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HHS issues long-awaited revised PRF guidance

June 15, 2021 Article 2 min read
Amanda Ward Dawn Stark

The U.S. Department of Health and Human Services issued updated Provider Relief Fund guidance. Here’s what you need to know.

Doctor in a lab coat reviewing information on a handheld tablet computer.On June 11, 2021, the Health Resources and Services Administration (HRSA), an agency of the U.S. Department of Health and Human Services (HHS), issued an updated Provider Relief Fund (PRF) General and Targeted Distribution Post-Payment Notice of Reporting Requirements (Notice). This Notice replaces all previous reporting requirements and applies to all past and future PRF General and Targeted Distributions.

Please be aware that the Skilled Nursing Facilities (SNF) and Nursing Home Infection Control Distributions are considered targeted distribution payments, which were not included in previous post-payment notices. The SNF and Nursing Home Infection Control Distributions include quality incentive program (QIP) payments.

The above-mentioned reporting requirements don’t apply to the Rural Health Clinic (RHC) COVID-19 Testing Program or the claims reimbursement from the HRSA COVID-19 Uninsured Program and the HRSA COVID-19 Coverage Assistance Fund (CAF).

Summary of PRF reporting requirements

The Notice provides the period of availability of funds, which is based on the date the PRF payment was received and provides related reporting time periods. The table below summarizes these items:

Graphic/table depicting provider relief funds.

The reporting deadlines apply to all recipients who received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period.

Please review the table carefully, as the deadline to use funds wasn’t entirely extended through Dec. 31, 2022. The extension is based on when your organization received funds, as noted in the table above. For example, funds received by providers between April 10 and June 30, 2020, must be used by June 30, 2021. Noncompliance with the Terms and Conditions, including reporting within the respective reporting time period, may result in recoupment of the relevant funds received.

Updated PRF reporting FAQs

HRSA updated the Reporting Portal FAQs and announced that the PRF Reporting Portal is expected to open on July 1, 2021. The FAQs provide additional information on the registration process as well as the information needed to complete registration.

In addition, HRSA updated the PRF FAQs to provide additional clarity on the funding as a whole, including the reporting process. Updates as of June 11, 2021 resulted in new FAQs and the removal of previous FAQs, including FAQs related to eligible expenses. It’s important that someone within your organization understand the impact of the revisions to the FAQs.

While this Notice confirmed single audit and other audit requirements for commercial organizations, we expect more guidance in the future. We encourage you to read the post-payment notice, reporting portal FAQs, and the revised PRF FAQs in their entirety to gain a thorough understanding of the implications to your organization. As you navigate RFP audit and reporting requirements, we’re here to help.

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