10/04/2021

Overview of the eligibility requirements and the application process for the Provider Relief Fund (PRF) Phase 4 funding webcast available

On September 30, 2021, the Health Resources and Services Administration (HRSA) held a webcast entitled, PRF Phase 4 and ARP Rural Informational Webcast. The webcast provided an overview of the eligibility requirements and the application process for the Provider Relief Fund (PRF) Phase 4 funding and the American Rescue Plan (ARP) Rural funding. This summary is created by the National Health Advisory Committee's (NAHC) outside counsel, Alston Bird.

Speakers present included:

• Samantha Ebersold, Public Health Analyst, Division of Policy and Program Operations, HRSA Provider Relief Bureau;
• Sara Williams, Senior Advisor, Division of Policy and Program Operations, HRSA Provider Relief Bureau; and
• Betsy Wieand, Team Lead, Division of Policy and Program Operations, HRSA Provider Relief Bureau.

Attached please find screenshots of the presentation slides from the webcast to accompany the topline summary below.

Overview of the Provider Relief Fund

• The PRF was created to help providers weather the challenges of the COVID-19 pandemic and continue providing access to care for millions of Americans.
• In 2020, Congress provided $178 billion in CARES Act funding to reimburse providers for lost revenue and additional health care expenses from the pandemic. HRSA provided an overview of the various General Distributions and Targeted Distributions, noting that PRF Phase 4 will provide payments based on revenues and expenses from July 1, 2020 to March 31, 2021.
• In 2021, the ARP provided an additional $8.5 billion for rural providers with Medicare, Medicaid, and CHIP beneficiaries to support continuous rural health care delivery.

Overview of PRF Phase 4 and ARP Rural Funding

• $17 billion will be distributed through PRF Phase 4 and $8.5 billion through ARP Rural.
• The PRF Phase 4 and ARP funding application opened on September 29, 2021, and the deadline to submit an application is October 26, 2021, at 11:59 PM.
• Providers can apply for both of these funding streams through a single application and can be considered for both funding streams simultaneously.
• PRF Phase 4 funding, like all previous PRF funding, can be used for costs incurred at any point after January 1, 2020, that can be attributable to the pandemic, and the deadline to use these funds will be dependent on when the payment is received.
• Providers who receive funding must agree to the terms and conditions of the payment. HRSA said the payment terms and conditions are similar to requirements for previous payments and highlighted one new requirement:
• HRSA noted that if a provider reports a merger or acquisition, it may be more likely to be audited to ensure that funding is being used appropriately for patient care.
• If the payment exceeds $10,000, the recipient agrees to inform HHS of a merger with, or acquisition of, any other provider.
• The full terms and conditions are listed on HRSA’s website.
• If a provider does not wish to accept the terms and conditions after receiving payment, the provider may reject the funds and return the money within 15 days.

Provider Eligibility

• Phase 4 Funding: HRSA provided examples of potentially eligible providers, including: providers with Medicare, Medicaid, and CHIP beneficiaries; dental service providers; behavioral health providers; and state licensed or credentialed Assisted Living Facilities.
• ARP Rural Funding: Providers with Medicare, Medicaid, and CHIP beneficiaries who operate in or serve patients from a rural area; rural health clinics and critical access hospitals; and in-home health, hospice, or long-term service providers may be eligible.
• Providers who are unsure about their eligibility are welcome to apply.
• Providers do not have to be located in a rural area to be eligible; providers may also qualify if they serve rural beneficiaries.
• The definition of rural beneficiaries is fairly expansive – providers are encouraged to review the definition on the HRSA website.
• Providers are not required to verify whether patients live in a rural area. HRSA will calculate payments based on claims data already available to them.
• HRSA emphasized that providers may be eligible regardless of where care is delivered (at medical centers, at home, or in the community).
• Additional details about the eligibility criteria are available on the HRSA website.

Payment Calculations

• ARP Rural payments are calculated based on the number and type of Medicare, Medicaid, and CHIP claims for beneficiaries living in a rural area between January 1, 2019, and September 30, 2021.
• HRSA will price Medicaid and CHIP claims data at Medicare rates, with some exceptions for services provided predominantly by Medicaid and CHIP.
• There will be a minimum payment amount for all eligible recipients, potentially including providers that only provided services to one Medicare, Medicaid, or CHIP beneficiary living in a rural area.  
• PRF Phase 4 funding will be distributed with an increased focus on equity, targeting small providers.
• Large providers will receive a payment of a percentage of their revenue and expense losses.
• Medium and small providers will receive a payment of a percentage of their revenue and expense losses, and a supplemental payment.
• Base payments will be determined after HRSA has analyzed the data from the applications and will not exceed 100 percent of losses and expenses from July 1, 2020 to March 31, 2021.
• HRSA will price Medicaid and CHIP claims data at Medicare rates, with some exceptions for services provided predominantly by Medicaid and CHIP. HRSA will use claims data already available to them.
• HRSA advised applicants to enter all eligible TINs as failing to do so may result in lower payments.
• 75% of funding will be allocated to payments calculated from operating revenues and expenses.
• 25% of funding will be allocated to bonus payments tied to services provided to Medicare, Medicaid, and CHIP beneficiaries.

