In early March 2022, HRSA began notifying providers who missed the deadline for reporting on the use of Provider Relief Funds for Reporting Period 1 that they would have to repay the funds. If the funds are not returned voluntarily, HRSA will initiate recovery of the funds. This has caused a stir in the healthcare community.
The American Medical Association (AMA) and other organizations wrote to HRSA asking for more time to report. The AMA indicated that providers need more time to comply, and many were unaware of the reporting deadline. One of the factors is the initial guidelines that were published when these funds suddenly appeared in provider bank accounts during the second quarter of 2020.
The reporting for Period 1 was based on funds received as of June 30, 2020. The report was to include eligible expenses attributable to coronavirus, those expenses used to prepare for, prevent and respond to coronavirus. A second factor was lost revenue. The reporting is based on the period of availability from January 1, 2020, to June 30, 2021. The initial reporting deadline was September 30, 2021, but it was extended to November 30, 2021. The reporting portal was opened again in December 2021 for an additional week.
It was reported by the Medical Group Management Association (MGMA) that approximately 10,000 providers were being asked to return funds for non-compliance. The total amount of funds was estimated to be approximately $100 million.
In response to the latest request by the AMA to reopen the reporting portal again for Period 1, the HRSA issued a statement on April 6, 2022, allowing for providers to submit a request to report late due to extenuating circumstances for Period 1. The following is a copy of the notice issued by the HRSA on April 6, 2022.
From: HRSA PRB Information <PRBInformation@hrsa.gov>
Date: April 6, 2022 at 4:37:44 PM EDT
To: HRSA PRB Information <PRBInformation@hrsa.gov>
Subject: HRSA Announces Opportunity for Providers to Report Late Due to Extenuating Circumstances
Dear Stakeholder,
Today, HRSA announced an opportunity for providers to submit a Request to Report Late Due to Extenuating Circumstances for Reporting Period 1. Below you will find additional information about the process to submit a late report in today’s provider notification.
Thank you in advance for sharing with your members and/or networks.
Provider Relief Bureau
Health Resources and Services Administration
United States Department of Health and Human Services
____________________________________________________________________________________________
Subject: Requests to Report Late Due to Extenuating Circumstances (Provider Relief Fund)
Dear Provider:
Some providers have informed the Health Resources and Services Administration (HRSA) that extenuating circumstances prevented them from submitting a completed Provider Relief Fund (PRF) report in Reporting Period 1. Today, HRSA is announcing an opportunity for providers to submit a Request to Report Late Due to Extenuating Circumstances for PRF Reporting Period 1 if one or more of the extenuating circumstances described below apply.
From Monday, April 11 to Friday, April 22, 2022 at 11:59 pm ET, providers who did not submit their Reporting Period 1 report by the deadline may request to submit a late Reporting Period 1 report, via a DocuSign form, if certain extenuating circumstances exist.
During this process, a provider will choose which extenuating circumstance(s) prevented them from meeting the reporting deadline. The allowable reasons that constitute extenuating circumstances are as follows:
- 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.
Requests to Report Late Due to Extenuating Circumstances must indicate and attest to a clear and concise explanation related to the applicable extenuating circumstance; however, supporting documentation will not be required. If HRSA approves the request, the organization will receive a notification to proceed with completing the Reporting Period 1 report. Providers will have 10 days from the date they receive the notification to submit a report in the PRF Reporting Portal.
Providers who plan to submit a Request to Report Late Due to Extenuating Circumstances and have not registered in the PRF Reporting Portal, should complete registration now. Registration instructions are on the PRF Reporting Webpage.
Please note that providers will also have an opportunity to submit a Request to Report Late Due to Extenuating Circumstances for Reporting Period 2 if the extenuating circumstances are applicable. Providers will receive a notification regarding the process to submit a request for RP2 in the coming weeks.
Where can I find more information?
For additional information, please call the Provider Support Line at (866) 569-3522; for TTY dial 711. Hours of operation are 8 a.m. to 10 p.m. Central Time, Monday through Friday.
Provider Relief Bureau
Health Resources and Services Administration
United States Department of Health and Human Services
Stay tuned for more information. We will keep you informed.
For any questions related to the CARES Act Provider Relief Fund, or healthcare reimbursement in general, contact Dave Macke, VonLehman’s Director of Reimbursement Services, at dmacke@vlcpa.com or 800.887.0437.
