Step-by-Step Guide: How Ob-gyn Practices Can Access HHS Federal Relief Funds

ACOG continues to advocate with Congress for continued financial relief for obstetrician-gynecologists. As information becomes available, this page will be updated. Subscribe to ACOG Rounds emails, ACOG Advocacy News emails, or follow us at @acogaction on social media for details.

Due to the financial impact of COVID-19, Congress allocated $175 billion in federal relief funds for physician practices and health care facilities. This guide outlines the eligibility and application requirements that women’s health practices must follow to access federal relief funds. These funds are not loans and will not need to be repaid.

Phase 4 General Distribution and ARP funds open September 29, 2021, and will close on October 26 at 11:59 p.m. ET.

Phase 4

HHS has allocated $25.5 billion combined funds to the Provider Relief Fund, split into a $17 billion General Distribution Fund and another $8 billion from the American Rescue Plan Act specifically for providers who serve rural Medicaid, Children's Health Insurance Program (CHIP), or Medicare patients. Providers will apply for both programs in a single application and HRSA will use existing Medicaid/CHIP and Medicare claims data in calculating portions of these payments.

General Distribution Phase 4

$17 billion based on providers’ lost revenues and changes in operating expenses from July 1, 2020 to March 31, 2021.

To promote equity and to support providers with the most need, HRSA will:

• Reimburse a higher percentage of lost revenues and expenses for smaller providers as compared to larger providers.
• Provide "bonus" payments based on the amount of services they provide to Medicaid, CHIP, and Medicare patients, priced at the generally higher Medicare rates.

American Rescue Plan (ARP) Rural

$8.5 billion based on the amount of services providers furnish to Medicaid/CHIP and Medicare beneficiaries living in Federal Office of Rural Health Policy (FORHP)-defined rural areas between July 1, 2020 to March 31, 2021.

To promote equity, HRSA will price payments at the generally higher Medicare rates for Medicaid/CHIP patients.

Payments

Will be updated once HHS releases further details.

*HHS is implementing a 60-day grace period to help providers come into compliance with their PRF Reporting requirements if they fail to meet the deadline on September 30, 2021, for the first PRF Reporting Time Period. While the deadlines to use funds and the Reporting Time Period will not change, HHS will not initiate collection activities or similar enforcement actions for noncompliant providers during this grace period.

For more information: Visit the HHS Federal Relief webpage and the press release for future Phase 4 Provider Relief Funding. For more detailed information on receiving payment, please see Provider Relief Fund FAQs.

General Allocation: Phase 3

The Phase 3 deadline was November 6, 2020

HHS has created a new portal of federal relief funds for providers that have already received Provider Relief Fund payments in addition to previously ineligible providers. For eligible providers, the new Phase 3 General Distribution is designed to balance an equitable payment of 2 percent of annual revenue from patient care for all applicants plus an add-on payment to account for revenue losses and expenses attributable to COVID-19.

Eligibility

The following practice types are eligible to apply for funds now through November 6, 2020:

• Providers who previously received, rejected or accepted a General Distribution Provider Relief Fund payment. Providers that have already received payments of approximately 2% of annual revenue from patient care may submit more information to become eligible for an additional payment.
• Behavioral Health providers, including those that previously received funding and new providers.
• Healthcare providers that began practicing January 1, 2020 through March 31, 2020. This includes Medicare, Medicaid, CHIP, dentists, assisted living facilities and behavioral health providers.

Requirements

1. Required documentation:
   1. Most recent federal income tax return for 2017, 2018, or 2019, unless exempt
   2. Revenue worksheet (if required by Field 15)
   3. Operating revenues and expenses from patient care
2. All applicants must submit their TIN and financial information to the Provider Relief Fund Application and Attestation Portal and agree to the Terms and Conditions for your first distribution of funds.
   1. You will be required to agree to these new Terms and Conditions for additional funding

Payments

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. All PRF distributions will be paid to the Filing or Organizational TIN, and not directly to subsidiary TINs. Providers receiving >$100,000 must sign up for Optum Pay in order to support program integrity.

For more information: Visit the HHS Federal Relief webpage and the press release for New Phase 3 Provider Relief Funding. For more detailed information on receiving payment, please see Provider Relief Fund FAQs.

If you previously applied to funds prior to Phase 3, payments may take 10-14 business days. If you are a first time applicant, it can take 5-7 weeks for TINs to be validated. The payment recipient must attest to the checklist within 90 days of receiving payment. Recipients must use these funds by July 31, 2021.

General Allocation: Phase 2

The Phase 2 deadline was September 13, 2020

Following ACOG’s advocacy efforts, HHS has reopened the General Distribution portal for all practices who have not yet received relief funds equal to 2% of your 2018 total practice revenue. Practices that missed the previous deadline to apply for funds and those that were not previously eligible can apply now.

