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IMPORTANT PRF UPDATE! HRSA Allows Providers the Opportunity to Correct Missed Period 1 Reporting

Client Alert

Late Wednesday, April 6, HRSA announced that it was going to allow providers with extenuating circumstances that prevented them from preventing a completed Period 1 Report to submit a Request to Report Late Due to Extenuating Circumstances. More information on the process and links to the required forms can be found here.

Providers who failed to report in Period 1 and failed to return their Period 1 PRF payments should have received an email on Wednesday, April 6. If a provider did not receive an email, the provider should go onto the portal and ensure that all provider contact information is correct. All providers must be appropriately registered with the Portal in order to engage in this process.

Step 1:  Providers must first submit a Request to Report Late Due to Extenuating Circumstances. Requests must be submitted between Monday, April 11 to Friday, April 22 at 11:59pm ET. Extenuating circumstances include the following instances: 

  • Severe illness or death – a severe medical condition or death of a provider or key staff member responsible for reporting hindered the organization’s ability to complete the report during the Reporting Period.
  • Impacted by natural disaster – a natural disaster occurred during or in close proximity of the end of the Reporting Period damaging the organization’s records or information technology.
  • Lack of receipt of reporting communications – an incorrect email or mailing address on file with HRSA prevented the organization from receiving instructions prior to the Reporting Period deadline.
  • Failure to click “Submit” – the organization registered and prepared a report in the PRF Reporting Portal, but failed to take the final step to click “Submit” prior to deadline.
  • Internal miscommunication or error – internal miscommunication or error regarding the individual who was authorized and expected to submit the report on behalf of the organization and/or the registered point of contact in the PRF Reporting Portal.
  • Incomplete Targeted Distribution payments – the organization’s parent entity completed all General Distribution payments, but a Targeted Distribution(s) was not reported on by the subsidiary.

Step 2:  HRSA must approve your Request to Report Late Due to Extenuating Circumstances. Therefore, providers must ensure that their request is detailed as to the extenuating circumstance that prevented them from timely reporting. If a provider’s request is NOT approved, the provider must return the Period 1 funds.

Step 3:  Providers must wait for HRSA to approve the request. If the request is approved, providers will have 10 days from the date of the notification to submit a Period 1 report.

Step 4:  Providers that have already reported may NOT use this process to make edits or adjustments to their Period 1 report.

If you need assistance in completing the Request to Report Late Due to Extenuating Circumstances or finalizing your Period 1 Report, please contact Amanda L. Waesch at alwaesch@bmdllc.com or 330-253-9185 to set up a consultation. 


Latest Batch of Ohio Chemical Dependency Professionals Board Rules: What Providers Should Know

The Ohio Chemical Dependency Professionals Board recently released several new rules and proposed amendments to existing rules over the past few months. A hearing for the new rules was held on February 16, 2024, but the Board has not yet finalized them.

Now in Effect: DOL Final Rule on Classification of Independent Contractors

Effective March 11, 2024, the U.S. Department of Labor (DOL) has adopted a new standard for the classification of employees versus independent contractors — a much anticipated update since the DOL issued its Final Rule on January 9, 2024, as previously discussed by BMD.  In brief, the Fair Labor Standards Act (FLSA) creates significant protections for workers related to minimum wage, overtime pay, and record-keeping requirements. That said, such protection only exists for employees. This can incentivize entities to classify workers as independent contractors; however, misclassification is risky and can be costly.

Florida's Recent Ruling on Arbitration Clauses

Florida’s recent ruling on arbitration clauses provides a crucial distinction in determining whether such clauses are void as against public policy and providers may have the opportunity to include arbitration clauses in their patient consent forms. On March 6, 2024, Florida’s Fourth District Court of Appeals reversed and remanded Florida’s Fifteenth Circuit Court ruling of Piero Palacios v. Sharnice Lawson. The Court of Appeals ruled that the parties’ arbitration agreement did not contradict the Legislature’s intent of Florida’s Medical Malpractice Act (the “MMA”), but rather reflects the parties’ choice to arbitrate claims entirely outside of the MMA’s framework. Therefore, the Court found that the agreement was not void as against public policy.

Corporate Transparency Act Update 3/14/24

On March 1, 2024, a federal district court in the Northern District of Alabama concluded that the Corporate Transparency Act (“CTA”) exceeded Congressional powers and enjoined the Department of the Treasury from enforcing the CTA against the plaintiffs. National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.). On March 11, 2024, the U.S. Department of Justice appealed the district court’s decision to the Eleventh Circuit Court of Appeals.

The Ohio State University Launches Its Accelerated Bachelor of Science in Nursing Program

In response to Ohio’s nursing shortage, The Ohio State University College of Nursing is accepting applications for its new Accelerated Bachelor of Science in Nursing program (aBSN). Created for students with a bachelor’s degree in non-nursing fields, the aBSN allows such students to obtain their nursing degree within 18 months. All aBSN students will participate in high-quality coursework and gain valuable clinical experience. Upon completion of the program, graduates will be eligible to take the State Board, National Council of Licensure Exam for Registered Nursing (NCLEX-RN).