The Health Resources and Services Administration (HRSA) announced it is making more than $413 million in Provider Relief Fund (PRF) Phase 4 General Distribution payments to more than 3,600 providers across the country this week. Providers would have received an email notification on March 21 if their application was among those processed in this latest batch. HRSA is working to review all remaining applications as quickly as possible and anticipates another round of Phase 4 to be released in late April or early May.
For more information:
- The U.S. Department of Health and Human Services (HHS) updated the state-by-state table detailing all Phase 4 payments made to date.
- As individual providers agree to the terms and conditions of Phase 4 payments, it will be reflected on the public dataset.
If you have neither received your Phase 4 award nor a No Pay Letter, your Phase 4 payment likely is still in manual review.
Reporting Period 1 Challenges
Providers began receiving failure to report notifications beginning March 14. AHCA/NCAL identified three reasons for receiving such a notification:
- SNF Targeted Allocation Filed at Parent Level: All Targeted Allocations must be reported on at the subsidiary level, not parent.
- Omitted sections
- Data entry errors
The transmittals providers are now receiving are simply notifications that HRSA believes it has found a problem with Reporting Period 1 (RP1) submissions. The 30-day repayment notification language in these transmittals is confusing. No funds should be returned to HRSA unless a provider receives a Demand Letter. Before Demand Letters, providers will be offered the opportunity to correct reporting errors or for HRSA to determine whether the notification was sent in error. Below is a summary of points verbally shared by HRSA and suggested member action steps.
What is considered non-compliance?
Non-compliance is defined as a failure to report funds in any reporting period. Reporting errors are not considered non-compliance. Providers who feel they received the “Failure to Report” email in error (i.e., they did complete their RP1 report), should call the Provider Support for assistance.
*ACTION ITEM: Provider should check their submitted RP1 reports to ensure they included all General and Targeted Distributions received from April 10, 2020, through June 30, 2020. Stated differently, the provider should self-identify. Keep on file a copy of the submitted letter/report that shows they have completed RP1 by TIN and Funds (General and Targeted). If providers have the needed documentation, they should pursue error correction and only use the documentation if a Demand Letter is sent later.
What happens if the letter was driven by data entry errors?
If a provider believes they had typos in their report, call the Provider Support to alert them of a necessary edit. There is significant flexibility to edit. Use the term “EDIT” - not “MISSED DEADLINE” for RP1 to get in the correct response queue. If the ‘unused funds’ listed on the report is related to an error in completing the report, there may be the opportunity to revise the report.
What if I reported all awards, including SNF Targeted and Infection Control at the parent level?
The parent organization may not report on a targeted distribution received by a subsidiary. HRSA has received inquiries related to a Failure to Report from entities that did not report on a Targeted distribution, which is required to be reported by the entity that received it. HRSA’s Customer Service team is finding examples of subsidiaries who failed to report on the Targeted money, though the Parent did report on their general dollars. When contacting the Support Line, providers also should ask about making these reporting corrections.
What does it mean to be non-compliant?
If the provider did not submit their RP1 report, they are required to return the funds received from April 10, 2020, through June 30, 2020. Only the funds not in the PR1 must be returned. Payments for future distributions will not be awarded until non-compliance for RP1 is corrected. Providers who have not reported will receive a Demand Letter at a future stage with specific action steps if the federal government plans to take recovery steps or other actions outlined in the Terms and Conditions Reporting requirements.
*ACTION ITEM: Providers who received RP1 failure to report letters to determine whether the HRSA notice was generated due to an error or whether funds were not reported upon. If funds were not reported, providers should review the Terms and Conditions reporting section to assess steps and proactively monitor for HRSA Demand Letters which will contain repayment instructions.