Grace Periods, Payments and Calculations: The Latest PRF News

The PRF landscape continues to evolve in the face of the pandemic and various natural disasters. We’ve got the latest developments from the Health Resources & Services Administration (HRSA) regarding the upcoming reporting deadline, new distributions and Phase 3 payment calculations.

A (Temporary) Grace Period

As you’ve probably heard, the PRF reporting portal is open until Sept. 30, 2021 for the first payment received period. However, many practices are still seeing their business disrupted by COVID-19 surges. Natural disasters, such as the California wildfires and tropical systems like Elsa, Ida and Norman, are also causing hardships.

Given such events, HRSA has announced a 60-day grace period for the first PRF reporting period. The agency will continue accepting reports from Oct. 1-Nov. 30, 2021 via the portal. All unused funds must be returned no later than Dec. 30, 2021 (30 days after the grace period).

Note that this grace period only applies to the Reporting Period 1 submission deadline (which covers payments received between April 10 and June 30, 2020 and used by June 30, 2021.) The Period of Availability for use of these PRF payments remains the same.

You will still be considered out of compliance if your report isn’t submitted by Sept. 30, 2021. However, recoupment or other enforcement actions will not be initiated during the grace period.

That said, compliance with the original deadline is still strongly encouraged. If you’re able, our healthcare CPAs recommend completing your PRF reporting and submitting it through the portal on time.

New Distributions Announced

HRSA has also announced a new distribution of $25.5 billion in relief funding will be available Sept. 29, 2021.

The amount includes two components. The first, PRF Phase 4, equals $17 billion of the new distribution. This funding is to help providers offset lost revenues and changes in operating expenses from July 1, 2020, to March 1, 2021. In the interest of equity and supporting providers most in need, HRSA has built in two provisions:

• Smaller providers will be reimbursed at a higher percentage of lost revenues and expenses.
• “Bonus” payments will be issued based on the amount of services provided to Medicaid, CHIP and Medicare patients. These payments will be priced at the generally higher Medicare rates.

The second component consists of $8.5 billion in American Rescue Plan (ARP) resources for providers who serve patients in rural areas (as defined by the Federal Office of Rural Health). As with the PRF Phase 4 funds, HRSA will price payments at Medicare rates for Medicaid/CHIP patients.

Reconsiderations for Phase 3 Payments

The Department of Health and Human Services (HHS) has released details about the methodology used to calculate Phase 3 payments. This resource is useful for providers who believe their Phase 3 payment was not calculated correctly. If you fall into this category, you will be able to request a reconsideration. However, details on this process are still being developed.

These and other developments are continuously tracked by our team. Stay tuned for updates from James Moore as we monitor the situation and inform you on any changes.

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