a previous alert, HHS has re-opened the application for providers that missed receiving the Phase 1 Tranche 2 payment ($20 billion) that would have afforded providers up to 2 percent of 2018 (2018 or most recent completed tax year ) total gross receipts. While the original announcement spoke to reopening the Phase 1 application, earlier this week, HHS announced that they have expanded the Phase 2 General Distribution (Medicaid/CHIP Providers) to include providers that qualified for Phase 1 General Distribution (Medicare Providers). Previously, Phase 2 was only available for providers that were not eligible for Phase 1.
This new announcement from HHS is a significant departure from the original eligibility requirement. In an updated FAQ, HHS provides further clarification on the eligibility criteria and what providers who were eligible for Phase 1 that did not receive the full 2% total gross receipts should do.
Below is the list of Q&As related to these changes that were updated on Aug. 10:
- Who is eligible for Phase 2 – General Distribution? (p. 22)
- For providers who are now eligible for the Phase 2 – General Distribution that had received a payment in the Phase 1 – General Distribution, which eligibility, application requirements and portal should applicants use? (p. 23)
- Will Phase 2 – General Distribution payments be made to the billing TIN or filing TIN for those who received a payment that was less than 2% of revenue as part of the Phase 1 – General Distribution? (p. 23)
- Can a health care provider that has a primarily Medicaid-focused practice that received a small initial General Distribution payment, but forewent applying for an additional General Distribution payment, now apply for the Phase 2 – General Distribution? (p. 24)
- Does payment from the Phase 1 – General Distribution affect what I may receive as a Phase 2 – General Distribution payment? (p. 24)
- If I rejected my Phase 1 – General Distribution payment, can I apply for a Phase 2 – General Distribution payment? (p. 24)
- If a provider received a Phase 1 – General Distribution payment and submitted financial information in the Provider Relief Fund Payment Portal, but has not yet received a payment that is approximately 2% of patient care revenue, does the provider need to resubmit their financial information in the Provider Relief Fund Application and Attestation Portal? (p. 29)
- If a health care provider received a Phase 1 – General Distribution payment, but did not submit their financial information as required by the Terms and Conditions, which portal should the provider use to now submit their financial documents? (p. 29)
- How should an applicant set up an Optum ID if it is applying for Phase 2 – General Distribution payment on behalf of multiple subsidiaries? (p. 29)
- Is a health care provider that did not deposit a check from the Phase 1 – General Distribution that was subsequently voided after 90 days, eligible to apply for the Phase 2 –General Distribution? (p. 23)
In short, companies that received payments from Medicare in 2019 and/or Medicaid in 2018-2019; provided care since January 31; and have not yet received 2 percent of 2018 (2018 or most recent completed tax year ) total gross receipts are eligible to apply for funding at Provider Relief Fund Application and Attestation Portal. HHS is accepting applications until August 28.
If you are still unsure about your eligibility and the application process, HHS hosted a webinar on the application process on Aug. 13, which is available as an archive.
This is an evolving program with changes occurring regularly. We are sharing information based on what is available at this time. We recommend companies to review the information published at the CARES Act Provider Relief Fund website, especially the FAQ. Companies with any specific concerns or questions should call the Provider Relief Fund Support Line: (866) 569-3522.
