Was there a set period of time in which providers must use ARP Rural payments to cover allowable expenses or lost revenues attributable to COVID-19?

Yes. Providers have at least 12 months, and as much as 18 months, based on the payment received date, to control and use the payments for expenses and lost revenues attributable to coronavirus incurred during the Period of Availability. 

The payment was considered received on the deposit date for automated clearing house (ACH) payments, or the check cashed date for all other payments.

ARP Rural recipients must use payments only for eligible expenses, including services rendered, and lost revenues attributable to COVID-19, incurred by the end of the Period of Availability that corresponds to the Payment Received Period. HRSA began distributing ARP Rural payments on November 23, 2021. Providers were required to maintain supporting documentation that demonstrated that costs were incurred during the Period of Availability, as required under the Terms and Conditions. However, providers were not required to submit that documentation when reporting. Providers must promptly submit copies of such supporting documentation upon the request of the Secretary of HHS. Examples of costs incurred for an entity using accrual accounting, during the Period of Availability include:

• Services that were received
• Renovation or construction that was completed
• Tangible property ordered, but need not have been delivered

For purchases of tangible items made using ARP Rural payments, the purchase did not need to be in the provider’s possession (i.e., back ordered PPE, ambulance, etc.) to be considered an eligible expense but the costs must be incurred by the end of the Period of Availability. Providers must follow their basis of accounting (e.g., cash, accrual, or modified accrual) to determine expenses. For projects that were a bundle of services and purchases of tangible items that cannot be separated, such as capital projects, construction projects, or alteration and renovation projects, the project costs cannot be reimbursed using Provider Relief Fund payments unless the project was fully completed by the end of Period of Availability associated with the Payment Received Period.

Recipients may use payments for eligible expenses or lost revenues incurred prior to receipt of those payments (i.e., pre-award costs) so long as they were to prevent, prepare for, and respond to coronavirus. Additionally, the opportunity to apply Provider Relief Fund payments (excluding the Nursing Home Infection Control Distribution) and ARP Rural payments for lost revenues were available up to June 30, 2023, the end of the quarter in which the COVID-19 Public Health Emergency ended.

HHS reserved the right to audit Provider Relief Fund recipients now or in the future, and may pursue collection activity to recover any ARP Rural payment amounts that have not been supported by documentation or payments not used in a manner consistent with program requirements or applicable law. All payment recipients must have attested to the Terms and Conditions, which required maintaining documentation to substantiate that these funds were used for health care-related expenses or lost revenues attributable to COVID-19.

(Added 5/5/2023)