Provider Relief Fund Updates: Reporting Period 1, Phase 4/Rural Application, Phase 3 Reconsideration, CLA Webinar

  • Health care and life sciences
  • 10/19/2021

Keeping up to speed on Provider Relief Fund dates and timelines can be a challenge. From deadlines to apply for additional PRF to upcoming reporting periods, we have...

What do September 30, 2021, October 26, 2021, November 12, 2021, and December 31, 2021 have in common? They are all dates you need to know related to Provider Relief Funds (PRF). Here is the run-down and key resources to help.


September 30, 2021 = Period 1 Reporting Deadline. 

We know many submitted their required reports for Period 1 PRF dollars by this date, but some may have needed to use the “grace period” provided by HRSA. While technically not an extension, HRSA announced a 60-day grace period to allow those who needed additional time to come into compliance with the reporting requirements. HRSA indicates that it will not initiate any enforcement actions during these 60 days. As such, the drop-dead date for PRF Period 1 reporting then is November 30, 2021. Reach out to a CLA advisor if you still have questions or need assistance.

October 26, 2021 = Deadline to Submit Phase 4 PRF, Rural Applications.

HRSA announced that $17 billion in PRF Phase 4 General Distribution money is now available. Health care providers must apply by 11:59PM ET October 26 to be considered. In addition, $8.5 billion will be concurrently available under the American Rescue Plan’s (ARP) rural fund.

PRF Phase 4 payments:

  • Include a base payment and potential bonus payment
  • For the base payment, 75% will be based on a percentage of a provider’s change in quarterly patient care operating revenues and expenses for July 1, 2020 – March 31, 2021. These quarters will be compared to the same quarters in 2019.
  • HRSA will use a banding process to determine small, medium, and large providers based on annual net patient care revenues. (Banding to be determined once all applications are in.) Large providers will receive a flat percentage amount. Small and medium will receive a flat percentage plus a supplemental percentage increase (% TBD)
  • For the 25% bonus potential, it will be based on Medicare, Medicaid/CHIP claims data from January 1, 2019 – September 30, 2020, which HRSA has access to already. HRSA will generally price Medicaid and CHIP claims data at Medicare rates.

ARP Rural Fund payments:

  • Determined on the rural location of patients
  • Based on existing Medicare, Medicaid, and CHIP services provided to rural patients between the dates of January 1, 2019 through September 30, 2020
  • Medicaid and CHIP claims will be priced generally at Medicare rates, with some limited exceptions
  • Applicants select whether they want to be considered for ARP rural
  • Applicants do not need to determine if patients are rural

Both Phase 4 and ARP rural funds have separate terms and conditions for allowable uses and related requirements. Both are under a short application cycle, so if you are interested in either of these funds, you should already be moving in that direction.


Did you miss CLA’s October 15, 2021 webinar on PRF Phase 4 and ARP rural application? No worries because you can watch it on demand. We are already assisting clients in working through the application process. Reach out if you need help.


November 12, 2021 = Deadline to Submit Phase 3 Reconsideration.

There were many questions related to the methodology used by HRSA for distributing Phase 3 PRF money. This was the result of various behind the scenes pre-payment mitigation tactics and other approaches used by HRSA of which providers were not aware. The result was that in some cases Phase 3 distributions varied wildly from what applicants anticipated. Therefore, HRSA released the full Phase 3 methodology and an opportunity for a Phase 3 reconsideration process.

If, after having reviewed the full Phase 3 methodology, you do not believe you received what you should have, you should submit a Phase 3 reconsideration request. Do so by November 12, 2021 at 11:59PM ET.

December 31, 2021 = Deadline to Use PRF Received During Period 2.

This date is the next deadline for you to use/expend any PRF that was received between July 1, 2020 – December 31, 2020. If you received PRF money during these six months, you will be in Reporting Period 2. You will then have 90 days — from January 1, 2022 – March 31, 2022 — to report on your use of these dollars.

Remember, you can use these PRF dollars for expenses and lost revenues (except nursing home infection control funds) between January 1, 2020 – December 31, 2021 that are due to “preparing, preventing and responding” to COVID-19 that have not been already offset by other sources. Review all the guidance and related PRF FAQs for details or contact your CLA advisor for assistance.  

How We Can Help

Across the health care spectrum, CLA has been actively assisting and advising clients on PRF and other COVID-19 relief funds. If you have a question, our PRF Advisory Team has likely heard it and worked on it. We are here to help. Reach out today.

This blog contains general information and does not constitute the rendering of legal, accounting, investment, tax, or other professional services. Consult with your advisors regarding the applicability of this content to your specific circumstances.

Experience the CLA Promise


Subscribe