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ARP Rural Requirements

On Nov. 23, 2021, the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), began distributing American Rescue Plan (ARP) Rural payments to providers and suppliers who serve rural Medicaid, Children's Health Insurance Program (CHIP), and Medicare beneficiaries. The ARP Rural payments are being made to providers based on the amount and type of services they provide to Medicare, Medicaid, and CHIP patients who live in rural areas, as defined by the Federal Office of Rural Health Policy.

Approximately 96 percent of ARP Rural applications have now been processed. Applicants receiving payments will receive both an email notification as well as a paper letter with additional detail on their aggregate payment. Providers who have not yet received any communication regarding their payment determination will be notified as soon as HRSA completes the review and processing of the remaining applications. For information on how payments are calculated, please visit the Provider Relief Fund (PRF) Phase 4 Payment Methodology webpage.

Within 90 days of receiving a payment, ARP Rural recipients must sign an attestation confirming receipt of the funds and agreeing to the Terms and Conditions of payment by re-entering the PRF Application and Attestation Portal. Providers choosing to reject the funds must also complete the attestation and return the funds within 15 calendar days.

Providers receiving ARP Rural funds should be aware that the Terms and Conditions require recipients to maintain advance payments in interest-bearing accounts, unless the qualifying exemptions listed below are met:

  • The non-federal entity receives less than $120,000 in federal awards per year.
  • The best reasonably available interest-bearing account would not be expected to earn interest in excess of $500 per year on federal cash balances.
  • The depository would require an average or minimum balance so high that it would not be feasible within the expected federal and non-federal cash resources.
  • A foreign government or banking system prohibits or precludes interest-bearing accounts.

Those receiving more than $10,000 in aggregate payments must also report the amount of interest earned.

HRSA expects to begin releasing PRF Phase 4 payments in December 2021. Like the ARP Rural payments, HRSA plans to send individual communications to providers when final payment determinations are made.

Reporting Period 1 – 60-Day Grace Period

Members who received more than $10,000 in PRF funding prior to July 1, 2020 are reminded that reporting associated with that funding was due through the PRF Reporting Portal by Sept. 30th. However, HRSA has provided a 60-day grace period to the Sept. 30th deadline in response to challenges providers are facing given recent COVID-19 surges and natural disasters around the country. Providers who were unable to submit their PRF reporting by the deadline still have until Nov. 30, 2021. HRSA stresses that:

  • While you are considered to be out of compliance if you did not submit your report by Sept. 30, 2021, recoupment or other enforcement actions will not be initiated during the 60-day grace period.
  • The grace period began on Oct. 1, 2021 and will end on Nov. 30, 2021.
  • Providers should return unused funds as soon as possible after submitting their report. All unused funds must be returned no later than 30 days after the end of the grace period (Dec. 30, 2021).
  • Phase 4 payments will be withheld from providers who do not meet the deadline.

HRSA recently stated that there is some flexibility in reporting the use of PRF funds. This may be important for nursing home members who received Nursing Home Infection Control (NHIC) incentive payments because these payments can only be used for infection control expenses and will not be reported until the second or third reporting periods. Homes may have the opportunity to use their PRF General Distribution payments to cover lost revenues and expenses by waiting until the second or third reporting period to report infection control expenses. HRSA also confirmed that PRF General Distribution funds can be used to cover COVID-19 staff testing costs that were not reimbursed or obligated to be reimbursed by another source. Providers should document that the testing expenses were to prevent, prepare for, and respond to coronavirus and that they were not reimbursed by other sources. This documentation needs to be maintained by the provider, not submitted as part of the reporting process.

Contact: Ken Allison, kallison@leadingageny.org, 518-867-8820