PRF Reporting Remediations

PRF Reporting Activities - 7 Public Comments Remediations.pdf

COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Payment Reporting Activities

PRF Reporting Remediations

OMB: 0906-0068

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Health Resources and Services Administration
PUBLIC COMMENTS REMEDIATIONS
COVID-19 Provider Relief Fund (PRF) Reporting Activities
OMB No. 0906-0068-Revision
The Health Resources and Services Administration (HRSA) is submitting an explanation of
remediations to issues raised previously in the 2022 package that has been fixed with the latest
revisions in the 2023 package. Details on the remediation enhancements are provided in the
“PRF Reporting Activities 6 PRF Portal Enhancements” document and included in the tables
listed below.

PRF Reporting
Activities – 6 PRF Port

Public Comments to FRN (2021 Package)
Date
Received
07/26/2021

From

Organization

Claire Ernst,
Director
Government
Affairs

Medical Group
Management
Association

Inquiry/
Comment
I’m writing to
inquire further
about the
COVID–19
Provider Relief
Fund Reporting
Activities ICR.
Specifically, I
would like
clarification on
whether the
“total estimated
annualized
burden hours”
table represents
total burden
hours for PRF
recipients or for
HRSA staff?
The notice states
that HRSA is
seeking
comments from
the public
regarding the

Response

Remediation

Thank you for your
inquiry regarding the
COVID–19 Provider
Relief Fund Reporting
Activities Federal
Register Notice. The
“total estimated
annualized burden hours”
table represents total
average burden hours for
Provider Relief Fund
(PRF) recipients
(providers).

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

8/12/2021

Taylor
Salmon,
Manager
Assurance
Services

Ernst & Young
LLP

burden estimate,
but it is unclear
who these
questions are
geared towards.
Any input is
appreciated.
You can also
call me at (410)
7075524.
Thanks!
Pursuant to
Public Comment
Request and
Information
Collection
Request
“COVID-19
Provider Relief
Fund Reporting
Activities, OMB
No. 0906XXXX New”, I
would like to
request:
1. More
information on
the proposed
project
2. A copy of the
data collection
plans
3. A copy of the
draft instruments
Comments and
Questions
1. What type of
documentation is
being requested?
Is data outside of
the PRF
Reporting portal
being requested?
2. How will the
information
collected assist
with conducting
audits?

Thank you for your
email. Please see our
responses below.

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
• More information on
Reporting Requirements
the proposed project
October – 2022 and resources.
Also See:
The Provider Relief Fund https://www.hrsa.gov/provider
-relief/reportingsupports American
families, workers, and the auditing/reporting-resources
and
heroic healthcare
https://prfreporting.hrsa.gov/s/
providers in the battle
against the COVID-19
outbreak. HHS is
distributing $178 billion
to hospitals and
healthcare providers on
the front lines of the
coronavirus response.
All recipients of Provider
Relief Fund payments are
required to comply with
the reporting
requirements described in
the Terms and Conditions
and specified in future
directions issued by the
HHS Secretary. The
report mechanism, as
written in the Federal
Register Notice, is the
mechanism for which
HRSA will collect this
information.
• A copy of the data
collection plans
Data collection plans are

3. Does the
average burden
per response (in
hours) represent
the amount of
time HRSA will
review each
respondent’s
PRF Report?
Does this
include
potentials
audits?
4. Will the
information
collected impact
future PRF
distributions for
respondents?
5. Will the
information
collected in the
first PRF
Reporting Portal
period be used
or saved for the
respondents’
second PRF
Reporting
period?

outlined in the June 11
Notice of Post-Payment
Reporting Requirements
at
https://www.hrsa.gov/site
s/default/files/hrsa/provid
er-relief/provider-postpayment-notice-ofreporting-requirementsjune-2021.pdf .
• A copy of the draft
instruments
There are various
resources available
online that outlines and
thoroughly describes the
report instrument. They
can be found here under
the resources section.
1. What type of
documentation is being
requested? Is data
outside of the PRF
Reporting portal being
requested?
Documentation requested
is outlined in the June 11
Post-Payment Notice of
Reporting Requirements.
There is no data
collection outside the
PRF Reporting Portal.
2. How will the
information collected
assist with conducting
audits?
HRSA’s audit strategies
use data collected from
the PRF report to assess
and ensure compliance
with payment Terms and
Conditions.
3. Does the average

