New HHS Guidance and Funding

Between last year and the beginning of this year, the US Department of Health & Human Services (HHS) issued three rounds of Provider Relief Funds (PRF) to assist healthcare providers that were negatively impacted by the COVID Pandemic. These funds were to cover both COVID related expenses, as well as decreases in overall revenue. Last week, HHS issued new guidance surrounding these relief funds, including the release of a fourth round of funding.

Grace Period:

HHS had announced earlier this year, the following due dates for reporting of PRF funding:

While the new guidance has not provided any extensions from these dates, and HHS has said providers not meeting these dates will be out of compliance, HHS has announced that providers falling into period 1 will be given a 60 day grace period during which there will be no recoupment or other enforcement action taken. Any unused funds must be returned within 30 days of the end of the grace period.

Phase 4 Funding:

HHS has announced an additional $17 million of phase 4 PRF money for providers that provide COVID related healthcare services (broadly defined). The amount of the funding will be determined based upon lost revenues and COVID related expenditures that occurred between July 1, 2020 and March 31, 2021 (as compared to the same period of the prior year). Smaller providers will be funded under this Phase at a higher rate than larger providers will. The application portal will open on September 29, 2021 for Phase 4 filing.

Phase 3 Reconsideration:

HHS has released their methodology on how they calculated Phase 3 payments for providers. Providers are encouraged to review these calculations, especially if you expected greater funding then you received. If HHS has made a mistake, you could request that they reconsider your funding.

If you have any questions, or you need assistance in completing any of the filings, please do not hesitate to contact us.