HRSA identifies permissible extenuating circumstances for late reporting of vendor relief funds


April 11, 2022

As previously reported, the Health Resources and Services Administration (HRSA) has decided to reopen the reporting deadline for recipients of Period 1 provider relief funds. Physicians who received more than $10,000 in relief funds from the supplier and who have not submitted their Period 1 report should act immediately.

Between Monday, April 11 and Friday, April 22, 2022 at 11:59 p.m. ET, suppliers who have not submitted their report for Period 1 may submit a report request for Reporting Period 1 late. During this reopening period, a supplier must choose one or more extenuating circumstances that prevented the original reporting deadline from being met.

HRSA has just released the following as allowable extenuating circumstances:

  • Serious illness or death – a serious medical condition or death of a supplier or key staff member responsible for the report has hindered the organization’s ability to complete the report during the reporting period.
  • Impacted by a natural disaster – a natural disaster has occurred during or near the end of the reporting period, damaging the organization’s records or information technology.
  • Lack of receipt of communications relating to the reports – an incorrect email or postal address on file with the HRSA prevented the organization from receiving instructions before the reporting period deadline.
  • Do not click “submit” – the organization has registered and prepared a report in the PRF reporting portal, but has not completed the final step of clicking “submit” by the deadline.
  • Internal miscommunication or error – Internal miscommunication or error regarding the person authorized and supposed to submit the report on behalf of the organization and/or the point of contact registered in the PRF reporting portal.
  • Incomplete targeted distribution payments – the parent entity of the organization has made all general distribution payments, but no targeted distributions have been declared by the subsidiary.

Although certification of a mitigating circumstance is required, no voucher or supporting document is required. If the HRSA approves the Mitigated Circumstances Form, the supplier will receive a notification to complete the Reporting Period 1 report shortly thereafter. Suppliers will have 10 days from the date of receipt of the notification to submit the Period 1 Overdue Report in the PRF Reporting Portal. More information is available here.

The American Medical Association, California Medical Association (CMA), and other organized medicine stakeholders are working with the HRSA to identify and reach out to the remaining practices that have not reported compliance.

Physicians who need help can call the CMA Member Resource Center at (800) 762-4262 or [email protected]

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