burden per response (in
hours) represent the
amount of time HRSA
will review each
respondent’s PRF
Report? Does this
include potentials audits
The average burden per
response represents the
amount of time Provider
Relief Fund recipients
will need to complete and
submit the report as
required by the Terms
and Conditions. These
numbers take into
account the amount of
PRF funding received,
hours required by size of
funding and number of
providers estimated to
report by reporting
period.
4. Will the information
collected impact future
PRF distributions for
respondents?
At this time, we do not
have information to share
regarding any future PRF
distributions.
5. Will the information
collected in the first PRF
Reporting Portal period
be used or saved for the
respondents’ second PRF
Reporting period?
HRSA is currently
assessing and developing
the report portal for the
second PRF reporting
period. Where possible,
we will consider your
suggestion to save
previously entered
provider data in the

portal.

8/18/2021

Meredith
Yinger, Senior
Regulatory
Strategist

American
Academy of
Family
Physicians

Attached please
find comments
from the
American
Academy of
Family
Physicians in
response to the
information
collection on
COVID-19
Provider Relief
Fund Reporting
Activities (OMB
No. 0906XXXX New).
We appreciate
the opportunity
to provide
feedback on
family
physicians’
experience with
PRF reporting
requirements.
Please don’t
hesitate to
contact me if
you have any
questions or
would like to
discuss this letter
further.

AAFP Letter to HRSA
on PRF Reporting Burd

Thank you for your
feedback regarding the
COVID-19 Provider
Relief Fund Reporting
Activities as published in
the Federal Register on
July 26, 2021. HRSA
seeks to be as helpful as
possible in supporting
providers as they
complete their reporting
obligations. We will
continue to share
resources and additional
guidance as they become
available.
You raise a number of
important considerations
and suggestions related to
the reporting
requirements, burden,
resources, and customer
support. At this time we
are actively reviewing
these considerations as
we refine our reporting
strategy and plans for
additional guidance and
resources.
Specifically, you asked
for clarity on the term
“due to COVID”. The
PRF, has disbursed funds
to eligible health care
providers to support
health care-related
expenses or lost revenues
attributable to the
COVID-19 pandemic.
Included below is an
updated Frequently
Asked Question (FAQs)
that may be helpful to
reference.
How does a Reporting
Entity determine whether
an expense is eligible for
reimbursement through

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

the Provider Relief Fund?
(Modified 7/1/2021)
To be considered an
allowable expense under
the PRF, the expense
must be used to prevent,
prepare for, and respond
to coronavirus. PRF
payments may also be
used for lost revenues
attributable to the
coronavirus. Reporting
Entities are required to
maintain adequate
documentation to
substantiate that these
funds were used for
health care-related
expenses or lost revenues
attributable to
coronavirus and that
those expenses or losses
were not reimbursed
from other sources and
other sources were not
obligated to reimburse
them. Reporting Entities
are not required to submit
that documentation when
reporting. Providers are
required to maintain
supporting
documentation which
demonstrates that costs
were incurred during the
Period of Availability.
The Reporting Entity is
responsible for ensuring
that adequate
documentation is
maintained. See
https://www.hrsa.gov/pro
vider-relief/faq/reporting
As we refine our
reporting strategy, please
look for current, new,
and updated resources
including reporting
requirements, FAQs, and

opportunities for future
funding, on HRSA’s PRF
webpage at
www.hrsa.gov/providerrelief.

9/3/2021

Dawn Ksepka,
Vice President
of Finance and
System
Controller

Fairview
Health Services

In response to
the HRSA
request for
comment
https://publicinspection.federa
lregister.gov/202
1-15885.pdf
regarding the
estimated burden
for submitting
information
through the PRF
Reporting Portal,
please find our
response.

Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.

HRSA
specifically
requests
comments on:
1. The necessity
and utility of the
proposed
information
collection;
2. The accuracy
of the estimated
burden;
3. Ways to
enhance quality,
utility, and
clarity of the
information
collected; and
4. The use of
automated
collection
techniques or
other forms of
information
technology to
minimize the
information
collection
burden.

You raise a number of
important considerations
and suggestions related to
the reporting
requirements, data
collection, and system
functionality. At this
time we are actively
reviewing these
considerations as we
refine our reporting
strategy and plans for
additional guidance and
resources.

