PRF Deadlines, Next Steps

While attention to COVID-19’s Provider Relief Funds (PRF) may have waned, there are ongoing dates and requirements to keep in mind.

Quick Background

Various COVID-19 funding packages included a total of $178 billion in PRF. The dollars were designated for health care organizations/providers and administered by the Health Resources & Services Agency (HRSA). HRSA began distributing the money in April of 2020 through “general” or “targeted” distributions. Tip: The general vs. targeted distinction does matter, so it is important for recipients to understand whether each PRF distribution is one or the other.

Several general terms and conditions providers must meet:

• Provide after January 31, 2020, diagnoses, testing, or care for individuals with possible or actual cases of COVID-19. HRSA later gave a broad definition of “possible” cases of COVID to include all patients.
• Use funds to “prepare, prevent and respond” to the COVID pandemic.
• Use funds for allowable COVID expenses and/or lost revenues as long as those have not been been reimbursed by other sources (no double-dipping).
• Submit any required reports.

Tip: there are many more details beyond the above list that recipients must know for compliance. For example, the targeted nursing home infection control distributions can’t be used on lost revenues. 

PRF Reporting Periods

There are now five reporting periods. See HRSA chart below. Recipients with more than $10,000 in PRF in any of the five payment received periods must report in that period. This means recipients could be required to report in multiple periods. PRF is considered received as of the ACH transfer date or date the check was cashed. Tip: It continues to be important to know the exact date each PRF distribution was received because it determines which reporting period is required.

Period 1 and Period 2 reporting have closed. We are now nearing the end of the Period 3 period of availability. Tip: The period of availability is the deadline to use PRF received in the respective period.

Reporting Updates

While the reporting window for Period 1 is over, some recipients failed to report in time due to various circumstances. To its credit, HRSA allowed an opportunity to request a late submission due to “extenuating” circumstances. HRSA is also allowing the same for failure to report in Period 2. Here’s what you need to know about both:

• Period 1 Extenuating Circumstance/Late Report. The opportunity to apply for this has closed. However, HRSA announced that those who did apply will begin receiving notification the week of May 9 if they were approved for late submission. They will have 10 days to submit a report once HRSA approval is received.
• Period 2 Extenuating Circumstances/Late Report. HRSA just announced an opportunity for anyone who missed their Period 2 reporting (which ended March 31, 2022) to request a late submission. A request for late reporting must be made to HRSA by Friday, May 13, 2022 by 11:59pm ET. Review details and the request form at Request to Report Late Due to Extenuating Circumstances | HRSA

We are currently in Period 3 which covers any PRF received between January 1, 2021 – June 30, 2021. If you received PRF during this time period, you have until June 30, 2022, to expend/use those dollars. You must then report on those funds between July 1 – September 30, 2022, if in excess of $10,000.

Next Steps, How CLA Can Help

CLA has been assisting many health care providers – from health care systems, rural hospitals, physician practices, nursing homes, life plan communities, non-profits and more – since the beginning of PRF. We hope you will reach out if you or your organization needs assistance. In the meantime, here are a few suggested next steps:

1. Check and double-check that you reported on Period 2 funds. If not, you only have until May 13 to request a late submission from HRSA. 
2. Did you receive PRF funds in Period 3? Make sure you have expended those funds by June 30, 2022, on appropriate COVID-19 related expenses or lost revenues.
3. Are you ready to report on Period 3 beginning July 1, 2022? Make sure you know specific requirements on your PRF distributions, have those tracked, documented and accounted for appropriately.
4. Will you need a PRF audit (single audit or for-profit audit)? If you have questions on what this means or need assistance with either of these required audits, please reach out to a CLA advisor.

As always, reach out to CLA for assistance with all things PRF (or any other COVID-19 funding). We are here to know you and help you.