PYA Covid-19 Information Hub
Published September 10, 2021

Provider Relief Fund News: Deadline Extension and Several Distribution Updates


UPDATE: September 14, 2021

A related webinar has been scheduled for Tuesday, September 21, 2021. Learn more and register here.


On Friday, September 10, 2021, the Health Resources and Services Administration (HRSA), the agency administering the Provider Relief Fund (PRF), posted four announcements to its PRF webpage

1. Extension of Reporting Deadline

Here’s the relevant text from the HRSA’s PRF Reporting Requirements and Auditing webpage

The September 30, 2021 Reporting Period 1 deadline has not changed, however in response to challenges providers are facing given the Covid surges and natural disasters around the country, a 60-day Grace Period is in place. This period allows providers to come into compliance with their PRF reporting requirements should they fail to meet the September 30, 2021 deadline.

Important Details: 

    • While you will be out of compliance if you do not submit your report by September 30, 2021, recoupment or other enforcement actions will not be initiated during the 60-day grace period.
    • The grace period begins on October 1, 2021, and will end on November 30, 2021.
    • Providers who are able are strongly encouraged to complete their report in the PRF Reporting Portal by September 30, 2021.
    • Providers should return unused funds as soon as possible after submitting their report. All unused funds must be returned no later than 30 days after the end of the grace period (December 30, 2021).

This grace period only pertains to the Reporting Period 1 report submission deadline. There is no change to the Period of Availability for use of PRF payments.

2. $17 Billion Phase 4 General Distribution

HRSA announced that on September 29, 2021, providers that can document lost revenue and expenses between July 1, 2020, to March 31, 2021, will be able to apply for a $17 billion Phase 4 General Distribution. While HRSA has not provided details regarding the application process itself (presumably, those will be forthcoming), the agency has provided on its PRF Future Payments webpage the following explanation regarding the manner in which the funds will be allocated:

  • 75% of the Phase 4 allocation will be calculated based on revenue losses and COVID-related expenses.
    • Large providers will receive a minimum payment amount that is based on a percentage of their lost revenues and COVID-related expenses.
    • Medium and small providers will receive a base payment plus a supplement, with small providers receiving the highest supplement, as smaller providers tend to operate on thin margins and often serve vulnerable or isolated communities.
    • HHS will determine the exact amount of the base payments and supplements after analyzing data from all the applications received to ensure we stay within our budget and funds are distributed equitably.
    • No provider will receive a Phase 4 payment that exceeds 100% of their losses and expenses.
    • HHS will continue to use risk mitigation and cost containment measures in Phase 4 to protect program integrity and preserve taxpayer dollars.
  • 25% of the Phase 4 allocation will be put towards bonus payments that are based on the amount and type of services provided to Medicaid, CHIP, and Medicare patients.
    • The U.S. Department of Health & Human Services (HHS) will price Medicaid and Children’s Health Insurance Program (CHIP) claims data at Medicare rates, with some limited exceptions for some services provided predominantly in Medicaid and CHIP.
    • Providers who serve any patients living in Federal Office of Rural Health Policy-defined rural areas with Medicaid, CHIP, or Medicare coverage, and who otherwise meet the eligibility criteria, will receive a minimum payment.

3. $8.5 Billion American Rescue Plan (ARP) Rural Distribution

Providers that serve Medicare and Medicaid beneficiaries residing in rural communities will be eligible for the new $8.5 billion ARP Rural Distribution. To streamline the application process and minimize administrative burdens, rural providers will apply for the Phase 4 and ARP Rural Distributions in a single application. Again, HRSA has not yet provided details regarding the application process itself, but the agency has explained how these funds will be allocated:

  • HHS will make payments to providers based on the amount and type of Medicare, Medicaid, and CHIP services provided to rural patients.
    • HHS will price Medicaid and CHIP claims data at Medicare rates, with some limited exceptions for some services provided predominantly in Medicaid and CHIP.
    • Providers who serve any patients living in Federal Office of Rural Health Policy-defined rural areas with Medicaid, CHIP, or Medicare coverage, and who otherwise meet the eligibility criteria, will receive a minimum payment.

4. Phase 3 Distribution Reconsiderations

We have heard numerous complaints from providers unable to figure out why they received the amount they did under the Phase 3 General Distribution. HRSA has finally released detailed information about the methodology used to calculate these payments. Any provider that believes its Phase 3 payment was not calculated correctly will now have an opportunity to request a reconsideration. HRSA promises details on this reconsideration process will be forthcoming.

Finally, HRSA also included the following statement at the end of its announcement regarding the new distributions (it appears to be a new requirement for recipients of Phase 4 General Distribution and ARP Rural Distributions funds):  

Terms and Conditions: To help ensure that these provider funds are used for patient care, PRF recipients will be required to notify the HHS Secretary of any merger with or acquisition of another healthcare provider during their Payment Received Period. Providers who report a merger or acquisition may be more likely to be audited to confirm their funds were used for coronavirus-related costs, consistent with an overall risk-based audit strategy.

Stay tuned for additional information regarding the application process for these new distributions, as well as any clarifications regarding the reporting process.

If you would like additional guidance related to Provider Relief Funds, Health and Human Services reporting requirements, or for assistance with any matter related to compliance, valuation, or strategy and integration, visit PYA’s COVID-19 Hub or contact a PYA executive below at (800) 270-9629.

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