Fairview Health
Services has
prepared the
following

Regarding your concern
on the estimated burden
hours, the average burden
per response represents
the amount of time
Provider Relief Fund
recipients will need to
complete and submit the
report as required by the
Terms and Conditions.
These calculations take
into account averages in
the amounts of PRF
funding received, hours
required by size of
funding, and the number
of providers estimated to
report by reporting
period. We appreciate

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

information in
response to your
request for
comment on
COVID-19
Provider Relief
Fund Reporting
Activities, OMB
No. 0906XXXX New.
1.) The data
request would be
significantly
simplified by the
following:
a.) Information
could be
presented for the
health system
instead of
entities receiving
target funds
being required to
report, even if
those funds are
transferred to the
Parent entity.
Under the
current
requirements,
Fairview Health
Services was
required to
submit 7
registrations and
will submit 13
reports over the
three required
reporting
periods.
b.) Expenses
were not
required to be
reported before
lost revenue
when lost
revenue alone
would be
sufficient to

your feedback and will
continue to assess the
burden on providers and
where possible,
streamline the reporting
portal and eliminate any
unnecessary burden.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the
PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including
reporting requirements,
frequently asked
questions, and
opportunities for future
funding.

support
utilization of the
grant award.
c.) Lost revenue
reporting would
be significantly
simplified if it
did not require
reporting by
payor category.
This information
is not available
out of our
accounting
system and
requires data to
be extracted and
combined from a
variety of
revenue cycle
billing systems.
2.) Fairview
Health Services
was required to
submit 7
registrations and
will submit 13
reports over the
three required
reporting
periods. We
estimate that the
average response
per report will
be 40 hours for a
total reporting
burden to our
Health System
of 520 hours.
3.) Ways to
enhance the
quality, utility
and clarity of the
information
collected
a. Personnel
information
should not

require inclusion
of contractor
resources which
are not included
in our human
resources
subsystem and
cannot be easily
combined with
employee data
b. Interest rate
calculation
should occur at
the end of the
process after the
utilization of
funds are
reported
c. Calculation
within the portal
included funds
that were
transferred from
other
registrations
4.) The
registration
process and
portal are easy to
utilize but could
be enhanced by
the following
a.) Ability to
move forward,
backward, and
save information
entered without
submitted all
required
information

9/15/2021

Jenna Stern,
Sr Regulatory
Affairs &
Public Policy
Director

Vizient

My organization
may comment
on the PRF
reporting
requirements (86
FR 40064). I am
interested in
learning if you
can share the
data collection
plans and draft
instruments?

9/21/2021

Jennifer
Nading
Director,
Medicare and
Medicaid
Policy and
Regulatory
Affairs

Trinity Health

Trinity Health
appreciates the
support the
Department of
Health and
Human Services
and the Health
Resources and
Services
Administration
have provided to
hospitals and
physicians who
are addressing
the COVID-19
pandemic.
Attached are
comments on the
questions posed
by HRSA,
please let me
know if you
have any
questions.

Trinity Health
Comments COVID19 P

Thank you for contacting
the Provider Relief Fund.
In response to your
email, data collection
plans are outlined in the
June 11 Notice of PostPayment Reporting
Requirements. There are
various resources
available online that
summarizes and
thoroughly describes the
report instrument. They
can be found at
prfreporting.hrsa.gov
under the resources
section.
Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.
You raise a number of
important considerations
and suggestions related to
the reporting
requirements, data
collection, and system
functionality. At this
time we are actively
reviewing these
considerations as we
refine our reporting
strategy and plans for
additional guidance and
resources.
As we continue to
evaluate feedback from
you and other
stakeholders to inform

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

9/22/2021

Alexandra
Donnelly,
MPH
Health Policy
Advisor
Center for
Health Policy
& Health
Services
Research

Henry Ford
Health System

On behalf of the
Henry Ford
Health System, I
want to thank
you for the
opportunity to
comment on
“COVID-19
Provider Relief
Fund Reporting
Activities, OMB
No. 0906XXXX New.”
This letter is
submitted on
behalf of James
Douglas Clark,
Senior Vice
President of
Corporate
Financial
Services at
Henry Ford
Health System.
Questions or
comments for
Mr. Clark can be
sent to
Alexandra
Donnelly, at

our ability to administer
the PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including
reporting requirements,
frequently asked
questions, and
opportunities for future
funding.
Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.
You raise a number of
important considerations
and suggestions related to
the reporting
requirements and data
collection. At this time
we are actively reviewing
these considerations as
we refine our reporting
strategy and plans for
additional guidance and
resources.
Regarding your concern
on the estimated burden

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

adonnel1@hfhs.
org.

