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Request to Report Late Due to Extenuating Circumstances - PRF Reporting Period 2 Recipients—submit your report if you are required to report no later than May 18, 2022!
Provider Relief Funds Reporting Requirements - Submit Request to Submit a Late Report Due to Extenuating Circumstances by April 22!
APMA is very pleased to announce that the HRSA has re-opened the Provider Relief Fund Reporting Portal for PRF recipients who were unable to report during Reporting Period 2 because of extenuating circumstances. HRSA took this action after hearing from APMA and other member associations, whose members expressed their serious concerns about the Period 1 funding they received being recouped despite good faith intents to report and the impact it would have on their practices. In order to report, providers will need to submit a Request to Report Late Due to Extenuating Circumstances before midnight on Wednesday, May 18. HRSA lists the following extenuating circumstances that would allow a PRF recipient to belatedly report for PRF monies:
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.
Process
Providers can find the process for submitting a Late Report Request via HRSA’s website. If you have not already registered for the PRF Reporting Portal, you will need to do so prior to submitting your request. Registration instructions are on the PRF Reporting webpage. In your late report request, you must indicate and attest to a clear and concise explanation related to the applicable extenuating circumstance; however, supporting documentation will not be required, and HRSA will notify you directly if your request is approved or denied. If your request is approved, you will received a notification to complete the report, which must be done within 10 days of receiving the notification. Providers whose Request to Report Late Due to Extenuating Circumstances is denied will remain non-compliant with the Terms and Conditions and will be required to return all funds to HRSA that were not reported on in the applicable reporting period. Review the Returning Funds webpage for additional details.
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.
Payment Received Period (Payments Exceeding $10,000 in Aggregate Received)
Deadline to Use Funds
Reporting Time Period
Request to Late Report Due to Extenuating Circumstances
Period 1
From April 10, 2020 to June 30, 2020
June 30, 2021
July 1 to September 30, 2021*
Now closed
Period 2
From July 1, 2020 to December 31, 2020
December 31, 2021
January 1 to March 31, 2022
Yes - May 2 - May 18, 2022 If request is approved, you have 10 days from the notification to complete your report.
Period 3
From January 1, 2021 to June 30, 2021
June 30, 2022
July 1 to September 30, 2022
n/a
Period 4
From July 1, 2021 to December 31, 2021
December 31, 2022
January 1 to March 31, 2023
n/a
Period 5
From January 1, 2022 to June 30, 2022
June 30, 2023
July 1, 2023 to September 30, 2023
n/a
* Please note, HHS has extended this deadline to November 30 as a grace period, and providers who do not report by September 30 will still be considered out of compliance. However, no collection activities or similar enforcement actions will be initiated during this 60-day grace period.
Reporting Period 1 and 2 Resources
APMA has worked with Hart Health Strategies to create a webinar during the first Reporting Period 1 for members to assist in navigating reporting, as well as a detailed summary.
Podiatrists who have gone through the reporting process recommend accessing the following documents and information prior to reporting:
Any interest earned on the PRF payments
Other sources of assistance received (e.g., SBA, FEMA, business insurance, local and tribal government assistance)
PRF expenses totals for general and administrative expenses, as well as health-care-related expenses from Q1 2020 through Q2 2021
Total revenues from 2019 and 2020
Number of part-time, full-time, and contractor clinical and non-clinical employees from Q1 2019 through Q2 2021
Number of furloughed, separated, and hired part-time, full-time, and contractor clinical and non-clinical employees from Q1 2019 thru Q2 2021
Number of patient visits from Q1 2019 thru Q2 2021
Included in this round was $25.5 billion in new funding for providers affected by the COVID-19 pandemic, specifically those who serve rural Medicaid, Children’s Health Insurance Program (CHIP), or Medicare patients, in addition to providers who are able to document revenue loss and increased operating expenses associated with the pandemic. Lost revenue and expenses will be calculated from the period of July 1, 2020, to March 31, 2021. To see if you qualify for areas deemed “rural,” view theRural Health Grants Eligibility Analyzeron the HHS website.
On December 14, HHS announced the distribution of approximately $9 billion PRF Phase 4 payments to health-care providers who have experienced revenue losses and expenses related to the COVID-19 pandemic. The average payment announced for small providers was $58,000, for medium providers was $289,000, and for large providers was $1.7 million. More than 69,000 providers in all 50 states, Washington, DC, and eight territories will receive Phase 4 payments. Payments for this distribution will start by December 17, 2021.
HHS released the Phase 4 payment methodology in September, making it available to providers during the application period. Approximately 75 percent of Phase 4 funding is being distributed based on expenses and decreased revenues from July 1, 2020, to March 31, 2021. HHS is reimbursing a higher percentage of losses and expenses for smaller providers—which generally entered into the COVID-19 pandemic on worse financial footing, have historically operated on slimmer financial margins, and typically care for vulnerable populations—as compared to larger providers.
HHS is distributing the remaining 25 percent of Phase 4 funding as “bonus” payments based on the amount and type of services provided to Medicare, Medicaid, or CHIP patients. Similar to the American Rescue Plan (ARP) Rural payments announced last month, HHS is using Medicare reimbursement rates in calculating these payments to mitigate disparities due to varying Medicaid reimbursement rates.
