HRSA Reopens Provider Relief Reporting

Physicians who accepted federal COVID-19 relief funds but failed to meet the Period 1 Provider Relief Fund reporting requirements now have more time to comply.

The Health Resources & Services Administration (HRSA) recently announced that healthcare providers can now submit a Request to Report Late Due to Extenuating Circumstances Form for Reporting Period 1 (RP1). All requests for RP1 must be submitted by Friday, April 22, at 11:59 p.m. ET.

The fund provided up to $178 billion in relief funds for healthcare providers who lost revenue and expenses due to the pandemic. The relief was approved as a part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. HSRA distributed $42.8 billion in the first phase, which began April 10, 2020.

Providers who received more than $10,000 between April 10, 2020, and June 30, 2020, were required to report how the money was spent by the end of September 2021. The agency then pushed the initial deadline by 60 days and granted providers a 60-day grace period to come into compliance before beginning enforcement. Many physicians did not know they needed to file a report or failed to complete the required paperwork during the late fall when the Delta variant was on the rise.

According to an article in Bloomberg “Reminder emails about reporting requirements went to some facilities’ spam folders or to staffers who initially accepted the money but ended up leaving their jobs, according to the Medical Group Management Association, which represents healthcare practices and providers.”

While the money is a grant that does not need to be repaid, HRSA said it will initiate the recovery of all funds not reported on and providers would be ineligible for future payments.

For each Reporting Period, a provider may request to complete their report after the reporting period deadline based on proof that one of the following allowable extenuating circumstances applies at the time of the deadline:

• Severe illness or death – a severe medical condition or death of a provider or key staff member responsible for reporting prevented the organization from completing 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.

The process is as follows:

• Providers considered non-compliant will be notified by HRSA after the end of the Reporting Period and will be given details on how to submit a Request to Report Late Due to Extenuating Circumstances.
• Providers who plan to submit a Request to Report Late Due to Extenuating Circumstances, but have not registered in the PRF Reporting Portal, should complete registration prior to submitting their request. Registration instructions are on the PRF Reporting webpage.

• Providers will submit a Request to Report Late Due to Extenuating Circumstances Form that clearly and concisely explains the applicable extenuating circumstance. Supporting documentation will not be required.

• Providers must attest to the truthfulness and accuracy of their extenuating circumstance(s) within the Form.

• Providers who submit a Request to Report Late Due to Extenuating Circumstances will be notified by HRSA if their request is approved or denied.

• Providers whose request is approved will receive a notification to proceed with completing the report. Providers will have ten days from the date the notification is received to submit a report in the PRF Reporting Portal.

Requests can be submitted from April 11 to April 22 at 11:59 p.m. ET

The Health Law Offices of Anthony C. Vitale can assist affected providers navigate the complexities of the reporting mandates. Give us a call at (305) 358-4500 or email info@vitalehealthlaw.com to discuss how we can assist.