In a notice published on April 7, 2022, the Health Resources and Services Administration (HRSA), the division of HHS that manages the distribution and oversight of CARES Act Provider Relief Funds (PRFs), requested comments from stakeholders on proposed changes to its Information Collection Request (ICR) Form that it will be submitting to the Office of Management and Budget (OMB).
The approved ICR uses an OMB form that is set to expire on January 1, 2023, so HRSA is requesting comments before submitting revisions to OMB. This is the first opportunity for providers who were subject to the first two PRF reporting periods (Period 1 and Period 2) to comment on the reporting program and provide feedback on requirements related to those reports. In addition to revising the PRF reporting form, HRSA is looking to add reporting for the American Rescue Plan (ARP) rural provider program to the ICR.
The ARP rural provider program was put in place by Congress to provide payments to providers and suppliers who served rural Medicaid, CHIP and Medicare beneficiaries from January 1, 2019 through September 30, 2020. The ARP Rural plan is distinct from the PRF, but it has similar reporting requirements and uses the PRF reporting portal for applications.
In its new ICR, HRSA provided estimated annualized burden hours for each PRF reporting period. HRSA defines “burden” as the time expended by affected providers to generate, maintain, retain, disclose, or provide the information requested by the ICR. The estimated burden time in hours for Period 1 and 2 were 5.6 and 4.2 hours, respectively. HRSA specifically seeks comments addressing: (1) the necessity and utility of the proposed information collection for the proper performance of the agency’s functions; (2) the accuracy of the estimated burdens; (3) suggestions to enhance the quality, utility, and clarity of the collected information; and (4) the use of technology to minimize the burden on providers.
As we noted in an earlier blog post, the reporting period requirements are important for all providers and suppliers who receive funds from the PRF. HRSA had previously announced an April 9, 2022 clawback date for any providers who failed to meet their reporting requirements for Period 1, although that date was tempered with an allowance for extra time for providers and suppliers who encountered “extenuating circumstances” and failed to properly report.
Comments on this new ICR can be submitted by electronic mail to firstname.lastname@example.org or mail the HRSA Information Collection Clearance Officer, Room 14N136B, 5600 Fishers Lane, Rockville, MD 20857. Comments must be provided before June 6, 2022.
Reed Smith will continue to track developments related to HRSA provider relief funding and reporting requirements. Please reach out to the authors of this post or to the health care attorneys at Reed Smith if you have any questions or for assistance in submitting comments.