On July 1, 2021, the Department of Health and Human Services (“HHS”) launched its Provider Relief Fund (“PRF”) Reporting Portal through the Health Resources and Services Administration (“HRSA”).  On the same day, HHS once again updated its PRF Frequently Asked Questions (“FAQs”).  

The attorneys at Chilivis Grubman have tracked prior 2021 updates to the FAQs last June and in the end of March. Providers should be aware that the HHS’ Office of Inspector General’s current workplan includes audits of CARES Act Provider Relief Fund Payments, and the Department of Justice has been directed to establish an inter-agency COVID-19 Task Force, which is expected to focus on PRF compliance concerns, among other COVID-19 relief programs.

Reporting Portal Resources:

Just prior to opening the Reporting Portal, HHS and HRSA released multiple resources to guide providers through the reporting process, including a Reporting User Guide for registration and for reporting.  HRSA will host a provider webcast on Thursday, July 8, 2021 at 3pm EST with an “Introduction to the PRF Reporting Portal,” which may be helpful to providers looking to complete their PRF reporting requirements.

FAQ Updates:

Here are a few highlights from this most recent round of changes to the PRF FAQs:

  • Don’t count on any deadline extensions.  Providers may not request an extension to use PRF payments and may not request an extension on any report submissions during their required reporting periods.
  • If a provider’s lost revenue in a given Payment Received Period exceeds the PRF payments it received for the same period, the remaining lost revenue may be carried forward and applied against PRF payments received during a later Payment Received Period.
  • If a provider has not used all of its PRF payment before the applicable deadline, the provider has 30 calendar days after the end of the applicable Period of Reporting to return the funds.

As a reminder, here’s the chart HHS released on June 11, 2021, for determining the deadline to use funds and the reporting period:

For example, if a provider received a PRF payment between April 10, 2020 and June 30, 2020, then the provider’s deadline to use the funds is June 30, 2021, the applicable reporting period is July 1, 2021 to September 30, 2021, and the provider would have to return any funds not used prior to June 30, 2020, before October 30, 2021.

The attorneys at Chilivis Grubman represent clients of all types and sizes, including healthcare providers and small businesses that have accepted COVID-19 relief funds.  If you need assistance with COVID-19 relief funds compliance, please contact us today.