On September 10th, the Department of Health and Human Services (HHS) released new guidance regarding the Provider Relief Funds (PRF). Included in this guidance is a 60-day grace period for Period 1 reporting, $17 billion in funding for Phase 4 distributions, and options for reconsiderations of Phase 3 distributions. Here is what we know now:
Grace Period for Reporting
Providers who received PRF payments are subject to reporting requirements, as outlined in the terms and conditions of the program. The original deadline for Period 1 reporting is September 30, 2021. Period 1 covers providers who received over $10k in PRF funding between April 10-June 30, 2020. Due to the Delta variant and recent natural disasters, HHS announced a 60-day grace period for those who miss the original September 30 deadline. No recoupment of funds or other enforcement actions will be initiated during this grace period.
Phase 4 Distributions
As part of the September 10th announcement, HHS indicated it will be releasing $17 billion of awards for Phase 4 of the PRF. Payments for Phase 4 will be based on the provider’s lost revenues and increased expenditures, associated with the pandemic, between July 1, 2020, and March 31, 2021. This phase will be open to virtually all providers, even those who received previous rounds of funding.
Phase 4 distributions will be based on new methodology, which will be more generous to smaller providers, and which also includes bonus payments for providers who serve Medicaid, CHIP and Medicare patients. As part of the new methodology, two allocations will be used for issuing the $17 billion of Phase 4 awards:
- 75% ($12.75B) will be issued based on revenue losses and COVID-related expenses
- 25% ($4.25B) will be issued towards bonus payments, based on the services provided to Medicaid, CHIP and Medicare patients.
The application process for Phase 4 distributions will begin on September 29th.
Phase 3 Reconsiderations
As a means of promoting transparency, HHS released detailed information on the methodology used to calculate Phase 3 distribution payments. Any providers who believe their Phase 3 payment was calculated incorrectly will now have the opportunity to submit a request for reconsideration. Details regarding the process of requesting a reconsideration have yet to be announced.
If you have any questions on this new guidance or any other PRF-related matters, please feel free to contact us.
