The Provider Relief Fund (PRF) Reporting Period 4(RP4) begins January 1, 2023 and will also include reporting on the American Rescue Plan (ARP) Rural Payments. To explain how the inclusion of ARP Rural payments changes the reporting dynamics, the Health Services and Resources Administration (HRSA) issued some updated reporting requirements and FAQs.

These are the first updates to the Post-Payment Notice of Reporting Requirements since June 11, 2021. Many of the changes focus on establishing the reporting requirements for ARP Rural Payments and how these changes alter how providers will report on PRF and ARP Rural payments going forward. Here are some of the key changes of which providers should be aware:

• Use of PRF and ARP Rural for Lost Revenue to End in Quarter of PHE End. In general, PRF and ARP Rural payments must be used by the end of the Period of Availability that applies to the payment. Of note, the new requirements limit the timeframe in which providers can use PRF and ARP Rural payments for lost revenues to the end of the quarter in which the Public Health Emergency (PHE) ends. What this could mean is if the PHE ends in April 2023, then providers could only use their PRF and ARP Rural Payments for lost revenues through June 2023. For payments received before June 30, 2022, this is mirrors the Period of Availability but those who received their Phase 4 payments after June 30, 2022 will have a shortened period of time to use them for lost revenues. At present, the PHE has been extended through January 11, 2023. The Administration has indicated it will give 60-day notice prior to ending the PHE and as of Nov.11, 2022, no such notice has been issued.
• Lost Revenues and Expenses must be first applied to ARP Rural Then PRF. As providers work their way through the reporting portal, they will be asked to first apply COVID-19 health care expenses and lost revenues to ARP Rural payments prior to applying them to any of your general PRF distributions like Phase 3 and 4.
• Parent Organizations are Reporting Entity for ARP Rural Payments. Where applicable, organizations that received ARP Rural funds were prohibited from transferring these funds to any entity but that which qualified. However, in some cases, the parent organization received the payment on behalf of a qualifying subsidiary. In these parent-subsidiary situations, the parent entity is the required reporter even though the qualifying organization is the only one that could use the ARP Rural funds.
• Providers cannot amend PRF reports for audit findings after the reporting period closes. HRSA notes that lost revenue adjustments can be made on future reports because the lost revenues are cumulative in nature. Therefore, a provider could offset an unallowable expense with unreimbursed lost revenue, as long as they make sure not to double dip or apply PRF to the same lost revenues twice.
• Providers in major disaster areas may have an extension on completing their single audit. Providers should check the FAQs to see if they can receive an extension for when they must submit their single audit due to a major disaster declaration.

HRSA also added to the current number of PRF reporting periods. There will now be 7 reporting periods. The final reporting period will cover any payments received in the first half of 2023 and the corresponding reports will be submitted by September 30, 2024. Providers only need to report in any given reporting period if they received an aggregate of $10,000 or more in PRF and/or ARP Rural Payments. For many providers, their reporting compliance may end before 2024.

Here is the updated reporting table:

Providers who received aggregate PRF and/or ARP Rural payments between July 1 and December 31, 2021, should being preparing for these new reporting requirements, as RP4 begins January 1, 2023. HRSA distributed the first batch of Phase 4 general distribution PRF payments on December 16, 2021 and the first batch of ARP Rural payments made on November 23, 2021.

Additional information on Provider Relief Funds, can be found on the LeadingAge website by clicking here.