The U.S. Department of Health and Human Services' (HHS) Provider Relief Fund (PRF) reporting portal opens on January 1, 2023 for those completing the reporting requirements for PRF stimulus payments received during Period 4. Many healthcare providers received this funding and are required to meet reporting requirements. These providers include nursing homes, durable medical equipment providers, physical therapists, and pharmacies. If the reporting requirements are not met, providers will be considered noncompliant with the terms and conditions and will be subject to enforcement action from HHS, including recoupment of the funds.

Below is a brief Q&A on the PRF and reporting requirements:

• What is the PRF?
  • The Provider Relief Fund is a stimulus program created through the CARES Act for healthcare providers. The funds can be used for increased healthcare-related expenses and lost revenues due to coronavirus. Some providers received significant payments through this program to support their businesses.
• Who received it?
  • Almost all healthcare providers, including ancillary providers such as physical therapists, labs, pharmacies, and durable medical equipment providers.
• What period does this reporting relate to?
  • Period 4 reporting is applicable for all providers who received funds from July 1, 2021, to December 31, 2021.
• What are the reporting requirements?
  • Providers must report on their use of the PRF funds, other assistance they received from programs like the Paycheck Protection Program (“PPP”), and personnel and patient metrics. As a reminder, Period 4 funds were eligible to be used for expenses and/or lost revenue, as defined by the terms and conditions, for the period of January 1, 2020, to December 31, 2022. While the requirements may sound simple, some providers may experience issues with tracking down the necessary information.
• What happens if the reporting requirements are not met?
  • If the provider does not meet the reporting requirements due by March 31, 2023, they will be considered out of compliance with the terms and conditions of the program. At present, the understanding is that the provider would be subject to a recoupment process from HHS, requiring them to return the funds. It is unclear at this point if they will face additional enforcement action from HHS.

How Citrin Cooperman Can Help

Citrin Cooperman’s Healthcare Practice has worked with many clients on reporting these funds and can provide you with the support you need. However, please note that the reporting requirements are extensive, and you may miss the deadline if the work is left to the last minute. If you require assistance or you are unsure if you received a payment, please reach out and we can help you to confirm and develop a plan for completing the reporting. For more information, contact one of our Healthcare Practice specialists or Amber Bichun at abichun@citrincooperman.com and Michael Criscione at mcriscione@citrincooperman.com.