Providers Can Correct PRF Reporting Errors
Regulation | March 23, 2022 | by Nicole Fallon
The Health Resources and Services Administration (HRSA) "strongly encourages" providers to correct reporting errors from the first Provider Relief Fund reporting period. By correcting errors, providers may avoid the need to repay all or a portion of the PRF dollars they have received.
HRSA noted this error correction option when asked about what providers who received repayment letters could do to correct issues. HRSA said to correct errors a provider must contact the PRF Provider Support Line (866-569-3522) and request to be escalated to a Tier 2 agent to discuss an error in their submitted report indicating their desire to correct it. We do not know the extent of circumstances that HRSA and the Tier 2 agents will consider "errors" vs. non-compliance but believe that some of the following situations may apply:
- Nursing homes who reported all their infection control expenses in the first PRF reporting period because they thought it was required. For some nursing homes, this error resulted in these providers having no or limited infection control expenses to report in the second reporting period to offset the Nursing Home Infection Control (NHIC) and related Quality Incentive Payments (QIP) that they must now report on. If providers are going to be able to apply these expenses in the second reporting period, they must correct their first report errors prior to the March 31, 2022 (11:59 p.m. ET) deadline for submitting second period PRF reports.
- A provider realized after the first report was submitted that a payment they received and thought was for a different purpose (e.g. Medicare Advanced and Accelerated Payment) was actually a PRF payment that should have been included in the first reporting period report. In this circumstance, the provider will likely to not only have the Tier 2 agent unlock their report for correction but also assist them in having this payment added to the report.
- A provider reported on all payments listed in the PRF reporting portal for the first reporting period but learned later that a payment was missing from that list.
- A provider realizes they have one or more typos in the report that have a material impact on the reports calculations of expenses and/or lost revenues incurred, interest earned, etc. Such errors may result in a report indicating a provider must return funds.
There are likely other scenarios. It is not clear if a provider who received a Repayment letter can ask to have their first PRF report unlocked so they can correct reporting on a targeted distribution but it is worth calling to find out.
For those who received Repayment letters following their first reporting period submission, HRSA wanted these providers to know that this initial notification is not a "Demand" or "Debt Collection" letter. A Demand Letter will follow and include additional information for providers on how to dispute this determination as well as information on alternative methods of repayment. Providers can wait to take action until they receive this information.