HHS Opens Application For $20 Billion Of Phase 3 General Distribution Provider Relief Funds

On October 1, 2020 the Department of Health and Human Services (“HHS”) announced that it will distribute a total of $20 billion as part of Phase 3 of the Provider Relief Funds. The application for Phase 3 funding is now open and will be available from October 5 – November 6, 2020. However, HHS has urged providers to apply early, which may be an indication that the funds will be available on a first-come first-serve basis.

Below are some key details regarding Phase 3:

Eligibility

HHS is making a large number of providers eligible for Phase 3 General Distribution funding, including:

  • Providers who previously received, rejected or accepted a General Distribution Provider Relief Fund payment. Providers that have already received payments of approximately 2% of annual revenue from patient care may submit more information to become eligible for an additional payment.
  • Behavioral Health providers, including those that previously received funding and new providers.
  • Healthcare providers that began practicing January 1, 2020 through March 31, 2020. This includes Medicare, Medicaid, CHIP, dentists, assisted living facilities and behavioral health providers.

Payment Methodology – (Apply Early)

All eligible providers will be considered for payment against the below criteria.

  1. All provider submissions will be reviewed to confirm whether they have received a Provider Relief Fund payment equal to approximately 2 percent of patient care revenue from prior general distributions. Applicants that have not yet received Relief Fund payments of 2 percent of patient revenue will receive a payment that, when combined with prior payments (if any), equals 2 percent of patient care revenue.
  2. With the remaining balance of the $20 billion budget, HHS will calculate an equitable add-on payment that considers the following:
    • A provider’s change in operating revenues from patient care
    • A provider’s change in operating expenses from patient care, including expenses incurred related to coronavirus
    • Payments already received through prior Provider Relief Fund distributions.

All payment recipients will be required to attest to receiving the Phase 3 General Distribution payment and accept the associated Terms and Conditions. More information is available on HHS’s website: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html.

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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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