October 21, 2020
On October 1, the Department of Health and Human Services (HHS) provided guidance for health care providers who have already received relief funds and announced a new round of $20 billion in funds currently available. Under this Phase 3 General Distribution allocation, providers that have already received Provider Relief Fund payments will be invited to apply for additional funding that considers financial losses and changes in operating expenses caused by the coronavirus.
So, who can still receive funds, and what is the process? We’ve put together some answers to commonly asked questions, a summary of the key dates, and reporting information to help you make sure you are in compliance and you have received the maximum amount of funds available to you during these uncertain times.
What Is The Phase 3 Fund Application Period?
Providers can begin applying for funds on Monday, October 5, 2020, through November 6, 2020. The new funding period helps ensure that America’s essential health providers are being reached and takes into account losses and expenses relating to coronavirus.
Who Qualifies For This Funding?
- Behavioral health providers
- Dental providers
- Home and community-based services
- Primary care or specialty practice providers
- Any provider who previously received funds (up to a total of 2% of patient care revenue)
What Information Must Be Provided?
- A provider’s change in operating revenues from patient care
- A provider’s change in operating expenses from patient care
- Payments already received through prior Provider Relief Fund distributions
Additionally, if you receive funds, you must attest to receipt within 90 days of payment at the HHS website. Providers must attest to meeting the terms and conditions of payment; if they do not actively attest within 90 days, they are assumed to have accepted the payment and terms and conditions.
More information on submission requirements can be found on the HHS site.
What Should I Know About Reporting For Funds Received (In Any Phase Of Funding)?
All recipients of Provider Relief Fund (PRF) payments are required to comply with the reporting requirements. It is important to note that recipients of greater than $10,000 will be required to submit reports about the use of their PRF distributions.
Below are some important reporting dates to keep in mind:
- January 15, 2021: Portal for the 2020 calendar year reporting opens
- February 15, 2021: Reporting for the 2020 calendar year due
- July 31, 2021: Reporting for funds spent after 2020 due
What Can The Funds Be Used For?
- Expenses attributable to coronavirus that are not reimbursed or obligated to be reimbursed from other sources
- Lost revenues, as represented by a change in net patient care operating income from 2019 to 2020
How Are Expenses Reported?
- Expenses need to be reported within two main categories: Health Care Related and General and Administrative. Health Care Related is anything directly related to COVID, for example, PPE, testing, and equipment for social distancing and sanitization. General and Administrative examples are rent, utilities, personnel, and other administrative expenses.
- Expenses that were covered by PPP funds or other sources do not qualify.
- If $500,000 or more was received, the provider must include expense detail by more specific subcategories.
Should I Report Lost Revenue?
You must report patient care revenue (net of write-offs) by quarter for the calendar year 2020 and comparative amounts by quarter for 2019.
Non-financial info is needed (by quarter):
- Personnel (detailed info on the number of employees and rehires)
- Patients (detailed info on the number of patients seen)
- Facilities (detailed info on the number of beds in use for hospitals)
Can I Be Subject To Any Additional Audit Requirements?
Single audit requirements apply if more than $750,000 of funds were received and expended from this program or any other federal funds, other than PPP loan funds, within the calendar year or your fiscal year (if different).
What Happens If I Do Not Expend All The Funds?
If after 2021 the funds were not spent and/or not enough revenue was lost to make up the total paid, the HHS can demand it be paid back. At this time there is no specific guidance on how this will occur.
In addition, if you are conducting COVID-19 tests for uninsured individuals, you can be reimbursed. As part of the Families First Coronavirus Response Act, the Paycheck Protection Program and Health Care Enhancement Act, and (CARES) Act, the HHS will provide claims reimbursement to health care providers, generally at Medicare rates.
Our goal is to ensure you are getting the very most out of the programs available to you. You can always count on us to be your trusted advisors and keep you updated as more information regarding the HHS Provider Funds is released. If you have any questions, please do not hesitate to call your accountant or email our medical niche lead, Stephanie Banuelos, at firstname.lastname@example.org.