As of April 11, 2022, the Health Resources & Services Administration (“HRSA”) is now offering providers who missed the original Provider Relief Fund (“PRF”) reporting deadlines the opportunity to request the ability to report in compliance with the PRF Terms and Conditions. Request submissions for Reporting Period 1 are due by Friday, April 22, 2022.
Providers who received one or more payments exceeding $10,000 from the PRF are required to comply with certain reporting requirements. HRSA set deadlines for (1) using the money and (2) reporting about that use, depending on when the funds were received.
HRSA apparently attempted to contact all providers who received PRF funds to make them aware of these deadlines; however, in the midst of a pandemic, many healthcare providers missed these deadlines or were unable to comply. HRSA recently began sending out notices, advising that providers who failed to report on time were out of compliance with the Terms and Conditions for the PRF, and would therefore have to return all of the funds received. Understandably, this caused a panic in the industry, as most providers used these funds long ago to keep their business afloat.
In response to the panic, HRSA created a form to “Request to Report Late Due to Extenuating Circumstances” (“Request to Report”). The process is “intended for providers who were required to report in an applicable reporting period, but extenuating circumstances prevented them from submitting a report by the required deadline.” The process is currently open to providers who received $10,000 in Payment Received Period 1 (April 10, 2020 to June 30, 2020). The process will be, but is not yet, available to those providers who missed the deadline for Payment Received Period 2 (July 1, 2020 to December 31, 2020) as well; details on the process for Reporting Period 2 will be released “in the coming weeks.”
A provider must have registered in the PRF Reporting Portal to submit a Request to Report. Note, most providers registered when making their attestations to keep the funds in the first place. “Allowable” extenuating circumstances preventing providers from meeting the reporting deadline include:
- Severe illness or death– a severe medical condition or death of a provider or key staff member responsible for reporting hindered the organization’s ability to complete the report during the Reporting Period.
- Impacted by natural disaster– a natural disaster occurred during or in close proximity of the end of the Reporting Period damaging the organization’s records or information technology.
- Lack of receipt of reporting communications– an incorrect email or mailing address on file with HRSA prevented the organization from receiving instructions prior to the Reporting Period deadline.
- Failure to click “Submit”– the organization registered and prepared a report in the PRF Reporting Portal, but failed to take the final step to click “Submit” prior to deadline.
- Internal miscommunication or error– internal miscommunication or error regarding the individual who was authorized and expected to submit the report on behalf of the organization and/or the registered point of contact in the PRF Reporting Portal.
- Incomplete Targeted Distribution payments– the organization’s parent entity completed all General Distribution payments, but a Targeted Distribution(s) was not reported on by the subsidiary.
The provider must “attest to a clear and concise explanation related to the applicable extenuating circumstance.” However, supporting documentation will not be required. All Requests to Report for Reporting Period 1 must be submitted by Friday, April 22, 2022 at 11:59 p.m. EST.
If a provider’s Request to Report is approved by HRSA, the provider will have the opportunity to complete their report in the PRF Reporting Portal. Providers will have 10 days from the date the notification is received to submit their report.
Providers whose Request to Report is denied will remain non-compliant with the Terms and Conditions and will be required to return all funds to HRSA that were not reported on in the applicable reporting period.