will hhs take back provider relief funds
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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.

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Tu Nguyen, Finance Consultant

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Tu Nguyen holds the position of Senior Finance Consultant at Ryan & Wetmore, P.C., where she primarily works with clients on business consulting, financial planning & analysis, mergers & acquisitions, and various healthcare projects. Tu earned her M.A. degree in Economics from Johns Hopkins University and a B.A. in Economics and Mathematics from Lake Forest College in Illinois.

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Partner & CPA

Traci is a partner with Ryan & Wetmore, PC and is based in our Frederick, MD office.  The Frederick office is home to the firm’s small business services department. Traci currently works with clients on individual, corporate, and tax compliance issues along with a variety of accounting and consulting services for small and medium-sized business owners.

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About Peter Ryan

Partner, Co-founder, & CPA

Peter T. Ryan co-founded Ryan & Wetmore in 1988 with business partner Michael J. Wetmore. Peter provides clients with the best strategies for success. His expertise extends across various industries, including medical practices. Peter obtained a Master of Business Administration in Finance from the University of Baltimore and a Bachelor of Arts in Accounting from the Catholic University of America.

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