As the CCA reported earlier in 2020, HHS previously made grants available to chiropractors (and many other providers, hospitals, and systems) to the tune of $50 billion, in what was called a General Distribution. These distributions, which were covered extensively in our COVID-19 article, amounted to 2% of doctors’ annual revenue (total patient care revenue, not just Medicare). The initial General Distribution was for $50 billion.
Recently, HHS announced a NEW distribution of the Provider Relief Fund – Phase 3. Providers can now apply for a new round of General Distribution funds totaling another $20 billion. Phase 3 now opens the door for even more chiropractic physicians to acquire funds through this program, including doctors who were new to practice in 2020. In fact, HHS indicates that, “Providers may be eligible regardless of whether they were eligible for, applied for, received, accepted, or rejected payment from prior PRF distributions.”
Which health care providers, including chiropractic physicians, are eligible?
Those who billed Medicare or Medicaid between January 1, 2018-March 31, 2020. Other providers include dentists, assisted living facilities, and behavioral health providers.
Requirements for eligibility require providers:
- “Filed a federal income tax return for fiscal years 2017, 2018, 2019 if in operation before Jan. 1, 2020; or be exempt from filing a return; and
- Provided patient care after Jan. 31, 2020; and
- Did not permanently cease providing patient care directly or indirectly; and
- For individuals providing care before Jan. 1, 2020, have gross receipts or sales from patient care reported on Form 1040 (or other tax form)”
If you believe you meet the requirements, simply visit the Provider Relief Fund Application and Attestation Portal, sign in (or create a new account), and complete the application. You can start that application here.
How much will providers receive?
This section is directly from HHS:
- “All provider submissions will be reviewed to confirm they have received a Provider Relief Fund payment equal to approximately 2 percent of patient care revenue from prior general distributions. Applicants that have not yet received Relief Fund payments of 2 percent of patient revenue will receive a payment that, when combined with prior payments (if any), equals 2 percent of patient care revenue.
- With the remaining balance of the $20 billion budget, HRSA will then calculate an equitable add-on payment that considers the following:
- A provider’s change in operating revenues from patient care
- A provider’s change in operating expenses from patient care, including expenses incurred related to coronavirus
- Payments already received through prior Provider Relief Fund distributions.”
Deadline
Applications must be received by HHS by November 6, 2020. This is an intentionally short time-frame, so DO NOT WAIT!
Reporting requirements for the Provider Relief Fund recipients:
Recipients of provider relief funds are required to file reports as described in HHS’ reporting requirements document. A few weeks ago, HHS modified the reporting requirements document… again. First, they lowered the reporting threshold to include any provider that received more than $10,000 (previously the threshold was much higher). Thus, some of our doctors will now be required to provide a post-payment report on the funds received.
One additional notable change in this document was to significantly change the definition of “revenues.” Although previous guidance indicated that the funds could be reconciled against lost revenues, HHS is now defining revenues as “a negative change in year-over-year net patient care operating income (i.e., patient care revenue less patient care related expenses for the Reporting Entity, defined below, that received funding).”
This change results in a reconciliation against patient care INCOME and not revenues. In other words, it now is not just total revenues, but instead they require the reconciliation to be patient care revenues less patient care expenses (profit vs. revenue). Of course, this offset is in addition to any expenses directly related to coronavirus.
Reminder – you cannot use the same losses for different grants. Thus, if you are attributing some of your losses to a DCEO grant or a forgivable PPP loan, then you would not be able to use them to reconcile your Provider Relief Fund amounts.
Based on HHS’ statement that providers may be eligible for the new phase of funding regardless of their previous eligibility or rejection, the CCA would strongly encourage doctors to submit an application for this round of funding.