Specifically, HRSA indicated that providers can wait to report certain expenses for future reporting periods because “all PRF payments have overlapping periods of availability.” HRSA had previously confirmed this position in response to a LeadingAge inquiry back in August. The revelation may be of greatest interest to nursing home members who received Nursing Home Infection Control (NHIC) distribution and monthly quality incentive payments in late 2020 and early 2021. NHIC payments can only be used for infection control expenses, and won’t be reported upon until the second and/or third reporting periods. By waiting to report infection control expenses until the second and/or third reporting periods, a nursing home may be able to maximize use of their NHIC payments, while also using their General Distribution payments (e.g., Phase 1, 2, 3, 4) to cover lost revenues and other eligible but non-infection control expenses. For all providers, HRSA reinforced that providers can choose during each reporting period whether to report expenses and lost revenues or enter “0” for expenses. Basically, HRSA said providers decide, how they apply their PRF funds received to their various coronavirus expenses and lost revenues.

HRSA also clarified that PRF general distribution funds can be used to cover COVID-19 staff testing costs that were not reimbursed or obligated to be reimbursed by another source. This clarification is most important to providers in states where the state did not cover testing costs. HRSA did note that providers should document that the testing expenses were to prevent, prepare for and respond to coronavirus and that they weren’t reimbursed by other sources. This documentation just needs to be maintained by the provider not submitted as part of the reporting process.

In related news, some providers began receiving emails from HRSA on Nov. 15 stating that they had not yet submitted their first PRF report. HRSA confirmed that the email went out pretty broadly and included providers who had actually submitted their reports already. Of note in the communication, HRSA indicates in the email, “Please be aware, if you are eligible for a Phase 4 General Distribution payment, HRSA will not release your Phase 4 payment until you have met your reporting requirements.” Providers who have already submitted their reports do not need to take any additional steps even if they received an email saying their report was not submitted. LeadingAge would recommend that members confirm in the reporting portal that their report is confirmed submitted. This email should provide extra motivation for other providers to submit their First PRF report by the Nov. 30 deadline and sooner, if possible. If you have questions about the PRF reporting process, HRSA has many resources but members can also contact Nicole Fallon at LeadingAge for assistance.