Reminder: HHS to Begin Accepting PRF Phase 4 Applications on Sept. 29th
The U.S. Department of Health and Human Services (HHS) recently announced that the Health Resources and Services Administration (HRSA), the division of HHS that administers the Provider Relief Fund (PRF), will begin accepting applications for the next round of PRF funding on Sept. 29th. The application portal will remain open for four weeks. Providers must submit their completed application by the final deadline of Oct. 26th at 11:59 p.m. ET. The total funding of $25.5 billion is comprised of $17 billion in PRF Phase 4 General Distribution funding and an $8.5 billion targeted rural allocation enacted by the American Rescue Plan (ARP).
While eligibility details for the targeted rural distribution require some clarification, providers who were eligible to apply for Phase 3 General Distribution payments should also be eligible to apply for Phase 4. Providers who previously created an account in the PRF Application and Attestation Portal and have not logged in for more than 90 days will need to first reset their password before starting a new application. On its website here, HRSA indicates that providers who bill Medicare Fee-for-Service (FFS) (Parts A and/or B) or Medicare Advantage, Medicaid (FFS or managed care), or the Children’s Health Insurance Program (CHIP) as well as assisted living facilities are potentially eligible. Please note that PRF Phase 4 payments will be based on providers' lost revenues and pandemic-related expenditures between July 1, 2020 and March 31, 2021. Of the Phase 4 payments, 75 percent will be used to reimburse expenses and lost revenue, while 25 percent will be used for bonus payments that will be based on the amount and type of services provided to Medicaid, CHIP, and Medicare patients/residents.
The HHS press release (available here) as well as the HRSA Future PRF Payments webpage (here) indicate that the Phase 4 distribution calculations will include new elements that will reimburse smaller and mid-sized providers for their lost revenues and COVID-19 expenses at a higher rate compared to larger providers and include bonus payments based on the amount of services providers furnish to Medicaid/CHIP and Medicare patients. Provider size will be determined based on patient care revenue. When it comes to the ARP rural distribution of $8.5 billion, the agency indicates that it will make payments to providers based on the amount and type of Medicare, Medicaid, and CHIP services provided to rural patients (as defined by the HHS Federal Office of Rural Health Policy: rural look-up functionality here, lists here). HHS will make payments to providers based on the amount and type of Medicare, Medicaid, and CHIP services provided to rural patients from Jan. 1, 2019 through Sept. 30, 2020. Providers can look forward to HRSA webinars for technical support and guidance on Thurs., Sept. 30th (register here) and Tues., Oct. 5th (register here). A helpful article by LeadingAge National is here.
HRSA estimates that it will distribute the rural provider payments by late November, likely before Thanksgiving, and the Phase 4 General Distribution payments will be made to providers by mid-December.
Supporting documentation and information needed to complete an application will include:
- Applicant Taxpayer Identification Number (TIN) and TINs for any subsidiaries included in the applicant TIN's Internal Revenue Service (IRS) tax filing.
- Internally generated financial statements that substantiate operating revenues and expenses from patient care in 2019 Q1, Q3, and Q4; 2020 Q3 and Q4; and 2021 Q1.
- Federal income tax return, audited financial statements, or internally generated financial statements submitted in their entirety.
- IRS Form 990 (from tax-exempt organizations).
Along with the funding announcement, HRSA released a methodology document outlining how the funding allocations for the Phase 3 General Distribution were calculated (available here). The agency is developing a structured process to review and potentially reconsider Phase 3 applications and payment determinations, which should be announced shortly. Phase 4 funds will also include a reconsideration process.
We remind members who received more than $10,000 in PRF funding prior to July 1, 2020 that reporting associated with that funding is due through the PRF Reporting Portal by Sept. 30th. However, HRSA has provided a 60-day grace period to the Sept. 30th deadline in response to challenges providers are facing given recent COVID-19 surges and natural disasters around the country. HRSA stresses that:
- While you will be out of compliance if you do not submit your report by Sept. 30, 2021, recoupment or other enforcement actions will not be initiated during the 60-day grace period (Oct. 1st to Nov. 30, 2021).
- The grace period will begin on Oct. 1, 2021 and end on Nov. 30, 2021.
- Providers who are able are strongly encouraged to complete their report in the PRF Reporting Portal by Sept. 30, 2021.
HRSA has consolidated most of the PRF reporting information and numerous resources on their dedicated reporting and auditing webpage here. While the PRF website was redesigned over the summer, the Frequently Asked Questions (FAQ) document (available here) remains one of the key resources and was most recently updated on Aug. 30th.