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Read this if your organization is required to report on Provider Relief Funds.
On October 27, 2022, HRSA released an update to its Post-Payment Notice of Reporting Requirements for Provider Relief Funds (PRF) and American Rescue Plan (ARP) funds, the first update since June 11, 2021. Although many of the updates are used to add the additional reporting periods for PRF (Periods 5 through 7) and incorporate ARP into the reporting requirements, there are several things you can do to prepare and understand the nuances of Period 4 reporting. By way of a reminder, here are the remaining reporting time periods:

Be aware. Did you know?
Before we provide a refresher on the data elements you need to prepare your portal submission, here are some very important elements to be aware of:
- Phase 4 and ARP payments are required to be maintained in interest-bearing accounts.
- ARP monies must be utilized before any unspent general PRF distributions.
- ARP distributions cannot be transferred or allocated to another recipient, because distributions were determined specific to the historical claims data of the qualifying recipient. If reporting is performed at the parent level, parent entities can still report on the ARP payments received by their subsidiaries.
- PRF and ARP monies can be used for lost revenues only through the end of the quarter in which the Public Health Emergency (PHE) ends. Currently, the PHE has been extended through April 11, 2023.
- Reporting through the HRSA portal will be on a cumulative basis. This may provide you the opportunity to change your option election for lost revenue (for the cumulative period) or correct for previous reporting errors.
Steps for reporting the required data elements
As a result of changes in requirements and the ARP distribution, the steps for reporting have morphed. Data will be entered in the following order:
- Interest earned on PRF payments prior to Phase 4
- Interest earned on Phase 4 and ARP payments
- Other assistance received
- Use of ARP payments for eligible expenses
- Use of ARP payments for lost revenues
- Use of Nursing Home Infection Control (NHIC) Distribution payments
- Use of General and Targeted Distribution payments for eligible expenses
- Use of General and Targeted Distribution payments for lost revenues
- Net unreimbursed expenses attributable to COVID-19
Although PRF and ARP funds have similar utilization, it is important to review the Terms and Conditions associated with each distribution to help ensure compliance that the funds are used appropriately.
Data elements you will need
The following is a category overview of the data elements that will be requested as you complete your portal submission:
- Reporting entity identifying information
- Associated subsidiary questionnaire—TIN(s), total PRF Targeted Distributions
- ARP subsidiary attestation
- Acquired or divested subsidiary information
- Interest earned on PRF and ARP payments
- Tax status and Single Audit information
- Other assistance received, broken down by quarters:
a. Department of the Treasury or SBA
b. FEMA
c. HHS COVID Testing
d. Local, state, and tribal government assistance
e. Business insurance
f. Other
- Use of ARP payments (and related earned interest) on eligible expenses
- Use of ARP payments (and related earned interest) on lost revenues attributed to COVID
- Use of NHIC Distribution payments
- Use of PRF General and Targeted Distribution payments (and related earned interest) on eligible expenses
- Use of PRF General and Targeted Distribution payments (and related earned interest) on lost revenues attributed to COVID
- Net unreimbursed expenses
- Personnel, patient, and facility metrics
- Survey
Two reminders for reporting expenses and lost revenues:
- Recipients with qualifying expenses of $500,000 or more will need to report expenses in greater detail. As a refresher, the expanded categories are as follows:
General and Administrative (G&A) expense categories: Mortgage/rent, insurance, personnel, fringe benefits, lease payments, utilities/operations, and other G&A
Healthcare related expense categories: Supplies, equipment, IT, facilities, and other health care related expenses
- Patient service revenue must be reported at net and broken down by payor (Medicare Part A & B, Medicare Part C, Medicaid/CHIP, commercial, self-pay, and other)
The final step in the portal is to complete the required survey, which often catches recipients off-guard as they grow weary toward the end of rigors of the submission and ready to cross the finish line. Be prepared to respond to questions on the impact the PRF and ARP payments have made for your organization, whether the benefits have been overall operations, solvency, staff retention, COVID operations, etc.
In addition to a federal Single Audit requirement when a recipient expends more than $750,000 of federal funding in one year (regardless of whether those federally sourced funds came directly from the federal government or were passed from a state or local government), HRSA may also perform its own audits of recipients. These audits will address the data used by the recipients to report on their usage of PRF and ARP monies. Recipients will need to provide support for lost revenue and expenses that justify the use of the funds that they received.
The HRSA is going to drill down on the revenue numbers, specifically looking at the general ledger (GL) and other select revenue tests. On the expenses side, they are going to review the GL, invoice dates, payments and more.
To complete this audit, HRSA will require a significant amount of supporting documentation. Ideally, most of these documents should already have been copied and set aside as support in anticipation of financial reporting requirements. Below is a partial list of items that could be requested during the audit:
- GL details
- Listing of expenses reimbursed with PRF and ARP payments grouped into specified categories
- Listing of patient care revenue by payor
- Listing of other sources of assistance
- Listing of expenses reimbursed with the other assistance received
- Detailed inventory listing of IT supplies
- Budget attestation from CEO or CFO and board minutes showing ratification of the budget before March 27, 2020
- Documentation of lost revenue methodologies
- Audited financial statements
- CMS cost reports for Medicare and Medicaid
- Other supporting documentation
If certain documentation isn’t available, recipients will need to request copies from their vendors. Missing documentation may make it difficult to justify the use of funds and may result in recipients having to repay a portion or all of their provider relief funding.
It is possible that certain expenses were not allowable under PRF and ARP. However, that doesn’t necessarily mean recipients will have to repay their funds. Recipients may have other lost revenue or expenses that would be allowed under PRF and ARP—but only if they have the documentation to prove it. That’s why it’s crucial that recipients have all relevant documentation for expenses and lost revenue over the periods they received provider relief funding.
To get ready for a potential HRSA audit, there are at least three immediate steps you should take:
- Select a responsible point person. One person should be responsible for coordinating the process to help ensure that nothing falls through the cracks or is overlooked.
- Keep your PRF/ARP filing reports on hand. Pull any related supporting documentation and collate it into one place if it isn’t already.
- Identify what support is needed by doing a gap analysis. Determine where you need additional support or expertise and seek to close these gaps before the notification of any audit process.
Insufficient documentation may result in the recapture of provider relief funding by the HRSA. Fortunately, a lack of documentation is preventable with the right support and resources in place. If you would like more information or have any questions about your specific situation, please contact us. We’re here to help.