Providers who received Provider Relief Funds (PRF) and/or American Rescue Plan (ARP) Rural funds between July 1 – December 31, 2021 are required to report on how they used those funds in Reporting Period 4 (RP4). These reports are due at 11:59 p.m. ET on March 31, 2023. New reporting requirements from October 2022 govern RP4 and all future reporting periods.

One new policy in the recently updated reporting requirements explains the period of time providers can use PRF and ARP Rural dollars to cover lost revenues once the Public Health Emergency (PHE) ends on May 11. While this change will not impact RP4, it will impact Reporting Period 5, 6 and 7. When the PHE ends May 11, providers will only be able to use PRF and ARP Rural funds to lost revenues incurred through June 30, 2023. The good news is that PRF can be used for any previously incurred lost revenues that a provider carried over from one report to the next as long as it was incurred between January 1, 2020 and June 30, 2023. Prior to the clarification, we were concerned that providers wouldn’t be able to apply PRF and ARP Rural payments to lost revenues when reporting in the final three reporting periods.

Here is the specific response and example from Health Resources & Services Administration (HRSA) clarifying this point for LeadingAge about when PRF can be used to cover lost revenues once the PHE ends.

“Providers may only apply PRF or ARP Rural payments to lost revenues incurred during the Period of Availability associated with the Payment Received Period in which they received funds. For providers that received payments in Payment Received Periods 1 to 4, the Period of Availability to use PRF or ARP rural payments for expenses or lost revenues has ended. For providers that received payments in Payment Received Period 5 or later, providers have from the beginning of the Period of Availability [January 1, 2020] up until the end of the quarter in which the COVID-19 Public Health Emergency ends to use PRF or ARP Rural payments for lost revenues. For example, if a provider received PRF payments in Payment Received Period 5, and the Public Health Emergency ends on May 11, 2023, the provider may use PRF payments for lost revenues incurred up until June 30, 2023, the end of the quarter in which the Public Health Emergency would end. The provider would be required to report on the use of PRF payments, including any lost revenues incurred, in Reporting Period 5. In subsequent reporting periods, the provider may apply PRF payments to lost revenues incurred that were not previously reimbursed, as long as the lost revenues were incurred prior to June 30, 2023, the end of the quarter in which the Public Health Emergency would end. “

Reports continue to be submitted via the PRF Reporting Portal but there are some enhancements to the portal that allows providers to seek “contextual help” on an area or topic while remaining in the portal. Members who need a refresher on the reporting portal and process can access a recording of a Feb. 2 LeadingAge/CLA webinar, which provides a refresher on how to report on PRF, walks through the new reporting requirements and portal updates, and highlights common audit findings related to PRF.  In addition, providers are encouraged to use the HRSA PRF Portal Users Guide – Reporting, which offers a step-by-step explanation for each page in the portal.