Provider Relief Fund Quick Hits: Updates for SNFs, Assisted Living, and More
Over the past few weeks, the Department of Health & Human Services (HHS) continued releasing Provider Relief Funds (PRF) to certain entities. Here are your details plus what we’re keeping our eyes on.
Targeted Distributions
In July, HHS announced a second round of $5 billion for nursing homes. It wasn’t until August 27 that the first $2.5 billion of the distribution was sent to eligible nursing homes and Skilled Nursing Facilities (SNFs) under the “Nursing Home Infection Control” distribution.
Eligible nursing homes and SNFs cannot be revoked, must have an active Centers for Medicare & Medicaid (CMS) certification, and have at least six certified beds. Eligible facilities received a per-facility payment of $10,000 plus a per-bed payment of $1,450.
It is important to note that the Nursing Home Infection Control PRF dollars may only be used for increased testing, staffing, personal protective equipment (PPE) and infection control as laid out in the applicable terms and conditions.
In a Frequently Asked Question, HHS elaborates a bit on acceptable uses of these funds:
“…infection control expenses…These include costs associated with administering COVID-19 testing for both staff and residents; reporting COVID-19 test results to local, state, or federal governments; hiring staff to provide patient care or administrative support; incurring expenses to improve infection control, including activities such as implementing infection control ‘mentorship’ programs with subject matter experts, or changes made to physical facilities; and providing additional services to residents, such as technology that permits residents to connect with their families if the families are not able to visit in person.”
On September 3, HHS then announced on another $2 billion (from the $5 billion) to be allocated via a performance-based payment incentive program. Eligible nursing homes must have active certifications, receive CMS reimbursements, and report to at least one of three data sources: Certification and Survey Provider Enhanced Reports (CASPER), Nursing Home Compare (NHC), and Provider of Services (POS).
HHS will use the data submitted by nursing homes along with the Centers for Disease Control and Prevention’s Community Profile Reports (CPRs) and the National Healthcare Safety Network (NHSN) LTCF COVID-19 module data. The CPRs will set the county COVID baselines by which facilities will then have their performance measured against two outcomes: ability to keep new COVID infection rates low among residents; and, the ability to keep COVID mortality low among residents.
The nursing home incentive program will run each of four months (Sept. – Dec. 2020) with $500 million available each month. Nursing homes will be assessed based on a full month’s worth of data submissions.
In a separate targeted distribution, HHS released $1.4 billion on August 14 to 80 free-standing children’s hospitals as an extension of the earlier “safety net hospital” distribution. Eligible facilities received a payment that equaled 2.5% of the annualized net patient revenue with a floor of $5 million and a ceiling of $50 million. In other words, if a facility’s calculated payment amount was below $5 million, it was adjusted up to $5 million. If a facility was over $50 million, it was capped at $50 million.
Phase II General Distribution
On September 1, HHS opened up the Phase II General Distribution to assisted living facilities (ALF). To be eligible, entities must be a state-licensed/certified assisted living facility. HHS indicates that some ALFs have already successfully applied for Phase II because they bill Medicare and/or Medicaid. This announcement is geared towards private pay ALFs that may not have billed these government programs. Entities will have until September 13 to apply for PRF dollars.
HHS indicates it has developed a curated list of TINs based on ALF data from state licensing boards and organizations, the American Seniors Housing Association (ASHA), the American Health Care Association (AHCA), National Center for Assisted Living (NCAL), Argentum, Brookdale, Leading Age, and other assisted living groups.
Eligible ALFs would receive 2% of net patient revenues. With respect to includable revenues, HHS provides some clarifications in their FAQs:
- Excerpt from HHS FAQ: “Assisted living facilities that are applying for Phase 2 – General Distribution funds may include patient care revenue that supports residents’ nutritional, housing, activities of daily living, and medical needs, including purchased services.”
- Excerpt from HHS FAQ: “For residents that live in skilled nursing or assisted living facilities, are resident fees that cover their accommodations considered service revenue or real estate revenues? (Modified 9/1/2020) Resident fees that cover their accommodations can be considered patient service revenue.”
- Excerpt from HHS FAQ: “Many assisted living and memory care communities also offer independent living units within the same community and those independent living residents benefit from services and supports offered by the community. Does the revenue from independent living units fits within the definition of “patient care?” (Modified 9/1/2020) Yes. The revenue from independent living units as a part of larger assisted or skilled nursing facilities fits within the definition of ‘patient care’ applying for the Phase 2 – General Distribution.”
A reminder that Phase II is also still open for a variety of other situations, including Medicaid/CHIP providers, dental practices and those entities that have not received 2% of patient revenues under Phase I. Find more details HERE.
What We’re Keeping Our Eyes On
- HHS’s long-awaited release of PRF reporting requirements. These were to have been released by Aug. 17, but are still being worked out. We await detailed information on determining lost revenues and acceptable uses of PRF.
- Single audit compliance supplement. This is expected out later this fall, but is highly anticipated to assist providers in understanding audit requirements. Single or program audits will be required for those that receive and expend $750,000 or more in applicable federal funds in a fiscal year.
- Next round of distributions. We’ve had Phase I and II. Will we see a Phase III soon or more targeted distributions? There is a sum of roughly $40 billion in PRF funds yet to be distributed.
How We Can Help
We are assisting clients large and small on PRF use, documentation, tracking, single audit and more. We’re here to know you and help you.
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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