Home Health & Hospice Week

Feds set to release another $20 billion to beleaguered providers.

Home health and hospice agencies may be eligible for a new infusion of relief funds — but only if they qualify under significantly changed reporting requirements.

On Oct. 1, the Department of Health and Human Ser-vices announced “$20 billion in new funding for providers on the frontlines of the coronavirus pandemic” under a “Phase 3 General Distribution allocation” of the Provider Relief Fund.

The round will consider “providers that have already received Provider Relief Fund payments” and “previously ineligible providers,” such as those that began operating in 2020, HHS said in a release.

Providers that already have received PRF funding, but not up to the “2 percent of annual revenue from patient care” mark, can apply to make up the difference. And agencies that previously gave back PRF funding can now apply for more.

Plus: Providers that already received 2 percent can apply to receive an unspecified PRF “add-on payment to account for revenue losses and expenses attributable to COVID-19,” HHS explains.

How it will work: The HHS Health Resources and Services Administration will collect applications for Round 3 funds until Nov. 6. Then HRSA will “calculate an equitable add-on payment,” taking into account 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; and PRF payments already received, HHS details.

“We’ve worked with all of the resources we have across HHS to ensure that America’s heroic healthcare providers know they can apply for support,” HHS Secretary Alex Azar says in the release. HHS says it has already issued more than $100 billion in prior PRF distributions. “Still, HHS recognizes that many providers continue to struggle financially from COVID-19’s impact,” the agency says.

“We are very pleased that HHS has established a new distribution to support those health care providers that have been especially impacted by COVID-19,” NAHC President William Dombi says in a member newsletter article.

Left out: But the new funding round doesn’t go quite far enough. “It would also be essential that HHS open a distribution to the crucial home care providers that do not provide Medicare or Medicaid services,” Dombi continues. “Those home care providers serve highly vulnerable populations of the elderly and persons with disabilities. We have made repeated requests to include those home care providers in the distributions.”

PRF Reporting Change Puts Funds At Risk

Plus, this new funding round ignores a major factor impacting the relief provided. Recently issued PRF reporting guidelines “include new guidance for calculating lost revenues attributable to … COVID-19 that appears to differ from HHS’ previously published [Frequently Asked Questions] that many providers used in applying for earlier Provider Relief Fund distributions,” point out attorneys with law firm McGuireWoods in online analysis.

While HHS previously said providers would use “any reasonable method” to calculate lost revenues — including comparing budgeted revenues to actual revenues under COVID-19 — now it defines lost revenues as “negative change in year-over-year net operating income from patient related sources,” the McGuireWoods attorneys highlight. That negatively impacts agencies that expected growth from 2019 to 2020 (see Eli’s HCW, Vol. XXIX, No. 36).

The PRF reporting guidance “continues to create confusion,” say attorneys Alexis Finkelberg Bortniker, Monica Chmielewski, Thuong (Amy) Nguyen, and Anil Shankar with law firm Foley & Lardner in online analysis. “As calendar year 2020 moves into the fourth quarter, many providers continue to weigh whether or not they are able to retain PRF payments received.”