization has elected to follow the debt model, whereby the PPP loan is recorded as debt until forgiveness is received, then any amount of PPP loan forgiveness must be recorded as revenue and should be reported on line 48R – Other Revenue of Schedule B for the program in which the related expenses were incurred.

If the PPP loan was received in one year and forgiven in a subsequent year, the revenue should be recorded in Line 48R – Other Revenue of Schedule B. Due to reporting the PPP revenue subsequent to the year, the expenses were incurred. Make sure you review your Organization’s Surplus Revenue Retention (SRR) calculation noted on the right side of Schedule A_OSI to ensure it does not exceed the 20% SRR cap. Each provider that exceeds the 20% SRR cap is responsible for repaying the commonwealth the excess funds. Make sure you review those calculations before submitting your UFR as the PPP loan forgiveness may put you over the threshold.

COVID19 Funding

Any COVID19 revenue received and expenses incurred should be reported as any other revenue and expenses within the applicable program and line items they relate to. These funds should not be reported separately and should be applied to the program in which it has benefited.

Extension:

Lastly, the UFR Deadline has been Extended! Check out our blog, UFR Extension. Due to the COVID-19 Pandemic, the OSD has granted a 30-day extension to the UFR filing deadline for the fiscal year ending 2021 filers. UFR filers do not need to file an extension.

Contact any member of our Not-for-Profit Services Team for guidance on how to begin the filing process.