Henry Ford Health
System Comment Lett

hours, the average burden
per response represents
the amount of time
Provider Relief Fund
recipients will need to
complete and submit the
report as required by the
Terms and Conditions.
These calculations take
into account averages in
the amounts of PRF
funding received, hours
required by size of
funding, and the number
of providers estimated to
report by reporting
period. We appreciate
your feedback and will
continue to assess the
burden on providers and
where possible,
streamline the reporting
portal and eliminate any
unnecessary burden.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the
PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including
reporting requirements,
frequently asked
questions, and
opportunities for future
funding.

9/23/2021

Chad Mulvany California
Vice
Hospital
President,
Association
Federal Policy

Please find the
attached
comments
submitted on
behalf of the
California
Hospital
Association
(CHA) in
response to the
request for
information on
the burden
associated with
COVID-19
Provider Relief
Fund (PRF)
reporting. CHA
appreciates the
opportunity to
offer comments
on necessary
clarifications to
the PRF
reporting
instructions. If
you have any
questions, please
do not hesitate to
contact me at
(202) 270-2143
or
cmulvany@calh
ospital.org.

CHA HRSA Reporting
Requirements RFI Com

Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.
You raise a number of
important considerations
and suggestions related to
the reporting
requirements, data
collection, provider
burden, and system
functionality. At this
time we are actively
reviewing these
considerations as we
refine our reporting
strategy and plans for
additional guidance and
resources.
Regarding your concern
on the estimated burden
hours, the average burden
per response represents
the amount of time
Provider Relief Fund
recipients will need to
complete and submit the
report as required by the
Terms and Conditions.
These calculations take
into account averages in
the amounts of PRF
funding received, hours
required by size of
funding, and the number
of providers estimated to
report by reporting

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

period. We appreciate
your feedback and will
continue to assess the
burden on providers and
where possible,
streamline the reporting
portal and eliminate any
unnecessary burden.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the
PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including
reporting requirements,
frequently asked
questions, and
opportunities for future
funding.

9/24/2021

Candice
Dailey
American
Hospital
Association,
Policy Dept.

American
Hospital
Association

Please see
attached letter
from the
American
Hospital
Association Re:
Agency
Information
Collection
Activities:
Proposed
Collection:
Public Comment
Request;
Information
Collection
Request Title:
COVID–19
Provider Relief
Fund Reporting
Activities, OMB
No. 0906–
XXXX New
(Vol. 86, No.
140), July 26,
2021.

2021-09-24-LTR-HRS
APRFPRA.pdf

Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
described in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.
You raise a number of
important considerations
and suggestions related to
the Provider Relief Fund
program, program
eligibility, reporting
requirements, and data
collection. At this time
we are actively reviewing
these considerations as
we refine our program,
reporting strategy, and
plans for additional
guidance and resources.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the
PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

information, including
reporting requirements,
frequently asked
questions, and
information on
opportunities for future
funding.

9/24/2021

Anthony
Curry,
Director,
Federal
Government
Affairs

Advocate
Aurora Health

Attached please
find Advocate
Aurora Health’s
comments in
response to the
Health
Resources and
Services and
Administration’s
request for
comments on the
COVID-10
Provider Relief
Fund Reporting
Activities.
We appreciate
the agency’s

Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

consideration of
our comments.
AAH HRSA 86 FR
40064.pdf

You raise a number of
important considerations
and suggestions related to
the reporting
requirements and data
collection. At this time
we are actively reviewing
these considerations as
we refine our reporting
strategy and plans for
additional guidance and
resources.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the
PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.

9/24/2021

Jenna Stern
Sr Regulatory
Affairs &
Public Policy
Director

Vizient

Please accept the
following
comments
regarding
HRSA’s notice,
“Agency
Information
Collection
Activities:
Proposed
Collection:
Public Comment
Request;

Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including
reporting requirements,
frequently asked
questions, and
opportunities for future
funding.
Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

Information
Collection
Request Title:
COVID-19
Provider Relief
Fund Reporting
Activities, OMB
No. 0906XXXX New”.

HRSA PRF Comments
9 17 FINAL.pdf

transparency and
proactive communication
about the PRF.
You raise a number of
important considerations
related to the reporting
requirements and data
collection. At this time
we are actively reviewing
these considerations as
we refine our reporting
strategy and plans for
additional guidance and
resources.
Regarding your concern
on the estimated burden
hours, the average burden
per response represents
the amount of time
Provider Relief Fund
recipients will need to
complete and submit the
report as required by the
Terms and Conditions.
These calculations take
into account averages in
the amounts of PRF
funding received, hours
required by size of
funding, and the number
of providers estimated to
report by reporting
period. We appreciate
your feedback and will
continue to assess the
burden on providers,
including with any future
distributions, and where
possible, streamline the
reporting portal and
eliminate any
unnecessary burden.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the

PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.

