A made-up character asks a common question:
Is PRF money only for additional employees and contractors I hired after the pandemic, or can I use it to reimburse compensation for longtime workers? – Confused by the Rules
Dear Confused –
I am not aware of any guidance limiting PRF reimbursement to those expenses first incurred after COVID-19 became a thing. I think you can use PRF money to cover compensation, paid during the period of availability, for employees already with the company … assuming they are contributing to the company’s efforts to prevent, prepare for … you know the drill.
You may suspect that compensation for existing workers is not eligible because you faintly recall the PPP requirement limiting eligible expenses to contracts established before a specified date. That is a different program with no applicability to PRF.
You may also be confused by the examples in the Post-Payment Notice and FAQs. PPE, emergency facilities, and the like are all associated with prevention and preparation, both of which require some advance knowledge of the virus. Clearly, recipients did not hire longtime employees before the
public health emergency.
The verb respond, however, is different from prevention and preparation. While the latter are actions that anticipate something, a response is an after-the-fact reaction to someone or something. Thus, redeploying existing assets in response to the emerging pandemic seems to me a completely reasonable response to coronavirus.
To qualify as a response, I do think it is important to connect the actions of the employees to coronavirus. Lawmakers and authorities have been consistent that attributable to coronavirus means:
Is PRF money only for additional employees and contractors I hired after the pandemic, or can I use it to reimburse compensation for longtime workers? – Confused by the Rules
Dear Confused –
I am not aware of any guidance limiting PRF reimbursement to those expenses first incurred after COVID-19 became a thing. I think you can use PRF money to cover compensation, paid during the period of availability, for employees already with the company … assuming they are contributing to the company’s efforts to prevent, prepare for … you know the drill.
You may suspect that compensation for existing workers is not eligible because you faintly recall the PPP requirement limiting eligible expenses to contracts established before a specified date. That is a different program with no applicability to PRF.
You may also be confused by the examples in the Post-Payment Notice and FAQs. PPE, emergency facilities, and the like are all associated with prevention and preparation, both of which require some advance knowledge of the virus. Clearly, recipients did not hire longtime employees before the
public health emergency.
The verb respond, however, is different from prevention and preparation. While the latter are actions that anticipate something, a response is an after-the-fact reaction to someone or something. Thus, redeploying existing assets in response to the emerging pandemic seems to me a completely reasonable response to coronavirus.
To qualify as a response, I do think it is important to connect the actions of the employees to coronavirus. Lawmakers and authorities have been consistent that attributable to coronavirus means:
- PRF recipients must provide care for patients with possible or actual cases of COVID-19, and
- Every patient is a possible case of COVID-19.
Are customer service representatives, respiratory therapists, delivery drivers necessary to take care of patients? Absolutely, regardless of individual hire dates.
Landscape architects? Maybe not so much.
If you have any questions, give us a shout.
Talk soon.
Derrick
SOURCE LINKS
https://www.hrsa.gov/sites/default/files/hrsa/provider-relief/terms-and-conditions-provider-relief-30-b.pdf
https://www.hrsa.gov/sites/default/files/hrsa/provider-relief/provider-post-payment-notice-of-reporting-requirements-june-2021.pdf
https://www.hrsa.gov/provider-relief/faq/reporting
https://www.hrsa.gov/sites/default/files/hrsa/provider-relief/allowable-expenses-one-pager.pdf
Landscape architects? Maybe not so much.
If you have any questions, give us a shout.
Talk soon.
Derrick
SOURCE LINKS
https://www.hrsa.gov/sites/default/files/hrsa/provider-relief/terms-and-conditions-provider-relief-30-b.pdf
https://www.hrsa.gov/sites/default/files/hrsa/provider-relief/provider-post-payment-notice-of-reporting-requirements-june-2021.pdf
https://www.hrsa.gov/provider-relief/faq/reporting
https://www.hrsa.gov/sites/default/files/hrsa/provider-relief/allowable-expenses-one-pager.pdf
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