Home Health & Hospice Week

Waste no time in applying once portal opens on Sept. 29, expert urges.

As COVID-19 continues to pummel the nation and its healthcare providers, the Department of Health and Human Services is making more relief money available.

HHS, “through the Health Resources and Services Administration (HRSA), is making $25.5 billion in new funding available for health care providers affected by the COVID-19 pandemic,” the Department says in a release. “This funding includes $8.5 billion in American Rescue Plan (ARP) resources for providers who serve rural Medicaid, Children’s Health Insurance Program (CHIP), or Medicare patients, and an additional $17 billion for Provider Relief Fund (PRF) Phase 4 for a broad range of providers who can document revenue loss and expenses associated with the pandemic.”

Reminder: Over time, Congress has allocated $175 billion in PRF funds. About $39 billion of that remains “unobligated,” a HRSA official said in a Sept. 15 webcast, reports finance expert Dave Macke with Von Lehman & Co. in Fort Mitchell, Kentucky. Presumably the announced $25.5 billion is coming out of that pool, Macke tells AAPC.

“This funding critically helps health care providers who have endured demanding workloads and significant financial strains amidst the pandemic,” HHS Secretary Xavier Becerra says of the newest round. “The funding will be distributed with an eye towards equity, to ensure providers who serve our most vulnerable communities will receive the support they need.”

Providers will be able to use one application to apply for both types of funding, HHS instructs. The application portal will open on Sept. 29.

HHS also has announced a grace period for PRF reporting (see story, p. 271) and a reconsideration process for Phase 3 distribution amounts.

ARP Details

HRSA will make ARP rural payments to providers “based on the amount of Medicaid, CHIP and/or Medicare services they provide to patients who live in rural areas,” HHS notes. “As rural providers serve a disproportionate number of Medicaid and CHIP patients who often have disproportionately greater and more complex medical needs, many rural communities have been hit particularly hard by the pandemic,” the Department acknowledges.

How it will work: “HHS will price Medicaid and CHIP claims data at Medicare rates, with some limited exceptions,” HRSA explains on its PRF Future Payments webpage. “Providers who serve any patients living in Federal Office of Rural Health Policy-defined rural areas with Medicaid, CHIP, or Medicare coverage, and who otherwise meet the eligibility criteria, will receive a minimum payment.”

Tip #1: “ARP rural providers can utilize the HRSA Rural Health Grants Eligibility Analyzer to help determine their qualification as a rural provider,” offer attorneys Dominic Costello and Eric Weatherford with law firm Husch Blackwell in online analysis. That tool is at https://data.hrsa.gov/tools/rural-health.

Tip #2: Remember, the ARP funds will be based on the patients you serve, not where your agency is located, Macke stresses. You may need to look up individual patient addresses to see whether they are categorized as rural to know if you’ll qualify for these ARP funds. Home health and hospice agencies in rural areas may find they serve patients who are not, and vice versa, Macke notes.

PRF Phase 4 Details

In addition to the ARP money is the “long-awaited Phase 4 general distribution funding,” note Margaret Lally and Robert Nasso with The Bonadio Group CPAs and consultants.

Consistent with the CARES Act of 2020, HHS will base PRF Phase 4 payments on providers’ lost revenues and expenditures between July 1, 2020, and March 31, 2021, HHS specifies in the release.

HHS will calculate 75 percent of the Phase 4 allocation “based on revenue losses and COVID-related expenses,” HRSA explains. And it will put 25 percent “towards bonus payments that are based on the amount and type of services provided to Medicaid, CHIP, and Medicare patients,” the agency says.

Key: “All providers who received PRF distributions in any of the other phases may be eligible to receive additional funding under the latest Phase 4 distributions,” Costello and Weatherford point out.

How it will work: “Large providers will receive a mini-mum payment amount that is based on a percentage of their lost revenues and COVID-related expenses,” HRSA details. “Medium and small providers will receive a base payment plus a supplement, with small providers receiving the highest supplement, as smaller providers tend to operate on thin margins and often serve vulnerable or isolated communities.”

HHS “is trying to help out the smaller providers,” Macke highlights.

Providers won’t know exactly what their relief payments will be until all applications are in and HHS has done its final calculations. HHS must “ensure we stay within our budget and funds are distributed equitably,” it says.

“There’s a finite pool of money,” Macke notes. How much each provider receives will depend on who applies and what they are entitled to. “It’s all pro rata,” he says.

It’s also unclear how HHS will determine the size categories, note strategy adviser Sheila Burke and attorney Jeffrey Davis with law firm Baker Donelson. “HRSA has not defined what will constitute a small, medium, or large provider,” they highlight.

Providers will need to stay tuned for the final details. The “Provider Relief Fund (PRF) program continues to evolve,” notes CPA and consulting firm Eide Bailly in online analysis.

The Rehabilitation Providers and Community Providers Association in Pennsylvania offers these three steps to prepare for both the ARP and PRF Phase 4 application:

1. Review eligibility information posted on the PRF Future Payments web page at www.hrsa.gov/provider-relief/future-payments — additional detail will be added prior to Sept. 29.
2. Search the Rural Health Grants Eligibility Analyzer to see what areas qualify as “rural” for the ARP rural payments.
3. Gather supporting documentation, such as most recent tax documents and financial statements, for the second half of calendar year 2020 and the first quarter of CY 2021.