Eligibility

The following practice types are eligible to apply for funds now through September 13:

• Practices that received a small amount of funds based on their Medicare revenue but missed the June 3rd deadline to apply for additional funds. 
• Those that see Medicaid patients and were previously excluded from receiving federal relief funds. 
• Providers who previously received Phase 1 General Distribution payment(s), but rejected and returned the funds and are now interested in reapplying.

Requirements

1. If you previously received a direct deposit from HHS, complete the Provider Attestation Portal to confirm that you received funds and you agree to the Terms and Conditions for your first distribution of funds. 
2. Gather the following materials to submit in the General Distribution Portal:
   1. Your practice’s Taxpayer Identification Number (TIN)
   2. Your practice’s “Gross Receipts or Sales” or “Program Service Revenue” that was submitted on your federal income tax return
   3. Estimated practice revenue losses in March and April 2020 due to COVID
   4. A copy of your practice’s most recently filed federal income tax return
   5. A listing of the TINs of any subsidiary practices that have received federal relief funds but do not file separate tax returns
3. Complete the General Distribution Portal
   1. You will be required to agree to these new Terms and Conditions for additional funding

Payments

Practices should receive relief funds that are equal to 2% of their 2018 total net patient revenue. Relief funds received during both allocations should add to equal this amount. To estimate your payment, you may need to use “Gross Receipts or Sales” or “Program Service Revenue.” For more detailed information, see the General Distribution FAQs linked below.

For more information: Visit the HHS Federal Relief webpage and the Instructions for Applying to Phase 2 of the General Distribution

Reporting Requirements 

• The period of availability of funds is based on the date the payment is received (rather than requiring all payments be used by June 30, 2021, regardless of when they were received).
• Recipients are required to report for each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments).
• Recipients will have a 90-day period to complete reporting (rather than a 30-day reporting period).
• The reporting requirements are now applicable to recipients of the Skilled Nursing Facility and Nursing Home Infection Control Distribution in addition to General and other Targeted Distributions.
• The PRF Reporting Portal will open for providers to start submitting information on July 1, 2021.

These requirements do not apply to the Rural Health Clinic COVID-19 Testing Program, the HRSA COVID-19 Uninsured Program, or the HRSA COVID-19 Coverage Assistance Fund.

Reimbursement for COVID-19 Care Provided to Uninsured Patients

Physicians and practices can be reimbursed for COVID-19 testing and treatment that was provided to uninsured patients. Reimbursements will be based on current Medicare rates for eligible services. However, on April 5, 2022, at 11:59 p.m. ET, the Coverage Assistance Fund will stop accepting vaccination claims due to a lack of sufficient funds. *Submitted claims will be paid subject to the availability of funds.

Eligibility

Patients must have COVID-19 as their primary diagnosis, except in the case of pregnancy, where it may be listed secondarily, to qualify for coverage. Reimbursements will cover the following services if they were provided after February 4, 2020:

• Specimen collection, antibody and other diagnostic testing
• Inpatient, outpatient, emergency room, and telehealth visits related to testing and for treatment after diagnosis.

Requirements

1. Register as a provider participant. Registration is now open at this link. You will need to create or sign in to an Optum ID account.
2. Validate your TIN
3. Set up Optum Pay Automated Clearing House
4. Add a Provider Roster
5. Add and Attest to Patient Roster
6. Submit patient claims electronically.
7. You will be required to agree to the Terms and Conditions for COVID-19 Testing and Treatment

Payments

The Health Resources and Services Administration (HRSA) began sending reimbursements in mid-May 2020.

For more information: Visit the HRSA webpage and FAQ.

Targeted Allocation

For more information, visit the HHS website.

• Rural providers – Rural health clinics and hospitals can receive additional funds, which will be distributed on the basis of operating expenses.
• High-impact areas – Hospitals in significantly impacted areas were contacted to apply for extra funds.
• Indian Health Services – Additional funds are being distributed to Indian Health Services facilities based on operating expenses.
• Skilled Nursing Facilities

ACOG Advocacy

If your practice is not eligible for any of the relief funds detailed above, ACOG is working diligently to secure the financial support you need. Read our statement regarding the methodology HHS is using to distribute relief funds, as well as the letters ACOG has sent to HHS urging them to prioritize women’s health practices that have been excluded from relief efforts.

Information on practice management during Coronavirus is developing rapidly and ACOG will release updates to policy and funding opportunities as they arise. ACOG continues to support its members during this time. If you have any further question or concerns, please reach out to us and submit your questions at acogcoding.freshdesk.com or [email protected].