The Health Resources & Services Administration (HRSA), Department of Health and Human Services (HHS) has announced via its website that for “each PRF Reporting Period,” a provider may file a request to complete their report after the reporting period deadline if one of the following “extenuating circumstances” applies at the time of the reporting period deadline:

• Severe illness or death – a severe medical condition or death of a provider or key staff member responsible for reporting hindered the organization’s ability to complete the report during the Reporting Period.
• Impacted by natural disaster – a natural disaster occurred during or in close proximity of the end of the Reporting Period damaging the organization’s records or information technology.
• Lack of receipt of reporting communications – an incorrect email or mailing address on file with HRSA prevented the organization from receiving instructions prior to the Reporting Period deadline.
• Failure to click “Submit” – the organization registered and prepared a report in the PRF Reporting Portal, but failed to take the final step to click “Submit” prior to deadline.
• Internal miscommunication or error – internal miscommunication or error regarding the individual who was authorized and expected to submit the report on behalf of the organization and/or the registered point of contact in the PRF Reporting Portal.
• Incomplete Targeted Distribution payments – the organization’s parent entity completed all General Distribution payments, but a Targeted Distribution(s) was not reported on by the subsidiary.

Currently, HRSA has only provided a window for submitting such requests for Reporting Period 1, which closed for the last time in December 2022. That window will be from Monday, April 11 to Friday, April 22, 2022 at 11:59 p.m. HRSA has not yet provided a window for submitting these requests for Reporting Period 2, which closed at the end of March 2022. Information on future reporting deadlines can be found here.

If a provider’s Request to Report Late is approved, the provider “will have the opportunity to complete their report in the PRF Reporting Portal.”

If a provider’s Request to Report Late is denied, the provider “will remain non-compliant with the Terms and Conditions and will be required to return all funds to HRSA that were not reported on in the applicable reporting period.”

Providers “must indicate and attest to a clear and concise explanation related to the applicable extenuating circumstance; however, supporting documentation will not be required.” Providers must also “attest to the truthfulness and accuracy of their extenuating circumstance(s) within the Form.”

Practice Tip: While documentation supporting your rationale is not required, we highly recommend keeping the documents that you relied upon in making your Extenuating Circumstances request for some years into the future (at least 3) should your request be audited or reviewed at some point in the future.

If you have missed the reporting deadline for Reporting Period 1 or 2, or any future reporting deadlines, we recommend that you contact an attorney.

Additional details about reporting for the Provider Relief Fund can be found here.