More HHS Provider Relief Funds Released; Your Look At PRF Data
On June 9, the Department of Health & Human Services (HHS) continued to push COVID stimulus dollars under the Provider Relief Fund (PRF) out to providers. In their most recent announcement, HHS designated $25 billion dollars to Medicaid or CHIP providers and safety net hospitals. We’ll catch you up to speed.
Medicaid/CHIP PRF Distribution
With respect to Medicaid and CHIP providers, including under managed care, HHS announced the release of $15 billion in a Medicaid/CHIP targeted distribution. Providers will need to submit annual patient revenue information to the HHS provider relief portal in order to receive their distribution. HHS indicates payments will be equal to at least 2% of reported gross revenues from patient care. To be eligible, providers must submit this data by July 20, 2020.
Providers who received previous HHS PRF distributions under the “General Distribution” (see chart below) are not eligible for this Medicaid/CHIP specific distribution. HHS indicates 62% of providers already received funds under the General Distribution, whereas this recent distribution will push funds out to the remaining 38% of providers who did not receive those dollars.
Eligible providers would need to meet several criteria:
- Have billed Medicaid for healthcare-related services during January 1, 2018 to December 31, 2019 or own an included subsidiary that has billed Medicaid for healthcare-related services during that same period;
- Must have either (i) filed a federal income tax return for fiscal years 2017, 2018 or 2019 or (ii) be an entity exempt from the requirement to file a federal income tax return and have no beneficial owner that is required to file a federal income tax return. (e.g. a state-owned hospital or healthcare clinic);
- Must have provided patient care after January 31, 2020;
- Must not have permanently ceased providing patient care directly, or indirectly through included subsidiaries;
- If the applicant is an individual, have gross receipts or sales from providing patient care reported on Form 1040, Schedule C, Line 1, excluding income reported on a W-2 as a (statutory) employee.
Safety Net Hospital Distribution
HHS also announced $10 billion in funds targeted at safety net hospitals. To qualify, a hospital would need to have the following:
- A Medicare Disproportionate Payment Percentage (DPP) of 20.2 percent or greater;
- Average Uncompensated Care per bed of $25,000 or more. For example, a hospital with 100 beds would need to provide $2,500,000 in Uncompensated Care in a year to meet this requirement;
- Profitability of 3 percent or less, as reported to CMS in its most recently filed Cost Report.
The distribution amount for an eligible safety net hospital is the proportion of the individual facility score (number of facility beds multiplied by DPP) to the cumulative facility scores for all safety net hospitals, times the $10 billion safety net distribution. HHS used 2018 cost report data. Each recipient will receive at least $5 million with the largest distribution being $50 million. The safety net hospital distribution will go out this week.
Future PRF Distributions
With over $70 billion left to be distributed from the PRF, HHS is now turning its attention towards a second round of funding for “high impact” COVID hot spots. In addition to $12 billion already released, a communication was recently sent to hospitals asking them to submit information on the number of COVID-19 positive inpatient admissions between the dates of January 1 and June 10. HHS intends to review this data to determine the release of additional dollars. To be considered, hospitals will need to submit this information by June 15 at 9:00 PM ET. Details for submission would be in the HHS correspondence hospitals received.
HHS is also working on a targeted distribution to broadly send funds to dentists. No more information has been provided on this distribution formula.
All total, over $102 billion has or is in process of being distributed from the PRF, leaving roughly $73 billion left to be distributed by HHS.
What Does The HHS Data Reveal About PRF Allocations?
HHS has released various pieces of information on those who have accepted and attested to the terms and conditions of the PRF funds. To date, $52.6 billion has been attested to, see image below.
- General Distribution (Tranche 1, 2) — $50 billion. HHS has provided a breakdown by state for the first $30 billion (Tranche 1) distributed, but not of the full allocation, as Tranche 2 is still being disbursed.
- High Impact Areas (Hot Spots) Distribution – $12 billion released to 395 hospitals. Not surprisingly, the top 12 hospitals receiving these payments are located in New York with their payments ranging from $108 million to $277 million. Ninety hospitals in NY received dollars. Hospitals in 32 states and the District of Columbia received funds with the smallest payment to a hospital being $7.7 million.
- Rural Distribution — $10 billion released to 7,988 providers. These distributions went to rural hospitals, including Critical Access Hospitals, rural health centers and rural health clinics. Twelve states had over $300 million distributed to providers in their state. Texas had 393 providers receiving a combined $634 million. Minnesota had 118 providers receiving a combined $384 million, Iowa with 177 providers gaining $383 million and Kansas with 201 providers totaling $382 million.
- Skilled Nursing Facilities (SNFs) — $4.9 billion was distributed to 13,237 SNFs across the country. Only California, New York, Ohio and Texas topped the $300 million mark for the SNFs in their states. For example, New York’s 831 eligible SNFs received $394 million combined and Ohio’s 976 eligible SNFs received over $314 million. The smallest allocation went to one SNF in Guam at $155,000.
- Uninsured (claims-based) – Specific to reimbursing providers for COVID testing and/or treatment for the uninsured, roughly $100 million has been paid out of the PRF to just over 3,150 providers so far. Amounts range from very minimal dollars to over $4.5 million. These are all claims-based reimbursements so are unlike the other PRF distributions.
No data was released on the Indian Health Service distribution.
CLA Can Help
We are working daily with our clients on PRF funds, assisting them in understanding eligiblity and data submission requirements, analyzing terms and conditions, and ensuring a comprehensive approach to evaluating, tracking, and documenting use of PRF funds (including use of our COVID funds tracker guide). If you have questions or would like us to help you, your practice or organization, please reach out.
Jennifer Boese is the Director of Health Care Policy at CLA. She is a highly successful public policy, legislative, advocacy and political affairs leader, including working in both the state and federal government as well as the private sector. She brings over 20 years of government relations and public policy knowledge with her to CLA. Well over half of her career has been spent dedicated to health care policy and the health care industry, affording her a deep understanding of the health care market and environment, health care organizations and health care stakeholders. Her role at CLA is to provide thought leadership, policy analysis and strategic insights to health care providers across the continuum related to the industry's ongoing transformation towards value. A key focus of that work is on market innovations and emerging payment models. Her goal is to help CLA clients navigate and thrive in an increasingly dynamic health care environment.
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