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Dentists and other health care providers who received federal Provider Relief Fund payments during period 3 ― Jan. 1-June 30, 2021 ― are required to use those funds on eligible pandemic-related expenses by June 30, 2022.
Providers must then report the use of those funds between July 1 and Sept. 30, 2022, if the payments exceeded $10,000. Providers will report the use of their period-3 funds through the U.S. Health Resources & Services Administration’s PRF reporting portal. Most dentists who applied for and received PRF payments received them during periods 3 and 4. The portal will not open for period-3 reporting until July 1. Period-4 reporting will open in January 2023.
Under the Provider Relief Fund, allowable expenses are those used to prevent, prepare for and respond to the coronavirus and may include health-care related expenses or general and administrative-related expenses. All recipients of PRF payments are subject to auditing.
Examples of eligible expenses common for dentistry include:
Dentists should read the HRSA’s explanation of allowable expenses for additional guidance, but Haden Werhan, CPA/PFS, an advisor at Thomas Doll, a financial services provider for dentists and physicians, has some immediate advice based on his experience helping dentists navigate earlier Provider Relief Fund payments.
“HHS will look very closely at how funds are used, so it is important to be precise in one’s reporting. Funds must have been used for health care-related expenses before they can be applied to lost revenue,” Werhan says.
Werhan also stresses that dentists should maintain records related to their reporting for at least three years.
HRSA has a “How to Report” webpage with instructions broken into three main steps: registering to use the portal, reading the reporting requirements notice and completing and submitting the report.
Providers will want to have certain information on hand, such as their tax ID or employer identification number and PRF payment information, when registering to use the portal. Providers who submitted a PRF report during a prior reporting period do not need to re-register.
The reporting requirements notice provides details on how to report on the use of the funds and lists the 11 required reporting data categories.
Werhan also cautions against what’s known as double-dipping.
“Most of the COVID-19 relief programs have stringent requirements that funds from multiple sources not be used to cover the same expenses. The best way to avoid having expenses disallowed in a follow-up audit is to maintain good records of which expenses were covered by specific programs, whether EIDL, Paycheck Protection Program or HHS’s Provider Relief Fund.”
Reporting for period 4 ― for PRF payments exceeding $10,000 received July 1-Dec. 31, 2021 ― will open Jan. 1, 2023. Recipients of period-4 payments must use their funds on eligible pandemic-related expenses by Dec. 31, 2022. CDA will remind members of these deadlines as they approach. Watch for updates in the newsroom, weekly member newsletter and on CDA social media.