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As the next Provider Relief Fund reporting period approaches, long-term care providers must have a clear understanding of the type of relief payments received and establish policies on staffers tasked with submitting the information to avoid potentially significant financial problems.

LeadingAge issued the warning to providers on Wednesday in an effort to ensure they’re prepared for PRF Reporting Period 3, which starts July 1. 

This reporting period requires providers that received one or more general and/or targeted PRF payments exceeding $10,000 in all, between Jan. 1, 2021 and June 30, 2022, to report on the use of their funds. The PRF reporting portal will be open through September 30. Federal health agencies have distributed approximately $13.5 billion in PRF payments to 86,000 providers since November.

Those who don’t properly prepare for the next reporting period could be required to return funds later if their submissions are incorrect, according to Nicole Fallon, LeadingAge’s vice president of health policy and integrated services.

Providers must know which payments they received from the PRF — as opposed to the Paycheck Protection Program, Medicare advanced payments or state grants —  and if they were general or targeted distributions, Fallon explained. This is the way providers can know if their reports include all PRF payments they received. 

“Some providers misunderstood what payments they received were for and failed to include them on their report. This error will require a provider to return the funds that were not reported upon,” Fallon said. 

Time to start talking

She also noted that some providers have inadvertently missed previous PRF reporting deadlines because they failed to communicate among their staff who were responsible for submitting the report — resulting in them being deemed non-compliant with the program. Fallon suggested that now is the time to discuss who will report on the general distributions received. 

Specifically for nursing homes, she added that staff should also be discussing who’s responsible for submitting reports on the Nursing Home Infection Control Quality Incentive Payments received in January and February 2021.

“Make sure the responsible person will not be on vacation when the reports are due,” Fallon warned. 

Providers should also review the terms and conditions associated with receiving the PRF payments, and assess whether they have enough expenses and lost revenues to offset relief payments received in the first half of 2021. 

“If the amount of payments received exceed your organization’s expenses and lost revenues, the difference will have to be returned,” Fallon explained. 

“Nursing homes that received Nursing Home Infection Control Quality Incentive Payments in January and February 2021, should total these dollars received and compare them to the non-reported infection control expenses they have incurred since January 2020,” she added. 

If there aren’t enough expenses to offset the PRF payments during this period, providers do still have time to make purchases, she noted. 

“These expenses must be incurred or projects completed by June 30, 2022, to be applied to [Reporting Period 3],” Fallon said. “Remember, you can only report an expense that is coronavirus related and hasn’t been reimbursed by another source.”