Assisted Living Facilities Eligible for Provider Relief Fund Phase 2 General Distribution

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On September 1, 2020, HHS announced that assisted living facilities (ALFs) that do not bill Medicare or Medicaid may now apply for funding under the Provider Relief Fund Phase 2 General Distribution allocation. HHS has developed a curated list of the tax identification numbers (TINs) of these private-pay ALFs. Like other providers applying for Phase 2 funding, eligible ALFs will receive 2 percent of their annual revenue from patient care.

Additionally, on September 1, 2020, HHS released new Frequently Asked Questions to assist ALFs in preparing their application. Importantly, HHS explains that it developed its curated list from state licensing boards/organizations, the American Health Care Association, National Center for Assisted Living, Argentum, Brookdale, Leading Age, and other assisted living groups. If a TIN is not on the curated list of ALFs, HHS will conduct additional analysis related to the TIN and any currently operating ALFs associated with the TIN. This validation process might involve the State or other third-party sources to determine if the provider is a known provider that was not captured initially.

The application deadline is September 13, 2020. For providers awaiting additional analysis and TIN validation, if the TIN is subsequently marked as valid, the provider will be notified to submit data into DocuSign, even if validation occurs after the September 13 deadline.

The complete FAQ document is available on the HHS website here, and the HHS announcement is available here.

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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