Provider Relief Fund update: Second reporting deadline looms as the fund nears depletion

HRSA is offering more flexibility in calculating lost revenue, but requests to give providers additional time to use their funds have gone unheeded.

Healthcare organizations that received Provider Relief Fund (PRF) payments between July 1 and Dec. 31, 2020, have until Thursday, March 31 at 11:59 p.m. Eastern time to describe their use of those funds as required in the PRF reporting portal.

The reporting requirements apply to organizations that received more than $10,000 during the second half of 2020. Noncompliance with the requirements could leave the provider subject to mandatory repayment or to debt collection.

The deadline to spend funds received during that time frame was Dec. 31, 2021. Any unused money must be returned to the Health Resources and Services Administration (HRSA), which oversees the PRF.

Flexibility in determining lost revenue

There are a few changes to reporting requirements for the current period. For example, HRSA has clarified that providers can use different methodologies from one reporting period to the next when computing lost revenue.

However, HRSA notes that “due to the overlapping periods of availability, if a reporting entity changes the method used to calculate lost revenues, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues.”

In addition, providers that seek to update their lost-revenue methodology will need to submit a written justification “to support and explain the change.”

As in the previous reporting period, the three allowed approaches to determining lost revenue are:

• Difference in actual patient-care revenues relative to 2019
• Difference between budgeted (prior to March 27, 2020) and actual patient-care revenues
• Any reasonable method of estimating revenues

Latest on PRF disbursements

The Phase 4 general distribution remains ongoing, with HRSA announcing that 89% of applications have been processed and 82,000 providers have received payments totaling about $12 billion.

There is about $5 billion left in the fund as needed for the remaining Phase 4 payments. After that, the $178 billion fund will be out of money unless Congress decides to add funding. That means no payments will be available to help providers mitigate the financial strain they’ve experienced during the delta and omicron surges over the last nine months.

The American Hospital Association recently wrote a letter to congressional leaders to request additional funding, along with other accommodations to ease the persistent financial and operational challenges of the pandemic. The hope is that along with offering additional funding, Congress would extend the deadlines for spending previously distributed funds.

A bipartisan bill in the House and a companion bill in the Senate would extend the deadline for providers to use all 2020 PRF disbursements through the end of the public health emergency. Furthermore, any money that had to be repaid after the Phase 1 spending deadline — June 30, 2021 — would be returned to providers that apply to recoup the funds.

The bills also would establish that funds could be used to enhance workplace security measures for staff.

However, the bills did not advance past the committee stage during negotiations on the FY22 appropriations bill that passed this month, leaving their fate uncertain in a legislative environment where the Biden administration’s request for funding to ensure steady supplies of tests, treatments and vaccines likewise has been languishing.