On October 22nd, the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), announced the latest Provider Relief Fund (PRF) application period has been expanded to include provider applicants such as residential treatment facilities, chiropractors, and eye and vision providers that have not yet received Provider Relief Fund distributions. On October 1, 2020, HHS announced it would be making up to $20 billion in new Phase 3 General Distribution funding available for providers on the frontlines of the coronavirus pandemic. HHS is also focused on ensuring the safe continuity of all types of health care delivery despite this pandemic. As such, the Administration is committed to providing relief resources in an equitable manner to assist the diverse health care provider community regardless of whether they accept Medicare or Medicaid payments. HHS is also announcing it will be updating its most recent PRF reporting instructions to broaden use of provider relief funds.
“We have worked closely with stakeholders across the healthcare system to ensure that the Provider Relief Fund reaches all American healthcare providers that have been impacted by the pandemic,” said HHS Secretary Alex Azar. “Today, we are expanding the pool of eligible providers to include a broader array of practices, such as residential treatment facilities, chiropractors, and vision care providers that may not have already received payments.”
Under the Phase 3 General Distribution, which began accepting applicants on October 5, 2020, HHS invited providers that had already received PRF payments to apply for additional funding that considers changes in patient care operating revenue and expenses caused by the coronavirus. HHS also expanded the list of eligible applicants to providers who had not previously received PRF payments, including behavioral health providers known to the Substance Abuse and Mental Health Services Administration (SAMHSA) and certain providers who began practicing in 2020. Still, pandemic related needs across the entirety of the provider community remains high. HHS has designed the PRF program to be agile and responsive to the unique and dynamic challenges this virus presents to the health care ecosystem. Important to this approach is maintaining an open line of communication with providers and provider organizations, members of Congress, and state and local officials. The PRF also released an animated video focused on eligibility and the ease of the application process for its current Phase 3 General Distribution. As HHS receives input and feedback on needs caused by the coronavirus pandemic, it has tried to respond.
Newly Eligible Phase 3 General Distribution Providers
HHS is expanding the pool of eligible Phase 3 applicants to include providers across a broad category of practices. Many providers who accept Medicare and Medicaid within these categories have already received a PRF payment, but others have not and HHS is working to ensure even more providers are able to receive Phase 3 funding. The list below includes eligible practices where providers may now apply for Phase 3 funding regardless of whether they accept Medicaid or Medicare.
• Behavioral Health Providers
• Allopathic & Osteopathic Physicians
• Dental Providers
• Assisted Living Facilities
• Nursing Service and Related Providers
• Hospice Providers
• Respiratory, Developmental, Rehabilitative and Restorative Service Providers
• Emergency Medical Service Providers
• Hospital Units
• Residential Treatment Facilities
• Ambulatory Health Care Facilities
• Eye and Vision Services Providers
• Physician Assistants & Advanced Practice Nursing Providers
• Nursing & Custodial Care Facilities
• Podiatric Medicine & Surgery Service Providers
(For a detailed description of all eligible Phase 3 General Distribution provider types, visit the PRF website.)
These providers and all Phase 3 applicants will have until 11:59PM EST on November 6, 2020 to submit their applications for payment consideration. Once validated, these providers will receive a baseline payment of approximately 2% of annual revenue from patient care plus an add-on payment that considers changes in operating revenues and expenses from patient care, including expenses incurred related to coronavirus. All payment recipients will be required to attest to receiving the Phase 3 General Distribution payment and accept the associated Terms and Conditions.
Reporting Requirements Update
HHS is committed to distributing PRF funds in a way that is fast, fair, simple and transparent. In September, HHS published final reporting guidance to set expectations for PRF payment recipients. In providing this guidance, HHS also updated its Frequently Asked Questions (FAQs) to clarify that for purposes of relief payments for lost revenues attributable to COVID-19, recipients must submit information showing a negative change in year-over-year net patient care operating income. This definition sought to balance fairness and establish guardrails to restrict some providers from receiving distributions that would make them more profitable than they were before the pandemic.
As providers, provider organizations, and members of Congress familiarized themselves with the reporting requirements, HHS received feedback from many voicing concerns regarding this approach to permissible uses of PRF money. In response to concerns raised, HHS is amending the reporting instructions to increase flexibility around how providers can apply PRF money toward lost revenues attributable to coronavirus. After reimbursing healthcare related expenses attributable to coronavirus that were unreimbursed by other sources, providers may use remaining PRF funds to cover any lost revenue, measured as a negative change in year-over-year actual revenue from patient care related sources.
A policy memorandum on the reporting requirement decision can be found here – PDF*.
The amended reporting requirements guidance can be found here – PDF.*
For updates and to learn more about the Provider Relief Program, visit: hhs.gov/providerrelief.