HRSA Issues Revised Provider Relief Fund General & Targeted Distribution Post-Payment Notice of Reporting Requirements
On June 11, 2021, the Health Resources & Services Administration (HRSA) issued an updated Provider Relief Fund (PRF) General and Targeted Distribution Post-Payment Notice of Reporting Requirements (Notice). This Notice supersedes the reporting requirements released on January 15, 2021, and applies to all past and future PRF General and Targeted Distributions (including the skilled nursing facilities and nursing home infection control distributions). It’s important to note the Notice doesn’t apply to the Rural Health Clinic COVID-19 Testing Program or claims reimbursements from the HRSA COVID-19 Uninsured Program and the HRSA COVID-19 Coverage Assistance Fund.
Within the Notice, HRSA extends the deadline providers have to use PRF funds and establishes new reporting time periods, both of which are based on the dates providers received PRF payments (see Table 1). According to HRSA, the reporting portal will open for reporting on the use of funds on July 1, 2021. The Period 1 reporting deadline will be September 30, 2021.
Table 1: Summary of Period of Availability & Reporting Requirements
Providers that received one or more payments during a Payment Received Period outlined above are required to report in the Reporting Time Period associated with the date in which they received payments that exceed $10,000 in aggregate. It’s also important to understand that providers that don’t report within the respective reporting time period are out of compliance with payment terms and conditions and may be subject to recoupment by HRSA.
In addition to the above direction from HRSA regarding period of availability and reporting requirements, HRSA also further clarified what providers are responsible for reporting, steps for reporting on the use of funds, eligible PRF expenditures, and lost revenue calculations, as well as other data elements to be included in the report submission.
In addition, while the Notice confirmed Single Audit or other requirements, we still expect further clarification to these requirements as a result of this Notice.
Providers should review the Notice and the PRF Reporting Portal Frequently Asked Questions document in their entirety to understand the full implications of the June 11, 2021, guidance. Please access the HHS press release regarding the Notice here.
For questions, a pdf copy of the Notice, or to discuss the PRF reporting requirements in more depth, please consult your BKD Trusted Advisor™ or submit the Contact Us form below.