The Health Resources & Service Administration (“HRSA”) has begun issuing Final Repayment Notices to providers who received Provider Relief Funds (“PRF”) under the following circumstances:

• Providers who rejected the Terms and Conditions in the PRF Application and Attestation Portal, but never returned funds.
• Providers who failed to submit a required report during a specific reporting period or the subsequent request to report late due to extenuating circumstances.
• Providers deemed required to repay funds as a result of audit findings.
• Providers deemed ineligible or noncompliant by indictment or other information not revealed through audit. 

Upon receipt of a Final Repayment Notice, a provider has 60 days to take one of two options: (1) return the PRF payments, with interest if held in an interest-bearing account, or (2) submit a request for a Decision Review to dispute HRSA’s request for repayment. Should HRSA issue a favorable decision, providers should be prepared to meet the reporting requirements. Providers that fail to repay funds upon request from HRSA may be subject to initiation of debt collection, so it is imperative that providers take steps to respond in a timely manner to any request for repayment from HRSA.

Based upon Nelson Mullins’ experience, the first round of Final Repayment Notices included physician groups that received PRF monies in April 2020 and failed to submit a required report; these groups received a Final Repayment Notice dated as early as December 7, 2022, with a February 7, 2023 response deadline.

If your organization received a Final Repayment Notice from HRSA and needs guidance on navigating the repayment and/or Decision Review process, Nelson Mullins’ experienced team is ready to help. Please reach out to the authors or another members of the Nelson Mullins healthcare group.