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.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.