LeadingAge staff spoke with staff from the Health Resources & Services Administration (HRSA) on Friday and learned some new information on the status of Phase 4 Provider Relief Funds (PRF) funding, how providers should approach notices to return funds and future training on the updated reporting requirements.

Phase 4 Updates

HRSA has roughly 1% of Phase 4 application that it must make final determinations on. It looks like that work should be completed by year-end or early in 2023. Once this effort is complete, HRSA will turn to reviewing provider requests for reconsideration of their Phase 4 payment determinations. They will begin processing the more straightforward requests first early in 2023, but providers with more complex reconsideration requests should expect the review to take longer. Given the latest updates to the PRF Reporting Periods, it looks like HRSA’s goal is to finish all PRF payment determinations, including reconsiderations, adjustments to the amounts previously received, and Phase 4 payouts by June 30, 2023.

Notices to Return Funds

Providers have now completed three PRF reporting cycles. Upon completion of some of those reports, providers may have been required to return unused funds. In other cases, nursing homes who failed to report on their targeted SNF Distributions and/or Nursing Home Infection Control payments may also be required to return those funds due to non-compliance. In both cases, HRSA has sent letters to these providers indicating funds must be returned. If you believe you received one of these notices in error, now is the time to reach out to HRSA to resolve these issues. While you are seeking to get answers, HRSA staff say do NOT return the funds until you have exhausted your appeal options. The initial letters telling you to return the funds are a first step. Ultimately, if the funds are not returned, providers will receive what is called a “demand letter.” It is at this point that the provider will have the opportunity to make their case for why they do not believe they need to return the funds. This will be done through a prescribed appeals process. The appeal decision will be the final decision and it is at that point that the provider will need to return funds, if still necessary. 
Providers who are considered out of compliance with the PRF payment terms and conditions (e.g., failure to report, failure to return required funds) are not eligible to received additional PRF distributions. Therefore, if this situation applies, it is imperative that the provider resolve the issue with HRSA, as it may be holding up receipt of a Phase 4 distribution for which they are eligible. LeadingAge members who are unable to resolve these issues with the Provider Support Line (866-569-3522), should reach out to Nicole Fallon for help.
January Webinar on Update PRF Reporting Requirements

HRSA staff are planning a webinar for providers in January to walk through the changes to the PRF reporting requirements that were made on October 27, 2022. The focus of the webinar will be on the addition of the American Rescue Plan (ARP) Rural payment reporting and how it intersects with reporting on Phase 4 general distributions.

The Future of PRF

LeadingAge also learned that while some PRF payments are being returned, the amount is not meaningful. Therefore, no future PRF funding opportunities are expected.