A New Phase of Provider Relief Funds May Be on the Horizon

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The Department of Health & Human Services (HHS) is expected to announce a new phase of Provider Relief Funding (PRF) that would likely cover COVID-related expenses and losses during the third and fourth quarters of 2020 (and potentially first quarter of 2021).  Timing of the announcement is unclear, but it would be met with enthusiasm as the last official PRF disbursement was on December 15, 2020 (the PRF distribution timeline may be accessed here).  Ahead of any new funding opportunity, providers should be aware of the following:

  • Review your calculated COVID-related losses and expenses to determine if they are expected to exceed the amount of PRFs already received, if any. As with previous disbursements, providers will need to be able to demonstrate the need and use of the funds during future reporting periods.
  • Familiarize yourself with eligibility requirements for past phases of funding (accessible here) to determine the likelihood that you will be eligible for any new funding. Eligibility requirements for any future funding will likely be similar to past requirements.
  • For providers that have undergone or will be undergoing a change of ownership, consider how future PRF distributions will be handled and ensure they are compliant with HHS requirements. In general, parties to an asset purchase may not transfer PRFs, while parties to a stock or membership purchase may transfer funds.  For more information, a previous article on PRFs and CHOWs may be accessed here.
  • For providers that have not previously applied for funding or those expecting to need to apply again for additional phases, familiarize yourself with the Phase 3 application instructions, sample application, and terms and conditions, as additional phases will likely include similar information and documentation requirements.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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