HHS Expands PRF Eligibility, Relaxes Fund Usage Requirements

The Department of Health and Human Services (HHS) recently issued a policy update that makes significant changes to the Provider Relief Fund (PRF) program. The Oct. 22 announcement not only expands PRF eligibility to healthcare providers that were excluded from previous distributions; it relaxes reporting requirements for recipients, allowing them more flexibility in how they apply funds to lost revenue.

Expanded Eligibility

Previous PRF distributions focused on providers that accept Medicare and Medicaid, but this latest policy change expands eligibility for PRF Phase 3 distributions to the following providers regardless of whether they accept Medicare or Medicaid:

• Behavioral health providers
• Allopathic and osteopathic physicians
• Dental providers
• Assisted living facilities
• Chiropractors
• Nursing service and related providers
• Hospice providers
• Respiratory, developmental, rehabilitative, and restorative service providers
• Emergency medical service providers
• Hospital units
• Residential treatment facilities
• Laboratories
• Ambulatory healthcare facilities
• Eye and vision services providers
• Physician assistants and advanced practice nursing providers
• Nursing and custodial care facilities
• Podiatric medicine and surgery service providers

If this change now makes you eligible for Phase 3 distributions, you have until Nov. 6 to submit your application.

Relaxed Fund Usage Requirements

While the term “lost revenue” was specifically used in the initial description of PRF usage, it was later defined as revenue minus expenses (i.e., net income). The policy position of HHS was that providers should not have increased profitability, relative to the prior year, due to PRF proceeds. HHS was attempting to route funding where it was most needed – to vulnerable providers struggling to remain viable.

In recent weeks, HHS heard many concerns regarding this approach. HHS’s latest policy update reverses this position: “PRF should allow a provider to apply PRF payments against all lost revenues without limitation.”

This point may be relevant as providers evaluate whether to pursue a PRF Phase 3 distribution. Knowing that PRF money can be used as an offset to lost revenue – as well as applicable COVID-19 expenses – may make the decision to apply more appealing.

If you need assistance navigating PRF requirements, please reach out to your KSM advisor or complete this form.

Visit the KSM COVID-19 Resource Center