Saltmarsh Siren: Upcoming Reporting Deadlines for HRSA Provider Relief Fund & American Rescue Plan Rural Distributions

3/8/2023 - By Andrew Kent, Esq., CVA, CHC

As a reminder, the PRF Reporting Period 4 opened on January 1, 2023, and will remain open through March 31, 2023. Reporting Period 4 covers PRF payments received between July 1, 2021, and December 31, 2021. Providers who received aggregated PRF payments of more than $10,000 should be prepared to report on their use of these funds. The Reporting Period 4 Period of Availability runs from January 1, 2020, through December 31, 2022.

In October HRSA published a Post-Payment Notice of Reporting Requirements for Provider Relief Fund and American Rescue Plan Rural Distributions payments. Significant updates include announcing future Reporting Periods 5, 6, and 7, together with the associated Periods of Availability and Reporting Time Periods. In addition, the notice provides important information concerning the data elements they are required to report. We recommend all providers who received either Provider Relief Fund or American Rescue Plan Rural Distribution payments review this notice.

HRSA has begun issuing Repayment Request Notices to providers who received Provider Relief Fund or American Rescue Plan Rural Distribution payment and who are required to return funds under certain circumstances. These circumstances could include:

Providers who rejected the Terms and Conditions in the PRF Application and Attestation Portal, but never returned funds.
Providers who failed to submit a required report must return all funds that were not reported on during a specific reporting period or the subsequent request to report late due to extenuating circumstances.
Providers deemed required to repay funds as a result of audit findings.
Providers deemed ineligible or non-compliant by indictment or other information not revealed through audit.

Providers will have 60 days from the date of the notice to return the funds or submit a request for Decision Review to dispute HRSA’s request for repayment. Providers who fail to take one of these steps may be subject to debt collection efforts.

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