The Health Resources & Services Administration (HRSA) announced April 6 that there would be an opportunity to not only correct reports submitted during PRF Reporting Period 1 (RP1) but also submit reports that may have been missed. This is a rare bit of good news for members who received repayment letters in March due to errors or missed reports from the RP1. LeadingAge is pleased to see its advocacy efforts on behalf of members has paid off in this latest announcement. 

HRSA explains that the only providers who meet one or more of the identified extenuating circumstances will be eligible to submit a Late Reporting Request for Reporting Period 1. These circumstances include: 

• Severe illness or death of a provider or key staff member responsible for reporting
• Impacted by a natural disaster
• Provider did not receive reporting communications from HRSA because their email or mailing address for wrong
• The provider registered, completed their report but forgot to click the “submit” button prior to the deadline
• An internal miscommunication or error about who was authorized and expected to report on behalf of the organization and/or the registered point of contact
• An incomplete targeted distribution report where the parent organization completed all General Distribution payment reports but a targeted distribution was not reported on by the subsidiary (e.g., nursing home). 

If a provider meets one of the above circumstances, they can submit a Late Report Request Form between Monday, April 11 and Friday, April 22 at 11:59 p.m. ET. The “Provider must indicate and attest to a clear and concise explanation related to the applicable extenuating circumstance.”  HRSA will then decide whether it will approve or deny the request. If approved, HRSA will notify the provider that they can complete the missing report in the Reporting Portal within the next 10 business days. There will be no extensions to this timeline so providers should be preparing their documentation as soon as possible and be ready to file once notified they are approved. Providers can review the PRF Reporting Portal User’s Guide to help them determine what information will be required. Providers who have not yet registered in the PRF Reporting Portal should do so now as it will ensure communications from HRSA on this process and expedite their ability to complete the missing reports. 

For those members who received repayment letters from HRSA in March 2022, HRSA asked LeadingAge to convey that members should NOT return funds at present. HRSA will contact providers in the future about returning funds if they fail to submit a Late Reporting Request and complete the missing report, or correct reporting errors for RP1. It should be noted that the Late Reporting Request process is NOT for making correction to a RP1 that was successfully submitted. 

For providers who made errors in their RP1 report, they can contact the Provider Support Line at 866-569-3522 and ask to speak with a Tier 2 representative regarding fixing an error in their RP1 report. They will need to ask for their report to be unlocked or re-opened. The representative will review the reason(s) for your request and notify you if/when your report will be re-opened for correction. Once re-opened, providers will be given a short period of time to complete the corrections and submit the revised report. Anecdotally, some members have had their reports re-opened in circumstances where they missed reporting on a payment because they answered a question wrong and therefore, the payment was not listed in the payment summary in the reporting portal. HRSA has said providers could also use this process to correct situations where a nursing home may have reported all of its infection control expenses in RP1 leaving them with little or no such expenses to apply to the Nursing Home Infection Control and Quality Incentive Payments received, which must be reported upon for Reporting Periods 2 and 3. 

Members with questions on PRF can reach out to Nicole Fallon at LeadingAge.

Questions?

Contact:

David Carter
Director Health Care Finance & Policy
c: 360.888.5702