New Health Care & Senior Living Relief Funding under the PRF program

Department Of Health And Human Services Announces Phase 4 of Funding Under the Provider Relief Fund Program and Extended Reporting Period Under Prior Phases

On September 10, 2021, the United States Department of Health and Human Services (“HHS”) announced “Phase 4” of funding under the Provider Relief Fund (“PRF”) program. In Phase 4 of the PRF program, HHS will make available $17 billion dollars of relief payments to eligible health care providers. Eligible providers include academic medical centers, acute care hospitals, primary care physician practices, assisted living facilities, dental providers, home health agencies, nursing homes and skilled nursing facilities, and outpatient clinics such as urgent care centers and dialysis centers, among others. Eligible providers may use Phase 4 payments to recoup lost revenues and changes in operating expenses incurred from July 1, 2020 to March 31, 2021 as a result of the COVID-19 pandemic.

Unlike prior phases of payments under the PRF program, HHS plans to prioritize available payments to small and medium-sized eligible providers compared to larger providers in an effort to ensure equitable distribution of PRF funds. As a result, small and medium-sized eligible providers will receive a supplemental payment not otherwise available to large eligible providers. Further, HHS announced that “bonus” Phase 4 payments will be available to eligible providers based on the amount of services that an Eligible Provider renders to Medicaid, CHIP, and Medicare patients. HHS will determine the amount of payments to be made to each eligible provider following a review of all Phase 4 payment applications received by HHS.

Eligible providers may apply to HHS for Phase 4 payments beginning on September 29, 2021. It is unclear whether HHS will review applications on first-come, first-serve basis, and we therefore encourage eligible providers to apply as early as possible.

In addition to announcing payments under Phase 4 of the PRF program, HHS also announced that all providers who received PRF payments from April 10, 2020 through June 30, 2020 in excess of $10,000 have an additional sixty (60) days to comply with HHS’s PRF program reporting requirements if these providers are unable to meet the September 30, 2021 deadline for reporting. During this extended reporting time period, HHS will not initiate enforcement actions against providers who did not comply with the original reporting deadline.

To learn more about Phase 4 of the PRF program or the extended reporting grace period, please contact a member of Hinckley Allen’s Health Care or Senior Living industry groups.