HHS Provider Relief Fund – Latest Updates

This article was written and produced by Margaret Lally, Healthcare Consulting Manager at The Bonadio Group. Looking to get in touch with Margaret? Reach out today: mlally@bonadio.com.

New Round of Funding for Skilled Nursing Facilities

On August 7, HHS announced a new $5 billion round of funding for Skilled Nursing Facilities. The first distribution of approximately $2.5 billion will be automatically remitted mid-August, requires no application process, and can be used for testing, staffing, PPE, and to establish COVID isolation facilities. Although the methodology has not been formally announced, the average 104-bed facility can expect approximately $90,000 if they have received an antigen testing device (part of a separate HHS initiative) and approximately $170,000 if they have not. The remaining funds will be distributed in the fall with performance-based requirements that have yet to be determined but will consider the prevalence of COVID in the provider’s area and the provider’s ability to control the spread within their facility.

Reporting Requirements

HHS announced on July 20th that providers who received $10,000 or more in Provider Relief Funds would be subject to reporting requirements. Although these requirements were scheduled to be announced in detail on August 17th, subsequent updates to the HHS site indicate that they are not yet complete but will be forthcoming. The online reporting system has a target opening date of October 1, 2020. The deadlines for reporting are as follows:

• All recipients must report on expenditures through December 31, 2020, by February 15, 2021.
• Recipients that have fully expended all funds by December 31, 2020, can submit one final report between October 1, 2020, and February 15, 2021.
• Recipients who have not fully expended all funds in 2020 must submit a second and final report by July 31, 2021.

It is anticipated that HHS will provide webinars, online instructions, and updated FAQs to assist providers in complying with the reporting requirements.

Phase 2 Application Deadline and Updated Eligibility

The Phase 2 General Distribution Fund, previously referred to as the Medicaid/CHIP Distribution, has recently been updated to include several provider types that had previously been excluded from this round of funding. In addition to providers who billed Medicaid, CHIP, or Medicaid Managed Care between January 1, 2018, and December 31, 2019, the following are now also eligible to apply provided they meet all of the requirements on the HHS Provider Relief Fund webpage and associated FAQ document:

• Medicare Providers who received a Phase 1 General Distribution but missed the June 3 deadline to submit revenue and get the balance of 2% of revenue.
• Medicare Providers who did not receive payments totaling 2% of annual patient revenue in Phase 1 (includes providers that were limited to lost revenue for March and April 2020).
• Providers who rejected Phase 1 General Distribution funds and would now like to re-apply.
• Medicare Part A providers who underwent a change in ownership in 2019 or 2020 that precluded eligibility for Phase 1 of the General Distribution.

The due date to apply for funding is August 28, 2020, and providers should note that the name of the portal has also changed and is now the “Provider Relief Fund Application and Attestation Portal”. In response to feedback from providers, the application has been significantly simplified and entails 3 basic steps:

1. Enter TIN to be validated by HRSA - HHS will send an email confirming the validation of TIN or communicating ineligibility.
2. Complete Application by entering Revenue and Tax Information.
3. Once Payment is Received, Attest to payment and terms.

If providers have submitted their TIN for validation by the August 28 deadline, they will be able to apply once validation confirmation is received, even if that occurs after August 28th.

As always if you have questions please reach out to your trusted advisors at The Bonadio Group for Assistance.

The information and advice we are providing for this matter relates to COVID-19 legislative relief measures. Because legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that could modify some of the advice and information provided to you, after the conclusion of our engagement. We, therefore, make no warranties, expressed or implied, on the services provided hereunder.