According to a report by Bloomberg Law on March 30, 2022, the Department of Health and Human Services (HHS) is expecting to recoup approximately $100 million in Provider Relief Fund (PRF) payments from providers that fail to report on their use of funds by November 30, 2021. On March 10th, the Health Resources and Services Administration (HRSA) sent notices to non-compliant providers and gave them 30 days to repay the funds. Some providers that were non-compliant would have to pay back the amount of funds they received from HHS Phase 1, ranging from $30,000 to $250,000.

Will Providers Have Another Chance to Report if They Missed the Deadline?

In a letter to HRSA on March 31, 2022, the American Medical Association (AMA), the Medical Group Management Association (MGMA), and other national medical specialty societies “urge the HSRA to reopen Reporting Period for at least 60 days” so those providers could have another chance to comply with the reporting requirements. The letter indicates that many small and rural physician practices would be affected by the fund claw-back and they are not in the financial position to be refunding those payments.

Important HHS Dates for Phase 3 Provider Relief Fund Recipients

Considering this news, we want to bring some action items to the providers’ attention. As mentioned in our previous blog post, the reporting deadline for use of Phase 2 funds was March 31, 2022.

For providers that received HHS PRF Phase 3 payments exceeding $10,000, Reporting Period 3 will open on July 1, 2022. Providers have until June 30, 2022, to use their funds and must report their use of funds by September 30, 2022.


Providers should ensure that their general ledger and financial reporting are properly reconciled to the amount of funds reported to HSRA. Providers must maintain documentation that fully supports the use of funds and the methodology of lost revenue calculation. Please contact us if you have any questions about allowable expenses or lost revenue.