9/24/2021

Erin
O’Malley,
Senior
Director of
Policy

America’s
Essential
Hospitals

Please find
attached a
comment letter
from America’s
Essential
Hospitals on the
Health
Resources and
Services
Administration’s
proposed
information
collection
request on
Provider Relief
Fund reporting
activities.
Thank you for
your
consideration of
these comments.
Please do not
hesitate to
contact me with
any questions.

FINAL AEH comment
letter HRSA PRF ICR 9-

Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including
reporting requirements,
frequently asked
questions, and
opportunities for future
funding.
Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.
You raise a number of
important considerations
and suggestions related to
the reporting
requirements, data
collection, and system
functionality. At this
time we are actively
reviewing these
considerations as we
refine our reporting
strategy and plans for
additional guidance and
resources.

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

Regarding your concern
on the estimated burden
hours, the average burden
per response represents
the amount of time
Provider Relief Fund
recipients will need to
complete and submit the
report as required by the
Terms and Conditions.
These calculations take
into account averages in
the amounts of PRF
funding received, hours
required by size of
funding, and the number
of providers estimated to
report by reporting
period. We appreciate
your feedback and will
continue to assess the
burden on providers and
where possible,
streamline the reporting
portal and eliminate any
unnecessary burden.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the
PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including
reporting requirements,
frequently asked
questions, and

opportunities for future
funding.

11/8/2021

Kara Webb,
Chief
Strategy
Officer

American
Optometric
Association

Attached are
comments on the
HRSA
submission to
OMB for
Review and
Approval:
COVID-19
Provider Relief
Fund (PRF)
Reporting
Activities.
Thank you for
the opportunity
to provide
comment.
HRSA PRF Burden
Estimate.pdf

Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.
Regarding your feedback
on the estimated burden
hours, the average burden
per response represents
the amount of time
Provider Relief Fund
recipients will need to
complete and submit the
report as required by the
Terms and Conditions.
These calculations take
into account averages in
the amounts of PRF
funding received, hours
required by size of
funding, and the number
of providers estimated to
report by reporting
period. We appreciate
your feedback and will
continue to assess the

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

burden on providers and
where possible,
streamline the reporting
portal and eliminate any
unnecessary burden.
We thank you for
providing additional
resources to your
members and helping to
guide doctors of
optometry through the
Provider Relief Fund
reporting process.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the
PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including
reporting requirements,
frequently asked
questions, and
opportunities for future
funding.

11/19/2021

Daniel
Samson,
Director of
Government
Relations

Argentum

1. Extend
the
Period 2
reportin
g
deadline
: HRSA
underest
imates
the time
burden
of
complyi
ng with
PRF
reportin
g
requirem
ents.
Further,
many
assisted
living
commun
ities are
still very
much
engaged
in the
same
COVID19
safety
protocol.
Given
this
ongoing
burden,
the
organiza
tion is
asking
for an
extensio
n to the
reportin
g
deadline
for
Period 2,
to allow

Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.
Regarding your feedback
on the estimated burden
hours, the average burden
per response represents
the amount of time
Provider Relief Fund
recipients will need to
complete and submit the
report as required by the
Terms and Conditions.
These calculations take
into account averages in
the amounts of PRF
funding received, hours
required by size of
funding, and the number
of providers estimated to
report by reporting
period. We appreciate
your feedback and will
continue to assess the
burden on providers and
where possible,
streamline the reporting
portal and eliminate any
unnecessary burden.
You raise a number of
important considerations
and suggestions related to
the Provider Relief Fund
program, reporting
requirements, data
collection, and ongoing

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

more
time for
provider
s to
comply.
2. Urges
HRSA
to
expediti
ously
distribut
e $25.5
billion
($17
billion
for
Phase 4
and $8.5
billion
for
ARPA)
before
the end
of the
year.
Urges
HRSA
to
prioritiz
e
assisted
living
provider
s in the
Phase 4
applicati
on
process.
Argentum_HRSA_86
FR58079_Nov2021_Co

funding strategies. At
this time we are actively
reviewing these
considerations as we
refine our program,
reporting strategy, and
plans for additional
guidance and resources.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the
PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including
reporting requirements,
frequently asked
questions, and
opportunities for future
funding.
Thank you,
Provider Relief Fund

