How to Handle Recent HRSA Notices to Providers for Provider Relief Funding

Recently, the U.S. Department of Health and Human Services Health Resources and Services Administration (“HRSA”) has reached out to providers that received Provider Relief Funds (“PRF”) and American Rescue Plan Rural Distribution Funds (“ARP Rural”) regarding either delinquency in required audit reporting, which must be reported by April 5, 2024, or final repayment notices.

As part of the conditions of funding, any organization that received or spent a total of $750,000 or more in federal funds, including PRF and ARP Rural, in their fiscal year would be subject to the Uniform Guidance Audit requirements, as outlined in the regulations at 45 Code of Federal Regulations (CFR) § 75 Subpart F. This requirement applied to both not-for-profit and for-profit providers. For example, a provider with a traditional calendar year-end who received over $750,000 in PRF and ARP Rural for Periods 1 and 2 would have been subject to this audit requirement.

In addition to the potential audit requirement above, PRF and ARP Rural included terms and conditions that required a provider to submit reporting on the use of the funding to either cover eligible expenditures of the provider or to cover lost revenues of the provider for each period in which funds of payments received exceeded $10,000 in the aggregate. The recent notices regarding requests for repayment of funds have largely impacted providers that did not submit the required reporting for one or more reporting periods.

To settle the issue of delinquency in required audit reporting, HRSA is requiring providers to self-report the audit status by April 5, 2024. As part of this process, providers must either:

For providers that have not yet engaged a firm to complete this audit, Withum’s Healthcare Services Team has extensive experience performing these audits for both not-for-profit and for-profit providers.

For those providers that received final repayment notices, HRSA is allowing providers who disagree with the repayment request an opportunity to request a review of HRSA’s decision. HRSA has set up a portal to upload this request for decision review – Decision Review. In addition, HRSA has provided the following guidance on the decision review process – PRB Decision Review Request Portal User Guide. As part of the decision review process, providers will be able to craft a narrative to explain their position as to why funds will not need to be repaid. In addition, providers will be able to upload supporting documentation to support the narrative provided to HRSA. Withum’s Healthcare Advisory Services Team guided providers throughout the pandemic to assist with required reporting to HRSA. Based on this experience with the program, our healthcare advisory professionals can assist with crafting the narrative and compiling the necessary backup financial information to support limiting any potential required repayment.

Author: James Trubenbach-Byrne, CPA | [email protected]