Home Health & Hospice Week

Heads up: PRF reporting now differentiates between expenses and losses.

Providers that still have unspent Provider Relief Funds don’t have to necessarily stop spending them just because the COVID-19 public health emergency has ended.

In recent guidance, the Health Resources and Services Administration addresses “the use of PRF and [American Rescue Plan] Rural payments for lost revenues after the COVID-19 Public Health Emergency ends.”

Experts thought spending of PRF funds might have to end when the PHE did. But HRSA clarifies that “PRF and ARP Rural recipients must use payments for eligible expenses, including services rendered during the period of availability, as outlined in Table 1.” That table adds two new Reporting Periods, RP 8 and RP 9.

For RP 8, providers that receive payments from July 1, 2023 to Dec. 31, 2023 can pay for eligible expenses through Dec. 31, 2024. For RP 9, providers that receive funds from Jan. 1, 2024 to June 30, 2024 can pay for eligible expenses through Dec. 31, 2025, HRSA indicates.

These timeframes indicate there may be future PRF payments still in store.

“PRF and ARP Rural recipients may also use payments for lost revenues attributable to COVID-19 incurred within the period of availability, but only up to June 30, 2023, the end of the quarter in which the COVID-19 Public Health Emergency ends,” the updated guidance adds.

RP 8’s reporting period runs from Jan. 1, 2025 to March 31, 2025, while RP 9’s spans July 1, 2025 to Sept. 30, 2025.

“HRSA’s guidance on the appropriate use of funds and reporting requirements ... continues to evolve,” note attorneys Timothy Fry and Sydney Menack with law firm McGuireWoods. “This guidance makes clear … that providers can continue to spend PRF payments after May 11,” Fry and Menack say.

Beware: “While previous guidance did not distinguish between the two uses [of eligible expenses and lost revenues] in determining the appropriate spending time frame, the end of the COVID-19 PHE complicates how HRSA is viewing providers spending such PRF payments,” the McGuire Woods lawyers caution in online analysis.

“For providers using the PRF payments for lost revenue purposes, the spending time frame is significantly altered by the sunsetting of the PHE,” Fry and Menack stress. “Providers may continue to use the funds for lost revenue only until June 30, 2023.”

Keep in mind: For the new PRs 8 and 9, “reports will be due for those time periods [only] if a provider received $10,000 or more in that period,” the attorneys remind.

HRSA has yet to correct one big weakness with the reports, judges The Health Group in Morgantown, West Virginia. “This weakness is the inability of the provider to amend report filings in the reporting portal,” the consulting firm notes in its electronic newsletter.

“Reporting errors could take a variety of forms,” The Health Group notes. “Many filings may be improved if a mechanism were available to amend filings,” it says.

Note: The updated guidance is at www.hrsa.gov/sites/ default/files/hrsa/provider-relief/prf-arp-rural-post-payment-notice-reporting-requirements.pdf.