11/19/2021

Laura
Spadaro, Vice
President of
Primary Care
and Public
Health Policy

The Wright
Center for
Community
Health/The
Wright Center
for Graduate
Medical
Education

1. Confirm
s the
necessit
y and
utility of
the
propose
d
informat
ion
collectio
n for
proper
perform
ance of
the
agency’s
function
s.
2. Confirm
s the
accuracy
of the
estimate
d
burden.
3. Provides
a
suggesti
on to
enhance
the
quality,
utility,
and
clarity
of the
informat
ion
collectio
n.
4. Appreci
ation for
HRSA’s
commit
ment
and
interest
in
explorin
g

Thank you for your
comments on the
COVID-19 Provider
Relief Fund (PRF)
reporting activities as
requested in the Federal
Register on July 26,
2021. As we continue
navigating this pandemic,
the Health Resources and
Services Administration
(HRSA) appreciates
opportunities for greater
transparency and
proactive communication
about the PRF.
You raise a number of
important considerations
and suggestions related to
the Provider Relief Fund
program, reporting
requirements, and data
collection. At this time
we are actively reviewing
these considerations as
we refine our program,
reporting strategy, and
plans for additional
guidance and resources.
As we continue to
evaluate our processes
and resources, feedback
from you and other
stakeholders informs our
ability to administer the
PRF in a manner that
bolsters the health care
system and helps
providers experiencing
COVID-related financial
hardships during this
crisis.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/pro
vider-relief/ for
frequently updated
information, including

Addressed in previous
response, in addition updated,
data, portal enhancements and
Post Payment Notice of
Reporting Requirements
October – 2022 and resources.
Also See:
https://www.hrsa.gov/provider
-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov/s/

methods
to
automat
e the
informat
ion
collectio
n.

reporting requirements,
frequently asked
questions, and
opportunities for future
funding.
Thank you,
Provider Relief Fund

Public Comments to FRN (2022 Package)
Date
Received
4/28/2022

From
Carrie
Cochran
McClain

Organizati
on
National
Rural
Health
Association

Inquiry/ Comment

Response

Remediation

I’m writing regarding
the following FR
notice about the PRF
information
collection request,
https://www.federalre
gister.gov/documents
/2022/04/07/202207408/agencyinformationcollection-activitiesproposed-collectionpublic-commentrequest-covid-19

Thank you for your email.
Please see the information
provided below.

Addressed in previous
response, in addition
updated, data, portal
enhancements and Post
Payment Notice of
Reporting Requirements
October – 2022 and
resources. Also See:
https://www.hrsa.gov/provid
er-relief/reportingauditing/reporting-resources
and
https://prfreporting.hrsa.gov
/s/

I’d like to received a
copy of the proposed
information
collection document
revisions to review.
Please let me know if
you need any
additional
information.
Appreciate the
consideration.

All recipients of Provider
Relief Fund payments are
required to comply with
the reporting requirements
described in the Terms and
Conditions and specified in
future directions issued by
the HHS Secretary. The
Terms and Conditions are
located at
https://www.hrsa.gov/provi
der-relief/pastpayments/termsconditions.
Data collection plans are
outlined in the June 11,
2021 Notice of PostPayment Reporting
Requirements at
https://www.hrsa.gov/sites/
default/files/hrsa/providerrelief/provider-postpayment-notice-ofreporting-requirementsjune-2021.pdf. HRSA
will be publishing an
updated Notice of PostPayment Reporting
Requirements in the
coming weeks. This
update will include ARP
funding requirements and
the 5th reporting period
details for the associated
payments and will be
available on the Provider
Relief Fund Reporting
Requirements and
Auditing webpage:
https://www.hrsa.gov/provi
der-relief/reportingauditing.

Various resources are
available online that
outline and thoroughly
describe the reporting
instrument. Resources are
located under the resources
section of the PRF Website
at
https://www.hrsa.gov/provi
der-relief/reportingauditing/reportingresources.
Please visit HHS’s PRF
webpage at
https://www.hrsa.gov/provi
der-relief/ for frequently
updated information,
including reporting
requirements, frequently
asked questions, and
opportunities for future
funding.
If you have any further
questions, please reach out
to Sharon Loper, Director
of the Customer Support
Division, at
[email protected].


File Typeapplication/pdf
AuthorMcGowan, Renee (HRSA)
File Modified2023-01-18
File Created2023-01-18

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