On April 10, 2020, the Health Resources and Services Administration (HRSA) swiftly distributed the first Provider Relief Fund (PRF) payments to Medicare providers’ bank accounts and now more than three years later—June 5, 2023—as quickly as they began, PRF payments now end, as a result of the Fiscal Responsibility Act of 2023 (a.k.a. the bipartisan debt ceiling agreement).

HRSA officially announced June 5, 2023 on the PRF website: “… no further payments will be made to providers under the Provider Relief Fund or American Rescue Plan Rural distribution, including no reconsideration payments. Likewise, no additional claims payments will be made under the Uninsured Program or Coverage Assistance Fund. Per the Terms and Conditions of each Program, all reporting and auditing requirements will continue without disruption.”

The PRF monies and subsequent American Rescue Plan (ARP) Rural fund dollars were a lifeline to providers who scrambled to purchase personal protective equipment in previously unforeseen quantities while in the midst of extreme shortages; to incentivize staff to remain working serving older adults in nursing homes, assisted living communities, life plan communities and in their own homes delivering home and community based services even through adversity and uncertainty, and were used for myriad other purposes that arose over the more than three years since the pandemic began.

Regrettably, the funds appropriated for PRF were unable to complete their important purpose in helping health care providers weather the incomprehensible financial hurdles they encountered.  Some providers have waited for years for decisions on their reconsideration requests where they were erroneously denied funds in Phases 3 and/or 4. Sadly, the lifeline for these providers won’t be coming.

While funding has officially ended, providers who received payments on or after January 1, 2022, are still required to submit reports for how the PRF and/or ARP Rural payments were used.

LeadingAge reminds members that HRSA changed the reporting requirements related to using PRF and/or ARP Rural for lost revenues in October 2022. This policy limits the use of PRF and ARP Rural payments only to lost revenues incurred through June 30, 2023. An article with further details on the lost revenue change can be found here.

While the PHE may have ended, COVID-19 has not. Providers can still use PRF for expenses incurred to prevent, prepare for and respond to COVID-19 beyond the end of the Public Health Emergency (PHE) (May 11,2023).  We anticipate, however, that even COVID-related expenses incurred post-PHE may be more highly scrutinized than those incurred during the heart of the pandemic. COVID-19 tests and supplies, PPE, etc. should continue to be clearly covered but it is not clear how staff bonuses, or other incentives might be viewed now that the pandemic has ended and vaccines are available. Both HRSA and the Office of the Inspector General are auditing providers’ PRF payments to make sure they were used appropriately. These audits will go more smoothly if providers can explain how their organization used these funds and how the expense relates to COVID-19. For this reason, members are encouraged to thoroughly document their rationale for the expenditures—how they related to preparing for, preventing and respond to COVID 19. Remember PRF can be used for COVID-19 expenses incurred at any point during the pandemic. All the way back to January 1, 2020 and through the entire Period of Availability associated with the Payment Received Period. See the chart below for the remaining reporting periods, revised periods of availability and reporting deadlines.

Finally, providers whose reports show they didn’t spend their entire PRF and/or ARP Rural fund distribution will be required to return the remaining funds to HRSA.