For the past two years, healthcare clinicians and facilities have received financial assistance from the federal government through the Provider Relief Fund to help cover the costs and losses related to the COVID-19 pandemic.
While the nation is still under a public health emergency, the relief funding is beginning to dry up, and providers who miss reporting requirements may be forced to return funds or face consequences. Here is an overview of recent Provider Relief Fund program changes and deadlines.
Provider Relief Fund
The Provider Relief Fund (PRF) was established in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The CARES Act itself provided $100 billion for the fund, with $75 billion added through the Paycheck Protection Program and Health Care Enhancement and $3 billion from the Consolidated Appropriations Act, 2021. An additional $7.5 billion was earmarked for providers and suppliers who serve rural Medicaid, Children’s Health Insurance Program (CHIP), and Medicare beneficiaries through the American Rescue Plan (ARP).
The PRF is administered through the Health Resources and Services Administration (HRSA). To date, HRSA has completed three general distributions, along with targeted distributions for the following:
- COVID-19 High-Impact Area Distributions
- Rural Distributions
- Allocation for Skilled Nursing Facilities
- Nursing Home Infection Control Distribution (formally known as the Skilled Nursing Facility and Nursing Home Infection Control Distribution)
- Tribal Hospitals, Clinics, and Urban Health Centers/Indian Health Service Providers
- Safety Net Hospitals
- Children’s Hospitals
Most recently, HRSA began distributing ARP Rural payments in November 2021 and Phase 4 general payments in December 2021. Applications for these distributions are no longer being accepted. However, about 11 percent of the applications for Phase 4 payments still need to be processed, with the goal of completing those in May 2022. HRSA has distributed most of the Rural fund payments.
To learn more about Phase 4 and ARP Rural Distributions, visit HRSA’s Provider Relief Fund Current and Future Payments webpage.
While the deadline for reconsideration of earlier distributions has passed, recipients of Phase 4 general payments and ARP Rural payments who believe their payment was not calculated correctly based on HRSA’s published methodology can request reconsideration.
Once a reconsideration is requested, HRSA will review the original Phase 4/ARP Rural application again and will request any clarifying information, as needed. Providers may not revise or correct their submitted application. Deadline is May 2.
To learn more about requesting a reconsideration, visit HRSA’s Provider Relief Fund Payment Reconsideration page.
PRF payments from each tranche must be spent within specified periods, and providers who received one or more PRF payments exceeding $10,000, in aggregate, during specified periods are required to report on how the money was used. Those periods are as follows:
|Reporting Period||Funds Received||Deadline to Use Funds||Reporting Period||Return Funds Deadline|
|Period 1||April 10, 2020 to June 30, 2020||June 30, 2021||July 1, 2021 to November 30, 2021||December 30, 2021|
|Period 2||July 1, 2020 to December 31, 2020||December 31, 2021||January 1, 2022 to March 31, 2022||April 30, 2022|
|Period 3||January 1, 2021 to June 30, 2021||June 30, 2022||July 1, 2022 to September 30, 2022||October 30, 2022|
|Period 4||July 1, 2021 to December 31, 2021||December 31, 2022||January 1, 2023 to March 31, 2023||April 30, 2023|
|Period 5||January 1, 2022 to June 30, 2022||June 30, 2023||July 1, 2023 to September 30, 2023||October 30, 2023|
To learn more about PRF reporting, along with instructions for how to file your own report, visit the Provider Relief Fund Reporting Requirements and Auditing webpage.
Providers who fail to submit reports by the specified deadlines may be required to return the funds. For instance, according to Fierce Healthcare, providers who failed to submit Period 1 reports by November 30, 2021, began to receive notices from HRSA in early March, indicating that “they would have 30 days to repay funds before the agency would ‘initiate the recovery of all funds not reported on’ during the first reporting period.”
After public outcry from the American Medical Association, the Medical Group Management Association, and other industry groups about the clawback of PRF money, HRSA announced they will provide an opportunity for non-compliant providers to complete a report as a result of specific extenuating circumstances, with further details forthcoming on their website.
However, HRSA also posted that providers who were required to report in Reporting Periods 1 and 2 but did not
- are out of compliance with the PRF Terms and Conditions,
- must return Payment Period 1 and 2 PRF payment(s) to HRSA, and
- will be excluded from receiving and/or retaining future PRF payments – including any applicable Phase 4 payments.
Providers may also be required to return payments if they reject a payment in the PRF Application and Attestation Portal or have remaining unused funds that cannot be expended on allowable expenses or lost revenues attributable to coronavirus by the applicable deadline to use funds for each reporting period.
For more information about returning funds, along with specific instructions for doing so, visit the Provider Relief Fund Returning Funds webpage.
COVID-19 Coverage Assistance Fund and Uninsured Program
In addition to the Provider Relief Fund, HRSA established the Uninsured Program (UIP) and the COVID-19 Coverage Assistance Fund (CAF) to compensate providers and facilities who provided testing, treatment, and vaccine administration for the uninsured. These programs were funded with $4.8 billion from the American Rescue Plan, along with $2 billion from the Families First Coronavirus Response Act (FFCRA) Relief Fund.
However, both of these funds are nearly depleted and claims can no longer be filed. The last day to submit claims for testing and treatment to the COVID-19 Uninsured Program was March 22, 2022. The last day to submit vaccination claims to the COVID-19 Uninsured Program and COVID-19 Coverage Assistance Fund was April 5, 2022.
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