On October 1, 2020 the Department of Health and Human Services (“HHS”) announced that it will distribute a total of $20 billion as part of Phase 3 of the Provider Relief Funds. The application for Phase 3 funding is now open and will be available from October 5 – November 6, 2020. However, HHS has urged providers to apply early, which may be an indication that the funds will be available on a first-come first-serve basis.

Below are some key details regarding Phase 3:

Eligibility

HHS is making a large number of providers eligible for Phase 3 General Distribution funding, including:

  • Providers who previously received, rejected or accepted a General Distribution Provider Relief Fund payment. Providers that 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.

Payment Methodology – (Apply Early)

All eligible providers will be considered for payment against the below criteria.

  1. All provider submissions will be reviewed to confirm whether they have received a Provider Relief Fund payment equal to approximately 2 percent of patient care revenue from prior general distributions. Applicants that have not yet received Relief Fund payments of 2 percent of patient revenue will receive a payment that, when combined with prior payments (if any), equals 2 percent of patient care revenue.
  2. With the remaining balance of the $20 billion budget, HHS will calculate an equitable add-on payment that considers the following:
    • 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
    • Payments already received through prior Provider Relief Fund distributions.

All payment recipients will be required to attest to receiving the Phase 3 General Distribution payment and accept the associated Terms and Conditions. More information is available on HHS’s website: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html.

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Photo of Tracey Toll Tracey Toll

Tracey focuses her practice on healthcare and regulatory compliance and works with a wide range of clients, including pharmacies, durable medical equipment suppliers, home health agencies, and hospitals. She advises clients on state and federal regulatory and compliance issues, transactional matters, licensure issues…

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Jameson advises clients on regulatory matters, mergers and acquisitions and other business transactions. In order to better understand clients’ financial situations, he earned a master’s degree in accounting with an emphasis on taxation. Jameson has experience analyzing financial statements, institutional investments and tax…

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Photo of Eric Weatherford Eric Weatherford

Eric uses his deep knowledge of Medicaid and Medicare reimbursement, compliance and regulatory matters to help healthcare clients find the answers they need. As the leader of the firm’s Healthcare Regulatory & Compliance Counseling team, Eric advises healthcare providers nationwide on state and

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