Provider Relief & ARP Rural Changes

Those who have received Provider Relief Funds (PRF) have already been through up to three reporting periods. And while those reporting requirements have remained relatively stable this past year, HRSA is shaking things up for future reporting periods now that American Rescue Plan (ARP) Rural funds will be included.

In today’s blog we give you a preview of what you need to know as you prepare for 2023 reporting. You will also want to register for CLA’s December 15 webinar that will cover these changes plus additional insights into single/program audits.

Webinar registration link HERE, and on CLA’s events webpage. 

Revised Reporting Requirements

On October 27, 2022, HRSA released a revised Post-Payment Notice of Reporting Requirements and supplemented those with new or revised FAQs. Key changes include the:

• Addition of three new future reporting periods
• Creation of ARP Rural reporting requirements
• Changes to the reporting portal itself
• Explanation that lost revenue usage will end once the public health emergency ends

Reporting Period (RP) 4

Reporting Period 3 recently wrapped up at the end of September. The next reporting period is RP 4. As a reminder, the dates you need to know for RP 4 are:

• PRF and/or ARP Rural received between July 1, 2021 – Dec. 31, 2021, fall into RP 4
• These dollars must be used (ie: their period of availability) by Dec. 31, 2022
• You must report on these RP 4 dollars between Jan. 1, 2023 – Mar. 31, 2023

As you plan to report on these dollars, it is important to understand the differences between PRF money and ARP Rural dollars. While both generally follow similar Terms & Conditions, they are NOT identical. (Further, their Terms & Conditions are also not identical to past PRF distribution Terms & Conditions.) The most important difference with ARP Rural’s Terms & Conditions and PRF is that ARP Rural may not be moved between Parent/Subsidiaries beyond a Parent TIN sending those funds to the qualifying TIN.

To understand what this means we need to remember that ARP Rural funds were calculated using historical claims data. Therefore, ARP Rural dollars attach to specific patient claims, and by extension, to a specific TIN that delivered care to those patients. This TIN is referred to by HRSA as the “qualifying TIN.” If a Parent TIN received ARP Rural for a qualifying TIN, it must send the money to that TIN. However, in these situations HRSA will require the Parent TIN to report on those dollars even though only the qualifying TIN can justify and use those dollars.

Single, Program And Additional Audits

Our upcoming webinar will also provide information on the single or program audit requirements. Interestingly, HRSA also just announced a new commercial audit reporting portal that can be used for submissions by for-profit entities. Not-for-profit entities will still be required to submit single audits to the Federal Audit Clearinghouse.

Since we are now through the first wave of single/program audits, we have seen some common compliance findings. We’ll talk through these general errors during our webinar while also discussing the process HRSA uses to resolve findings.

Compliance Tips

Health care providers and organizations should be aware that when $178 billion in funding is distributed, there will be many other audits in addition to the single/program audit. Those can include audits done by Health & Human Services Office of the Inspector General (OIG), the federal Government Accountability Office (GAO), HRSA’s own payment integrity audits, and the Department of Justice (DOJ).

Ensuring robust compliance is important. Here are some compliance tips as you move through the rest of 2022 and prepare for 2023.

• Make sure you understand the specific requirements for each federal award received. Re-read the Terms & Conditions for each PRF or ARP Rural distribution because they are not always identical
• Assemble, organize, and house all supporting documentation in a common location so it is easy to locate.
• Double-check everything. Ensure you have supporting documentation for every expense and that you have not double-counted that expense. Make sure your revenue numbers include (or exclude) what they should and that you follow the requirements for reporting under each lost revenue Option (1-3).  
• Confirm you treated all “presumptive or actual” COVID-19 patients as in-network (ie: prohibition on balance billing out-of-network costs).
• Review claims you sent to the COVID-19 Uninsured Program and/or COVID-19 Coverage Assistance Program to confirm they met the requirements for those reimbursements.
• Seek legal counsel before responding to DOJ, OIG, GAO.

How We Can Help

CLA has worked with health care organizations and individuals across the continuum on their PRF and ARP Rural funds (plus PPP, ERC and many other COVID dollars). We hope you reach out if you need assistance.

We look forward to having you join us on our December 15 webinar.