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October 5, 2020

PRF Phase 3 Portal Opens, Applications Due by November 6. The Department of Health and Human Services (HHS) opened the portal for the $20 billion Provider Relief Fund (PRF) Phase 3 General Distribution this morning as planned. In addition to the portal, HHS posted more information about Phase 3 on their PRF web page (scroll down to "How to Apply for Phase 3 General Distribution"), along with the terms and conditions for Phase 3. HHS posted an updated version of their frequently-asked questions (FAQ) with 9 pages that address Phase 3 (see page 40 and following). The FAQ notes in several places that if a provider was unable to complete its Phase 2 application, it can restart the application under Phase 3, as Phase 3 is another opportunity to apply for the 2% of patient revenue that was offered under Phase 2. The deadline for Phase 3 applications is November 6.

The post defines eligibility for Phase 3:

All providers eligible for a previous PRF distribution, plus new 2020 providers and behavioral health providers may apply.

Providers may be eligible regardless of whether they were eligible for, applied for, received, accepted, or rejected payment from prior PRF distributions.

To be eligible to apply, the applicant must meet at least one of the following criteria:

  • Billed Medicaid/CHIP programs or Medicaid managed care plans for health-related services between Jan. 1, 2018-Mar. 31, 2020; or


  • Billed Medicare fee-for-service during the period of Jan.1, 2019-Mar. 31, 2020; or
  • Be a Medicare Part A provider that experienced a CMS approved change in ownership prior to Aug. 10, 2020; or
  • Be a state-licensed/certified assisted living facility as of Mar. 31, 2020

Additionally, to be eligible to apply, the applicant must meet all of the following requirements:

  • 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 (Note: patient care includes health care, services, and support, as provided in a medical setting, at home, or in the community); 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)

Note: Receipt of funds from SBA and FEMA for coronavirus recovery or of Medicaid HCBS retainer payments does not preclude a healthcare provider from being eligible.

The FAQ gives additional detail on eligibility for Phase 3. Suffice to say, virtually all Medicare and Medicaid providers are eligible, along with private-pay assisted living. Just because a provider is eligible does not mean they will receive a payment. The web post defines the how payments will be determined:

  • Phase 3 General Distribution supports providers who have been most significantly impacted by COVID-19, as measured by changes in their revenues and expenses from patient care
  • If a provider did not previously receive approximately 2% of annual revenues from patient care, they will receive this amount consistent with prior general distributions, plus their Phase 3 allocation
  • Payments received in prior PRF distributions will be considered when calculating a provider's Phase 3 payment
Again, there is more detail in the FAQ. HHS clarifies that beyond the 2% catch-up, the amount of the payments cannot be determined until HHS sees how many providers apply. This is because HHS capped the total payout at $20 billion.

AHCA/NCAL Provider Relief Fund Reporting Office Hours Part 2 (from AHCA/NCAL). AHCA/NCAL will host a second Office Hours on the Provider Relief Fund (PRF) Reporting Guidance on Friday, October 9 at 3 PM Eastern. Speakers will address: 

  • PRF reporting and financial management requirements and suggested action steps; 
  • Possible approach to stimulus reconciliation and modeling; and  
  • Highlights from written responses to the October 2 webinar follow-up Q&A. 

This webinar is open to all AHCA/NCAL members. Registration is required. The webinar will be recorded.

A recording of the October 2, 2020 AHCA/NCAL hosted PRF Requirements Office Hours Part 1 is now available on ahcancalED.

Medication Administration Certifications, RN Quality Assessments for DD Services. Before August 1, 2020, the Department of Developmental Disabilities (DODD) provided regulatory relief by allowing staff to continue to pass medications for up to 120 days after their Medication Administration Certification expired. This relief ended August 1, 2020, for all certification categories, so all staff administering medications in the DD system now must have current certifications. DODD also suspended RN Quality Assessments (QAs) in March. The department now has restarted them, but is allowing a six-month extension to complete them, equivalent to the period other regulatory work was suspended. For additional information, see DODD’s Medication Administration COVID-19 guidance webpage

Unusual Incident Log Reviews. DODD also is restarting reviews of unusual incident (UI) logs. In their recently released memo, DODD writes, “[c]ounty boards and DODD will resume their process of requesting UI logs on a representative sampling as outlined in OAC 5123-17-02 (N)(1)-(3). However, unusual incident logs can be requested at any time to ensure compliance with the rule.”

CDC Guidance on How COVID-19 Spreads. The Centers for Disease Control and Prevention (CDC) posted new guidance about transmission of the SARS-CoV-2 virus that causes COVID-19. The guidance lists a hierarchy from the most likely method of transmission (close contact) to less likely methods and emphasizes the importance of distancing and wearing masks to prevent spread. The guidelines address airborne transmission, which has been controversial and can have implications for ventilation systems. CDC wrote:

There is evidence that under certain conditions, people with COVID-19 seem to have infected others who were more than 6 feet away. These transmissions occurred within enclosed spaces that had inadequate ventilation. Sometimes the infected person was breathing heavily, for example while singing or exercising.

AHCA/NCAL PPE Vendor List. AHCA/NCAL compiled an extensive list of vendors who can supply various types of personal protective equipment (PPE) to members, along with other PPE-related resources. AHCA/NCAL indicates it vetted these vendors as successfully delivering PPE to long-term services and supports providers.