Additionally, HHS has updated the Terms and Conditions for Phase 4 and ARP Rural payments to ensure relief funds are being used to address the financial impact of COVID-19. Recipients whose payment(s) exceed $10,000 are required to notify HHS of a merger with or acquisition of any other health-care provider. Providers who report a merger or acquisition may be more likely to be audited to ensure compliant use of funds.
HHS is currently reviewing the remaining Phase 4 applications and will make the remainder of Phase 4 payments in 2022.
Terms and Conditions
Recipients of Provider Relief Fund payments must agree to the Terms and Conditions specific to the distribution in which they received a payment or reimbursement.
Providers must attest to program Terms and Conditions in order to receive payment, such as:
Eligible providers may use funds to prevent, prepare for, and respond to coronavirus, and for related expenses or lost revenues attributable to coronavirus.
Funding cannot be used where another source has reimbursed or is obligated to reimburse those expenses or losses.
Payments can be pre-payments, prospective, or retrospective payments.
Provider and payment information for entities that have attested to at least one payment is posted to an HHS Public Use File (PUF)
Phase 3 - Phase 3 General Distribution Relief Fund Terms and Conditions: The recipients have received a payment appropriated as part of Phase 3 General Distribution, including Medicaid, CHIP, dental, assisted living facilities, behavioral health and other providers.
Targeted Distribution
COVID-19 High-Impact Payments High Impact Area Relief Fund Payment Terms and Conditions: The recipient has received payment from funds appropriated as part of the targeted allocations known as the High Impact Area Targeted Distribution.
Rural Payments
Rural Targeted Distribution: The recipient has received payment from funds appropriated as part of the targeted allocations known as the Rural Targeted Distribution.
In reviewing the terms and conditions, there are a few key items for providers to consider, as detailed below.
Possible or actual cases. Providers must attest that they “[provide] or provided after January 31, 2020, diagnoses, testing, or care for individuals with possible or actual cases of COVID-19.” The initial terms and conditions did not include the specific date. While this information is not included in the terms and conditions, HHS on its website further noted that “HHS broadly views every patient as a possible case of COVID-19.” With the addition of the date and the HHS clarification, providers may be able to attest to this requirement if they treated any patient after January 31, whether via telehealth or in person.
Reallocating funds. At this time, there is a not a process to allow an entity to reallocate the funds to different a TIN in light of changes in ownership or new providers. This situation is a particular issue given that the legacy TINs may not be able to attest to the ability to treat patients and, as such, may have difficulty in attesting to retain the funds.
Bans balanced billing. In essence, to retain the funds, a provider must not balance bill for “all care for a presumptive or actual case of COVID-19.” For those patients, the provider must not seek from the patient more than the patient would have been obligated to pay if the provider was an in-network provider. While it is still unclear which cases would be “presumptive or actual” cases, one could attest that this subset of patients is different from “possible or actual” (which is essentially all patients) but would still apply to all patients in that subset, regardless of payer. And, given that this language does not have a similar date qualifier (i.e., the January 31 date), it is unclear when HHS expects the balance billing requirement to be in effect. This situation is particularly troubling, given that, so far, there has been no discussion regarding the amount of payment required.
Note that the secretary has concluded that the COVID-19 public health emergency has caused many health-care providers to have capacity constraints. As a result, patients who would ordinarily be able to choose to receive all care from in-network health-care providers may no longer be able to receive such care in-network. Accordingly, for all care for a presumptive or actual case of COVID-19, the recipient certifies that it will not seek to collect from the patient out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network recipient.
No other reimbursement. One additional requirement is that the “recipient certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse.” Unfortunately, HHS did not provide enough information for providers to easily untangle how to provide appropriate accounting for these items, especially given that many health-care services may be under additional obligations (e.g., Medicare payment for certain telehealth services), interactions with other government programs (e.g., the Paycheck Protection Program), etc.
Salary cap. The funds provided cannot be used to “pay the salary of an individual, through a grant or other extramural mechanism, at a rate in excess of Executive Level II.” According to OPM, Executive Level II is $197,300 for 2020. On its website, HHS has stated that “these are payments, not loans” but has not clarified whether this is an “extramural mechanism” subject to this restriction.
Use of funds. Another key requirement is that the “recipient certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus, and shall reimburse the recipient only for health-care related expenses or lost revenues that are attributable to coronavirus.” This requirement is confusing at best, and it seems virtually impossible to use the fund at the same time for both care and lost revenue. Therefore, additional clarity is needed, especially in light of the extensive reporting requirementsfor the program.
Not an exhaustive list. The terms and conditions include a statement that “[t]his is not an exhaustive list and you must comply with any other relevant statutes and regulations, as applicable.” Further, the notice states that “[n]on-compliance with any term or condition is grounds for the secretary to recoup some or all of the payment made from the Relief Fund.”
Subcontractors. Another key statement is that “[t]hese terms and conditions apply directly to the recipient of payment from the Relief Fund. In general, the requirements that apply to the recipient, also apply to subrecipients and contractors, unless an exception is specified.”
Additional language from $20 billion allocation. The additional language in the terms and conditions for the second tranche (e.g., $20 billion allocation) is as follows: “The recipient shall also submit general revenue data for calendar year 2018 to the secretary when applying to receive a payment, or within 30 days of having received a payment. The recipient consents to the Department of Health and Human Services publicly disclosing the payment that recipient may receive from the Relief Fund. The recipient acknowledges that such disclosure may allow some third parties to estimate the recipient’s gross receipts or sales, program service revenue, or other equivalent information.”
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