Announcing 60-Day Grace Period – PRF Reporting Period 1

The September 30, 2021 Reporting Period 1 deadline has not changed; however, in response to challenges providers are facing given the COVID surges and natural disasters around the country, a 60-day Grace Period through November 30, 2021, is now in place. This period allows providers to come into compliance with their PRF reporting requirements should they fail to meet the September 30, 2021 deadline.

Important Details: 

  • While you will be out of compliance if you do not submit your report by September 30, 2021, recoupment or other enforcement actions will not be initiated during the 60-day grace period (October 1 – November 30, 2021).
  • The grace period begins on October 1, 2021, and will end on November 30, 2021.
  • Providers who are able to are strongly encouraged to complete their report in the PRF Reporting Portal by September 30, 2021.
  • Providers should return unused funds as soon as possible after submitting their report. All unused funds must be returned no later than 30 days after the end of the grace period (December 30, 2021).

This grace period only pertains to the Reporting Period 1 report submission deadline. There is no change to the Period of Availability for use of PRF payments.

Click here or contact your HW Healthcare Advisor if you need help with your PRF reporting.

New Provider Relief Funding Available

The Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), announced $25.5 billion in new funding for healthcare providers affected by the COVID-19 pandemic. This funding includes $8.5 billion in American Rescue Plan (ARP) resources for providers who serve rural Medicaid, Children’s Health Insurance Program (CHIP), or Medicare patients, and an additional $17 billion for Provider Relief Fund (PRF) Phase 4 for a wide range of providers who can document revenue loss and expenses associated with the pandemic.

Applications open on September 29, 2021. To streamline the application process and reduce administrative burdens, providers will apply for both programs in a single application and HRSA will use existing Medicaid/CHIP and Medicare claims data in calculating portions of these payments.

  • Phase 4 General Distribution— $17 billion based on providers’ lost revenues and changes in operating expenses from July 1, 2020, to March 31, 2021.
    • To promote equity and to support providers with the most need, HRSA will:
      • Reimburse a higher percentage of lost revenues and expenses for smaller providers as compared to larger providers.
      • Provide “bonus” payments based on the amount of services they provide to Medicaid, CHIP, and Medicare patients, priced at the generally higher Medicare rates.
  • American Rescue Plan (ARP) Rural — $8.5 billion based on the amount of services providers furnish to Medicaid/CHIP and Medicare beneficiaries living in Federal Office of Rural Health Policy (FORHP)-defined rural areas.
    • To promote equity, HRSA will price payments at the generally higher Medicare rates for Medicaid/CHIP patients.

Prepare To Apply

  • Review eligibility information posted on the PRF Future Payments web page and additional details will be announced before September 29.
  • Search the Rural Health Grants Eligibility Analyzer to see what areas qualify as “rural” for the ARP rural payments.
  • Gather supporting documents, such as most recent tax documents and financial statements for the second half of calendar year (CY) 2020 and the first quarter of CY 2021.

PRF Phase 3 Reconsiderations

There have been questions related to how HRSA calculated the PRF Phase 3 payments. To promote transparency in the PRF program, HHS also released detailed information about the methods used to calculate Phase 3 payments on September 10th. Providers who believe their Phase 3 payment was not calculated correctly according to this methodology will have an opportunity to request a reconsideration. Further details on this Phase 3 reconsideration process are forthcoming.

Additional resources and information can be found on the PRF Reporting Webpage

We will keep you posted as more is known. HW&Co. is here to assist you in any way we can. Please visit the HW&Co. COVID-19 resource center on our website for additional resources or contact your HW Healthcare Advisor if you need assistance.

Disclaimer:  Information in this article is subject to change and is based upon our current understanding as of the issue date. This is a constantly evolving process as HHS has been issuing new or changed guidance on a frequent basis.

Paula Z.Reape, CPA, LNHA
Principal
preape@hwco.com