The phase1 application period had closed (on June 3rd), but there is now a phase2 application period, open until August 28th. HHS will again allow practices to apply for grants equal to 2% of total 2019 medical revenues under the PRF (Provider Relief Fund) program.

Critical points:

• This new deadline applies to practices taking Medicare, Medicaid and CHIP, and also Dental providers. Medicare providers are only eligible if they did not apply before the original deadline or did not receive 2% of 2019 medical revenues.

• Grants are equal to 2% of 2019 total medical revenues, not just revenues associated with the listed programs. The grants are tied to the TIN.

• These are grants – they do not need to be repaid.

• Application Deadline is August 28th. Here is a link to the online application.

• The application form is available as a pdf by clicking here, BUT the pdf should be used as a checklist as applicants gather their information. The actual application must be filled out online. Field by field instructions for filling out the application and attestation may be downloaded by clicking here.

• There is a small set of conditions restricting the use of these funds. These are likely to have no effect on most practices. Practices receiving funds should attest online that they meet these conditions in order to keep the funds. If attestation is not done within 90 days of receipt of funds, it is assumed you meet the conditions.

• A report will be required on use of the funds. For funds expended in 2020, the deadline for report submission is February 12th, 2021. The report portal opens October 1, 2020.

• Recipients may be audited. Providers of inaccurate information may need to return the funds to HHS and may be subject to unspecified other legal action.

• Recipients must maintain appropriate records and cost documentation “including, as applicable, documentation described in 45 CFR § 75.302”

More about the Provider Relief Fund:

The PRF was established in the Cares act, which included $100 Billion for a Relief Fund for practices and hospitals. Medical practices were to receive $50 Billion, with Hospitals, providers in rural areas, and other targets to receive the other $50 Billion. Back in the 2nd week of April, an amount approximately equal to 6% of that 2019 Medicare billing was pushed out by HHS to any medical practices that billed Medicare in 2019. Healthcare Providers could accept or return the money, but to accept they were supposed to attest online that they met the requirements of the program. These requirements were few and unlikely to be a problem for most practices. They subsequently changed the rules such that if a practice did not fill out the attestation, it would be treated as if they met the requirements and were keeping the money.

While the initial distribution of funds was to Medicare participants, the PRF was available to all medical practices. The fund can distribute up to 2% of total revenues for 2019 delivered medical services to applicants. If a practice received less in the initial distribution than an amount equal to 2% of their 2019 total medical revenues, they can apply for the difference. The original distribution will be included in the 2%, with total grants available from this program not to exceed 2%. (There was no mention in the HHS documentation of what happens if the initial distribution exceeded the maximum amount, as could happen if a practice had more than 1/3rd of its 2019 revenues from Medicare.)

The PPP and Healthcare Enhancement Act added another $75 Billion to the fund at the end of April. In May, HHS opened a portal to allow for application for these funds. The original date for application was June 3rd. In July, HHS extended the program specifically to Medicaid, CHIP and Dental providers. Shortly thereafter, they also opened it back up to Medicare providers who had not previously applied. It also reduced reporting requirements for fund recipients.

Additional detail on this program can be found on the HHS website, at: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html