Application Process

Overview:

• HRSA has published several resources for providers to reference before and during the application process.
• Providers should gather information and relevant supporting documents before beginning the application. Important documentation includes:
• Applicant TIN and subsidiary or billing TINs included in the IRS tax filing.
• Financial statements showing the operating revenues and expenses from patient care in 2019 quarters 1, 3, and 4; 2020 quarters 1 and 2; and 2021 quarter 1.
• Federal income tax return, audited financial statements, or other financial statements documenting annual revenues.
• Providers may submit more than one application before the deadline, to correct errors or include additional information for consideration. HRSA will review the latest report submitted prior to the application deadline.
• If payments are over $100,000, providers are required to enroll in automated clearing house (ACH) payments. HRSA encourages providers to sign up for ACH when they submit their applications to avoid delays.
• Once providers receive a payment, they are required to attest to the payment and accept the terms and conditions through the portal to complete the application process.

Part 1: IRS TIN Validation

• HRSA walked through how to submit TINs for validation on each page of the application portal. The attached slides show each page of the application portal that HRSA discussed.
• Staff highlighted the following important things to keep in mind:
• For new providers, the application portal will show instructions for creating a new ID.
• For returning providers, the portal will ask them to sign in with their credentials. If providers have not logged into their accounts for more than 90 days, the portal will ask them to reset their password.
• Providers will need a One Healthcare ID to begin an application.
• The IRS can take up to 4 days to validate TINs, so providers are encouraged to begin their applications early.
• When submitting the organization TIN, providers must enter their name exactly how it appears on their IRS W-9 form (i.e. “&” instead of “and,” or “Inc.” instead of “Incorporated”).
• If a provider received Phase 3 funding and has not yet attested to that funding, the provider must attest to the Phase 3 funding before they can start the Phase 4 funding application.
• Providers must name an administrator who is authorized to handle all aspects of the application submission. This administrator must provide a valid email and be easily contactable if HRSA reaches out for any reason.
• HRSA will flag applications with reported figures that fall outside of HRSA’s expected range for that provider type. Expected ranges are calculated according to the methodology published on HRSA’s website.
• Providers must submit a full list of subsidiary TINs on their applications.
• Once the IRS has validated the TIN, the homepage will show a green check and a “Get Started” link to begin the application.
• The application will prepopulate some information from the IRS into the application. Providers must fill out the remaining sections of the contact information page before they can progress to the application.

Part 2: Revenues and Expenses

• HRSA emphasized that the revenues tab is the most important part of the application.
• Staff said HRSA has built in some internal checks and instructions to help providers avoid common mistakes, but providers should triple-check the information provided to ensure everything is correct.
• Providers should upload their supporting documentation to this tab.
• HRSA emphasized the importance of providing thorough and complete supporting documentation. Staff said if a provider’s application is flagged during the review process, HRSA will use the supporting documentation provided to validate the information in the application.
• More information about the required supporting documentation can be found on HRSA’s website.

Part 3: ARP Rural Funding

• At the end of the application, there is a tab where providers may request to be considered for ARP Rural funding.
• HRSA emphasized there is no penalty to submitting an application and having the request rejected.
• HRSA also noted that providers must supply the required banking information and must also agree to additional terms and conditions for the ARP Rural payments.

Question & Answer Session

• Questions answered during this session are captured in the attached slides.
• In response to the questions raised, HRSA stated the following:
• Phase 4 funding will be distributed to promote equity among small providers and large providers, with bonus payments accounting for the number of Medicare, Medicaid, and CHIP patients served.
• Phase 4 funding can be applied to any costs attributable to the coronavirus from any point after January 1, 2020.
• HRSA will classify providers as small, medium, or large according to annual revenue from patient care. It will determine payments and supplements according to set ranges for each type of provider.
• Providers will not need to verify their beneficiaries are rural to receive an ARP Rural payment because HRSA will use claims data it already has.
• HRSA will make Phase 4 and ARP Rural bonus payments based on available claims data. It will not adjust payment amounts for entities that began operations halfway through 2019 or 2020 and do not have full financial data to report.
• HRSA will use claims data associated with billing TINs to determine payments, so providers should include all billing TINs to ensure full payment.
• Recipients of ARP Rural payments may not allocate that funding to non-rural subsidiaries; ARP Rural funding may only be delegated to the billing TIN that was approved to receive that funding to ensure it is used appropriately for rural beneficiaries.
• Phase 4 funding is more flexible than ARP Rural funding – funds do not necessarily need to be allocated to the approved billing TIN. 

HRSA Resources

• Providers should reach out to the Provider Support Line at 866-569-3522 with additional or provider-specific questions.
• HRSA provided several resources on its website. Links to the resources mentioned throughout the webcast are captured in the attached slides.
• HRSA noted a second webcast is scheduled for next week, which will cover the same content as this session. Additional webcasts are scheduled for later in October and will incorporate answers to the questions raised during the first webcasts. Links to register for these webinars are available here:
• Tuesday, October 5, 3:00 – 4:00PM – register to attend 
• Wednesday, October 13, 3:00 – 4:00PM – register to attend 

Thursday, October 21, 3:00 – 4:00PM – register to attend