HRSA Offers Second Chances In Provider Relief Funding And Reporting – Healthcare

Andara Puchino

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The initial phase of Provider Relief Funds (“Funds”)
was distributed in April 2020, and since then, many providers have
been playing catch up. The Health Resources & Services
Administration (HRSA) recently addressed two critical pieces of
this “catch up” by offering assisted living operators the
opportunity to apply for Funds they were previously denied and by
allowing providers that were required to report under Reporting
Period 2, but failed to do so, the ability to request to report
late in certain circumstances.

1. Assisted Living Operators’ Chance for Funding

On April 26, 2022, HRSA quietly released the following FAQ on

Will applicants that did not have their TINs validated but were
able to submit a DocuSign application have an opportunity to
substantiate their eligibility for Phase 4 payments?

Assisted living facilities (“ALFs”) and behavioral
health providers that do not participate in Medicare, Medicaid, or
the Children’s Health Insurance Program (“CHIP”) have
the opportunity to submit additional documentation in order to be
considered for Phase 4 funding. Only ALFs and behavioral health
providers that successfully submitted a DocuSign application during
the Phase 4 application cycle are eligible for this opportunity.
Affected ALFs and behavioral health providers received a notice
directing them to submit their state/territorial license or
nationally recognized certification (if operating in a state that
does not license their profession or facility) via the form
available at
ALFs and behavioral health providers have until May 9, 2022, at
11:59 p.m. EST to submit this documentation in order to be
considered for payment from this distribution.

Please note that this opportunity is limited to Phase 4 funding;
HRSA will not reevaluate eligibility for ARP Rural payments.

The FAQ addresses an issue experienced by many assisted living
operators when applying for Funds: because HRSA depended on state
licensing and third-party databases to verify applicant information
for assisted living facilities that do not participate in Medicaid,
many of the assisted living operators could not apply for Funds
because the operator entities or their taxpayer identification
numbers could not be verified by HRSA. The new FAQ may remedy this
by allowing these operators to submit a copy of their state license
to confirm eligibility for Funds.

Operators affected by this FAQ were notified of the change. As
mentioned in the FAQ above, operators were able to submit their
licenses by May 9, 2022, at 11:59 p.m. EST. HRSA has also made
clear that the opportunity was limited to Phase 4 Funds and did not
apply to earlier phases of Funds.

2. Reporting Period 2 and Requests to Report Late

previously reported on
 HRSA allowing Fund recipients to
request to report late for Reporting Period 1, where
“extenuating circumstances” resulted in the inability to
report by the due dates in 2021. HRSA has now updated its
“Request to Report Late” 
 with information on requesting to report late for
Reporting Period 2. Requests to Report Late Due to Extenuating
Circumstances for Reporting Period 2 must be submitted from Monday,
May 2 to Friday, May 13, 2022, at 11:59 p.m. ET.

As with the previous round of requests to report late, a
provider must attest to meeting an “extenuating
circumstance” in order to report late.  The following is
a list of the “extenuating circumstances”:

  • Severe illness or death – a severe
    medical condition or death of a provider or key staff member
    responsible for reporting hindered the organization’s ability
    to complete the report during the Reporting Period.

  • Impacted by natural disaster – a
    natural disaster occurred during or in close proximity of the end
    of the Reporting Period damaging the organization’s records or
    information technology.

  • Lack of receipt of reporting
     – an incorrect email or mailing
    address on file with HRSA prevented the organization from receiving
    instructions prior to the Reporting Period deadline.

  • Failure to click
     – the organization
    registered and prepared a report in the PRF Reporting Portal, but
    failed to take the final step to click “Submit” prior to
    the deadline.

  • Internal miscommunication or
     – internal miscommunication or error
    regarding the individual who was authorized and expected to submit
    the report on behalf of the organization and/or the registered
    point of contact in the PRF Reporting Portal.

  • Incomplete Targeted Distribution
     – the organization’s parent entity
    completed all General Distribution payments, but a Targeted
    Distribution(s) was not reported on by the subsidiary.

Providers that failed to report on time but believe they meet
one or more of the extenuating circumstances should review
HRSA’s “
Process for Submitting a Late Report Request
” summary and
take steps to file the request as soon as possible. If HRSA
responds to the requests on a similar timeline as the previous
round of requests, providers should expect to hear back from the
agency within 2-3 weeks after May 13, 2022.

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

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