Updates On PRF Phase 2 Payments and Phase 3 Eligibility Expansion

Regulation | October 22, 2020 | by Nicole Fallon

The U.S. Department of Health and Human Services has shared a number of developments this week related to Phase 2 and Phase 3 application rounds including how pending Phase 2 applicants can still apply for Phase 3 and expanding the Phase 3 application to additional providers.

It confirmed that payments continue to roll out in batches for providers who applied for Provider Relief Funds (PRF) under the Phase 2 application process and that it is continuing to research Tax Identification Numbers (TINs) for validation. LeadingAge and other senior living associations have agreed to assist HHS in this important validation of certain assisted living TINs to ensure legitimate ALs are able to receive needed PRF payments. 

In addition to AL providers, HHS also confirmed that all Phase 2 applicants who are still awaiting their TIN being validated, are still in the queue to apply for Provider Relief Funds. However, once their TIN is validated, instead of completing the Phase 2 application, providers should receive an access code to complete the Phase 3 application. If a provider finds that the application they are asked to complete does NOT ask for 2019 and 2020 expense and revenue information, these providers should contact the Provider Support Line at 866-569-3522, where representatives can walk the provider through the process of canceling their Phase 2 application so they can complete the Phase 3 application. This is a positive development, as the Phase 3 funding not only seeks to ensure eligible providers receive a payment of 2% of their annual patient service revenue but also makes them eligible for a possible add-on payment over and above the 2% amount. The add-on payments will be determined based upon looking at how much a provider has already received in PRF payment plus what they report related to their  organization's 2019 and 2020 expense and revenue data. Under the Phase 3 application process, HHS will first ensure eligible providers receive their full 2% payment and then will seek to "equitably distribute" the remaining funds for those providers who have demonstrated need above what has been received thus far.  All Phase 3 applications must be submitted by Nov. 6, which is the Phase 3 deadline to be eligible for any of the $20 billion in PRF.  

HHS also announced on Oct. 22 that the Phase 3 application is now open to residential treatment centers, chiropractors and eye/vision providers. It also confirmed the following providers are eligible even if private pay: nursing service and related providers; hospice providers; respiratory, developmental, rehabilitative and restorative service providers, nursing and custodial care facilities; as well as other providers. At the time of publication the CARES Act Provider Relief Fund website and FAQs have not been fully updated to reflect these changes yet but are expected to be in the coming days.

HHS has also added a webinar on the Phase 3 application process, which will be held live on November 2, at 3 pm. To register.

Finally, HHS published revisions to the PRF reporting requirements that were originally issued on Sept. 19 by removing previous restrictions on the use of PRF dollars to cover lost revenues. See HHS Retracts Limits on Use of PRF for Lost Revenues for additional details.