Late Reporting Option Announced for Certain Provider Relief Fund Recipients

Overview of Circumstances That May Permit Late Reporting

The Coronavirus Aid, Relief, and Economic Security (CARES) Act allocated over $175 billion for the Provider Relief Fund (PRF) to support healthcare providers in the battle against the COVID-19 pandemic. On October 1, 2020, the PRF was expanded by an additional $24.5 billion of funds and the eligibility to previously excluded practices, such as behavioral health providers.

Qualified providers of healthcare, services, and support may use the PRF payments for healthcare-related expenses or lost revenue due to COVID-19.

PRF Deadlines for Late Reporting Under Extenuating Circumstances

The U.S. Department of Health and Human Services (HHS) announced that providers that received $10,000 or more in the first half of 2020 from the Provider Relief Fund but missed the reporting deadlines will have an opportunity to request to report late if they experienced a specific extenuating circumstance.

Extenuating circumstance requests must be submitted by April 22, 2022, at 11:59 p.m. (ET) through a form that will be available starting April 11. Providers approved by HHS to report late can then submit their required reports through the Provider Relief Fund reporting portal.

Note: According to HHS, submission of a report will not guarantee approval. If denied, a provider will be required to return to HHS all funds that were not reported before the earlier deadline for failing to comply with the Provider Relief Fund’s terms and conditions.

6 Extenuating Circumstance Categories for PRF Late Reporting

To request an opportunity to complete a late report, your healthcare entity must select one of six reasons explaining why it was unable to submit a completed report in reporting period 1 before the passed deadline. The six categories are as follows:

1. Severe illness or death;
2. Impacted by natural disaster;
3. Lack of receipt of reporting communications;
4. Failure to click “submit”;
5. Internal miscommunication or error; or
6. Incomplete Targeted Distribution payments

A concise explanation related to the applicable extenuating circumstance must be provided as well as an attestation to the truthfulness and accuracy of such circumstance. HHS definitions for the six categories can be found here.

Late Reporting Steps for PRF Recipients

Your healthcare entity should take the following steps for late reporting due to extenuating circumstances:

1. Register on the PRF Reporting Portal
   If you have not previously registered on the Provider Relief Fund reporting portal, register immediately and complete the reporting portal registration. Registration will be required to submit the late report request and this process takes time for HHS to review and link the account with the received funds.
2. Determine Applicable Extenuating Circumstance
   Determine which, if any, of the above-listed acceptable extenuating circumstances applies. You will need to submit a clear and concise explanation related to the extenuating circumstance. While supporting documentation will not be required, providers should ensure for their comfort that such supporting information is available and maintained for any filing made to the government in case there is a future audit or review.
3. Prepare the Required Information for Report Submission
   You should begin preparing the information required to submit a period 1 report as soon as possible. HHS has stated that providers will have only 10 days from notification that their request was approved to submit the report. The reports will require financial and organizational information, as well as information about how the funds were used.
4. Monitor Future Provider Relief Fund Communications
   You should also carefully monitor and review future Provider Relief Fund communications. Any email address provided through the reporting portal (as well as emails given in government reimbursement program enrollment and licensure applications) should be monitored to ensure you receive all important communication in the future. Adding emails received from @hrsa.gov, @hhs.gov, and @ProviderEmail.uhc.com domains to your safe receipt lists can also ensure you receive communications.

HHS Late Reporting Request Response

This opportunity comes after required reports for period 1 were initially due September 30, 2021, extended with a grace period for reporting until November 30, 2021, and then a subsequent reopening for a week in December. After the close of period 1, HHS began notifying nonreporting providers that they were noncompliant and would need to return received funds.

This late reporting request period is likely a response by HHS to address industry concerns from the perceived inflexibility and inadequate compliance opportunities for providers. The ongoing COVID-19 surges have also presented challenges for some providers in returning funds. HHS has indicated that there will be similar late reporting request periods for future reporting periods, including the recently closed period 2 (for funds received during the second half of 2020).

Questions on PRF Late Reporting for your healthcare entity? We are advising some of our clients on this issue and can share our knowledge and insights on Provider Relief Funds and the compliance requirements. Contact us: Email | 804.747.0000