Provider Relief Fund Updates Surrounding Reporting Deadlines and Revisions of Reports Previously Submitted


More guidance has been issued surrounding the Provider Relief Funds. Specifically, these updates correspond with reporting deadlines and revisions of reports that were previously submitted.

Here’s the update on what you can expect.

Reporting Deadlines

Were you or the person responsible for your organization’s Provider Relief Fund (PRF) portal unable to meet the reporting deadline due to illness, miscommunication, natural disaster, or other extenuating circumstances?

On April 6, 2022, the Health Resources & Services Administration (HRSA) issued the latest round of updates to their FAQ document. They also added an additional page to their website related to the opportunity for PRF recipients to request permission to submit their PRF reporting after the original reporting due date, when extenuating circumstances exist.

In order to obtain an extension, recipients must electronically submit a Request to Report Late Due to Extenuating Circumstances form, which will be reviewed and approved or denied by HRSA. This extension request is available for all reporting periods, but requests for extension of Reporting Period 1 (i.e., reporting for PRF payments received between April 10, 2020 and June 30, 2020) must be submitted by April 22, 2022 at 11:59 p.m. EST.

Allowable extenuating circumstances identified by HRSA include the following:

  • Severe illness or death: a severe medical condition or death of a provider or key staff member responsible for reporting hindered the organization’s ability to complete the report during the Reporting Period.
  • Impacted by natural disaster: a natural disaster occurred during or in close proximity of the end of the Reporting Period damaging the organization’s records or information technology. 
  • Lack of receipt of reporting communications: an incorrect email or mailing address on file with HRSA prevented the organization from receiving instructions prior to the Reporting Period deadline.
  • Failure to click “Submit”: the organization registered and prepared a report in the PRF Reporting Portal but failed to take the final step to click “Submit” prior to deadline.
  • Internal miscommunication or error: internal miscommunication or error regarding the individual who was authorized and expected to submit the report on behalf of the organization and/or the registered point of contact in the PRF Reporting Portal.
  • Incomplete Targeted Distribution payments: the organization’s parent entity completed all General Distribution payments, but a Targeted Distribution(s) was not reported on by the subsidiary.

It is noted that the submission of a Request to Report Late Due to Extenuating Circumstances form does not guarantee that the request will be approved or that a provider will be allowed to enter the PRF Reporting Portal to complete and submit a report.

However, if your organization missed a reporting due date and does not submit a form or if your form is denied, your organization will remain non-compliant and will be required to return all funds to HRSA that were not reported on in the applicable reporting period.

If a request for extension is approved, providers will have 10 days from the date the notification is received to submit a report on the PRF Reporting Portal.

Revisions of Reports Previously Submitted

Now that most recipients have submitted the first two periods of PRF portal submissions, many have realized that there were errors in one (or both) of their original submissions. This commonality isn’t all that alarming, considering the unique components of the PRF terms and conditions, the consistent changes to the guidance surrounding them, and the challenge of trying to understand exactly how your information needed to be summarized and formatted on the PRF reporting portal.

On the additional page that HRSA added to their website, HRSA has provided reference to an opportunity to revise a previously submitted report. When referencing the electronic form that needs to be submitted to request approval for late submission, HRSA goes on to say “Providers may not utilize the Request to Report Late Due to Extenuating Circumstances process to request an opportunity to make edits or adjustments to an already submitted report. Contact the Provider Support Line at 866.569.3522 for assistance regarding revising a submitted report.”

If your organization is one of the many recipients that have realized an error in a previously submitted report and your organization believes that the error merits revision, your organization would be encouraged to reach out to the PRF Provider Support Line. Correcting an error in a previously submitted report may allow for the retention of funds that were otherwise required to be paid back or could be the difference in avoiding a qualified audit opinion, if your organization is required to have a PRF compliance audit.

Our Provider Relief Fund team has developed expertise in guiding healthcare leaders through PRF reporting and compliance.

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