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Focus on Healthcare: Phase 3 General Distribution from the Provider Relief Fund – November 6 Deadline

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The application deadline for Phase 3 Provider Relief is November 6, 2020.
November 2, 2020

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The application deadline for Phase 3 Provider Relief is November 6, 2020. Eligible providers include:
  • Providers who previously received, rejected or accepted a General Distribution PRF payment. Providers who have already received payments of approximately 2% of annual revenue from patient care may submit more information to become eligible for an additional payment.
  • Behavioral Health providers, including those that previously received funding and new providers.
  • Healthcare providers that began practicing January 1, 2020 through March 31, 2020. This includes Medicare, Medicaid, CHIP, dentists, assisted living facilities and behavioral health providers.1

For a further list of eligible applicants, please see the following links:

https://www.hhs.gov/sites/default/files/provider-relief-fund-6-steps-to-apply.pdf and https://www.hhs.gov/sites/default/files/provider-distribution-instructions.pdf.

All eligible providers’ submissions will be reviewed to confirm they have received a PRF payment equal to approximately 2% of patient care revenue from prior general distributions. Applicants that have not yet received PRF payments of 2% of patient revenue will receive a payment that, when combined with prior payments (if any), equals 2% of patient care revenue.

For the remaining balance of the $20 billion budget, HRSA will calculate an equitable add-on payment that considers 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 the COVID-19 pandemic), and payments already received through prior PRF distributions. All payment recipients will be required to attest to receiving the Phase 3 payment within 90 days and must also accept the associated Terms and Conditions.2 The disbursement does not place limits on which quarters the funds must be applied to cover eligible losses or expenses provided that the funds are expended by June 30, 2021.

Providers will need to provide their taxpayer identification number (TIN) and the following documentation by November 6, 2020 at 11:59 ET:

  • Applicant’s most recent federal income tax return for 2017, 2018, or 2019 if in operation before January 1, 2020; or quarterly tax returns for the fiscal year 2020 if operations began on or after January 1, 2020, or a written statement explaining why the applicant is exempt.
  • If required, the Revenue Worksheet, which can be found at: https://hhs.gov/sites/default/files/prf-gross-revenues-worksheet.xlsx.
  • Supporting documents for Q1 and Q2 operating revenues and expense from patient care for 2019 and 2020.3

HHS considers “operating revenues from patient care” to be net patient service revenue from the delivery of healthcare services directly to patients.4  HHS also considers “operating expense from patient care” to be the operating expenses incurred as part of the delivery of care, including salaries, benefits, medical supplies, contracted and/or employed physicians, interest, and depreciations.5 Further application instructions can be found at: https://www.hhs.gov/sites/default/files/provider-distribution-instructions.pdf.

At this time, some details of the Phase 3 General Distribution are still unclear, such as the exact methodology for determining the amount of a provider’s payment. RubinBrown will continue to release updates as further guidance is released.

1 https://www.hhs.gov/about/news/2020/10/1/trump-administration-announces-20-billion-in-new-phase-3-provider-relief-funding.html
2 https://www.hhs.gov/about/news/2020/10/1/trump-administration-announces-20-billion-in-new-phase-3-provider-relief-funding.html
3 https://www.hhs.gov/sites/default/files/provider-distribution-instructions.pdf
4 https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/general-distribution/index.html#phase3
5 https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/general-distribution/index.html#phase3

 

Readers should not act upon information presented without individual professional consultation.

Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.

 

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