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Reingruber Alert: Phase 4 General & ARP Rural Distributions for HRSA

9/30/2021 - By Claudia Reingruber, CPA, CHC

HRSA is now accepting applications for $25.5 billion in Phase 4 general & ARP rural distributions.

How to Apply and Related Guidance from HRSA

  • Applications can be submitted beginning September 29, 2021
  • The deadline to apply is October 26, 2021
  • HRSA warning: Failure to adhere to their requirements and instructions "may result in HRSA deeming your application ineligible for payment.” 
  • More information is provided at these links:
    • Application Resources here
    • Application Instructions here
  • HRSA offers technical resources to guide you in the application process:
    • Sample Application form
    • “How to Apply” Flow Chart
    • Worksheets for Patient Care Revenue and Revenue Adjustments
    • Fact Sheets, including for Complex Organizational Structures
    • Frequently Asked Questions (FAQs)
    • Terms and Conditions for Phase 4 and ARP Rural Distributions
    • Payment Calculation Methodologies

Technical Assistance Webinars and Stakeholder Video

  • HRSA is offering webinar sessions for Phase 4 and Rural applicants on these dates:
    • Thursday, September 30 @ 3:00 – 4:00 PM EST - Register Now  
    • Tuesday, October 5 @ 3:00 – 4:00 PM EST - Register Now  
    • Wednesday, October 13 @ 3:00 – 4:00 PM EST - Register Now
    • Thursday, October 21@ 3:00 – 4:00 PM EST - Register Now
  • Department of HHS held a briefing session on $25.5 billion in new distributions. Watch on YouTube here

HRSA Phase 4 “Application Review Process”

  • Defines how new providers in 2019 and 2020 will be evaluated
  • Patient care revenues for DME suppliers and pharmacies will be capped at 10% of their total annual revenue
  • Applicants with financial data that is “anomalous or outside the expected range” and with “potentially high payments” will be subjected to an in-depth manual review 
  • More details are available here

How to Request a Phase 3 Payment Reconsideration

  • Providers who believe their Phase 3 payment was incorrect can now submit a PRF Reconsideration Request
  • Required steps for submitting a Phase 3 Reconsideration Request are:
    • Review the detailed “PRF Phase 3 Calculation Methodology”
    • Complete the “PRF Reconsideration Request Form”
    • Submit the completed form online
  • Complete and submit the Phase 3 Payment Reconsideration Request online through this link using DocuSign

New and Updated PRF Info Posted by HRSA

60-Day Grace Period for 1st Reporting Period

  • The grace period does not extend the 09/30/2021 deadline 
  • The grace period permits providers to come into compliance if they fail to meet the deadline
  • Those that are “out of compliance” will not be subject to recoupment or other enforcement actions
  • The grace period begins 10/01/2021 and ends on 11/30/2021
  • HRSA “strongly encourages” providers to complete their reporting by 09/30/2021


Does all this make your head spin?

Don't worry, we can help...

  • Identify all appropriate COVID expenses and lost revenues
  • Consider the potential impact of new PRF reporting guidance
  • Prepare a timely application for Phase 4 and/or ARP Rural Distributions
  • Determine if you may qualify for a Phase 3 reconsideration request 
  • Assemble documentation to prepare for possible audits of PRF fund use
  • Evaluate if the Single Audit requirement applies to you
  • Review PRF worksheets for optimal and compliant 1st PRF reporting!

Join our Reingruber Alert email list to receive the latest post-acute healthcare updates or contact our team if you have questions regarding this Alert.


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