HHS Changes Reporting Requirements for PRF Payments

Arent Fox

Arent Fox

Take note, all providers who received Provider Review Fund (PRF) payments – there are changes in the reporting deadlines and requirements. On June 11, the Department of Health and Human Services announced that it was extending the reporting deadlines for PRF payments that were received by providers after June 30, 2020.

The Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 allocated $178 billion for the PRF. Today, all but approximately $24 billion has been distributed. The PRF played and continues to play an essential role in steadying the provider industry as the pandemic forced physicians’ offices, hospitals, and other providers to close or discontinue elective procedures. As a result, the provider industry has pointed out that more time is needed to deploy their payments as the financial and operational consequences of the pandemic are still becoming known.

The initial spending deadline for PRF monies was June 30, 2021. Funds not spent by then were required to be returned. The update provides a rolling deadline for using the funds, depending on when the payment was received.

Before the latest update, reporting was required if a provider received more than $10,000 in total from the PRF. Recipients are required to report for each “Payment Received Period” in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments).

The revised reporting periods and corresponding deadlines are:

                                 Payment Received Period (Payments Exceeding $10,000 in Aggregate Received) Deadline to Use Funds Reporting Time Period
Period 1 From April 10, 2020 to June 30, 2020 June 30, 2021 July 1 to Sept. 30, 2021
Period 2 From July 1, 2020 to December 31, 2020 Dec. 31, 2021 Jan. 1 to Mar. 31, 2022
Period 3 From January 1, 2021 to June 30, 2021 June 30, 2022 July 1 to Sept. 30, 2022
Period 4 From July 1, 2021 to December 31, 2021 Dec. 31, 2022 Jan. 1 to Mar. 31, 2023

The PRF reporting portal was opened for provider registration on January 15, 2021, but HHS has not yet permitted submission of reports while it considered updates to its reporting requirements. The portal is scheduled to be fully operational starting July 1. Updated reporting procedures are detailed here. The reporting requirements do not apply to the Rural Health Clinic COVID-19 Testing Program, the HRSA uninsured program, or COVID-19 coverage assistance funds.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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