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Category: Rural Health

CARES PRF Update

February 5, 2022

CARES Phase 4 / Rural ARP Consideration

CARES PROVIDER RELIEF FUND (PRF)

Phase 4 and Rural ARP Reconsideration Update

Toyon is pleased to provide this update on the CARES Provider Relief Fund (PRF). Please feel free to contact Fred Fisher at 888.514.9312, fred.fisher@toyonassociates.com with any questions.

Providers in receipt of CARES Phase 4 and/or rural payments from the American Rescue Plan (ARP) have until May 2, 2022 to request a payment reconsideration. The reconsideration process is available to any provider looking to correct potential errors in their Phase 4 and/or Rural ARP payment according to HRSA’s methodology. HRSA will only consider correction of any errors; and will not consider changes to its payment methodology or policy in the reconsideration process. To request a Phase 4 and/Rural ARP reconsideration, providers must:

1) Review HRSA’s methodology. Providers may also contact HRSA at 866.569.3522 (TTY dial 711) to receive additional information on how Phase 4/Rural ARP payments were determined.

2) Gather the following documents:

a. Payment determination letter from HRSA

b. DocuSign envelope ID for the ARP Rural/Phase 4 application

c. The contact information and Tax ID Number (TIN) included on the original Phase 4/ARP Rural application

d. The reason believed the Phase 4/Rural ARP payment was calculated incorrectly, (related to the PRF Phase 4 and ARP Rural Payment Methodology)

3) Complete and submit the PRF Reconsideration Request Form by 11:59:59 pm EST on May 2, 2022. HRSA states not to include any supplemental information or documentation beyond completing the PRF Reconsideration Request Form and uploading your Phase 4/ARP Rural payment determination letter. HRSA will only review your original submitted application and will request any clarifying information directly, as needed.

Providers expecting, but not yet in receipt of, CARES Phase 4 and/or Rural ARP payments will have 45 days to apply for reconsideration after receipt of a payment determination notice from HRSA. More information is available at HRSA’s PRF Reconsideration site as well as HRSA’s PRF Reconsideration FAQ site. Please also see Toyon’s updated CARES PRF Presentation (February 4) for information on recent CARES PRF allocations, Period 2 Reporting, and new FAQs issued January 27, 2022.

COVID-19 Funding Update

March 26, 2021

Toyon is pleased to provide this update on COVID-19 funding for rural providers.

● $8.5 billion in funding for rural providers

● Providers in rural areas, providers in MSAs less than 500K, and rural referral centers.

● Recognition of COVID-19 expenses – direct, indirect, and stranded – is critical.

$8.5 billion in Provider Relief for Rural Providers

On March 11, 2021, H.R.1319 – American Rescue Plan Act of 2021 was signed into law appropriating $8.5bn of COVID-19 funding for rural providers recognizing healthcare expenses and lost revenues attributed to COVID-19. Rural providers eligible for this funding include:

This legislation specifies as part of eligibility, a provider will submit an application including, “A statement justifying the need of the provider for the payment, including documentation of the health care related expenses attributable to COVID-19 and lost revenues attributable to COVID-19.”

Toyon’s Take

HHS has yet to prescribe how hospitals and providers apply for this additional COVID-19 funding for rural providers. However, documenting healthcare related expenses and lost revenue is the same information providers will be submitting to justify current CARES funding allocations (the reporting was delayed from February 15, 2021). It is possible, yet still undetermined, information reported to the Provider Relief Fund Reporting Portal could be the same information used to determine hospital funding need.

Recognizing all costs – direct, indirect and stranded – is critical not only to justify funding, but also to prove eligibility for additional funding. The legislation notes this funding “includes” expenses as follows:

“…health care related expenses to prevent, prepare for, and respond to COVID-19, including the building or construction of a temporary structure, the leasing of a property, the purchase of medical supplies and equipment, including personal protective equipment and testing supplies, providing for increased workforce and training (including maintaining staff, obtaining additional staff, or both), the operation of an emergency operation center, retrofitting a facility, providing for surge capacity, and other expenses determined appropriate by the Secretary.”

Toyon continues to advocate HHS recognize not only the direct expenses, much of which are delineated in the legislation – but also the indirect and stranded expense resulting from COVID-19. These expenses are currently discussed in HHS’s “$85 FAQ” and may include, but are not limited to:

✓ The inability to flex down during preparations for COVID-19 surges

✓ Rapid employee burnout and turnover

✓ Current labor costs and an unknown future

✓ Excess laboratory cost from pandemic

✓ Wear and tear on assets – shortening the useful life of an asset

We are Here to Help

Please contact Fred Fisher at 888.514.9312, fred.fisher@toyonassociates.com. Feel free to also visit Toyon’s COVID-19 Funding Resources

Respectfully,

Toyon Associates

CARES Act Funding Update

August 6, 2020

HHS allocates $14 billion in targeted “Round Two” payments.
Toyon’s August Series of CARES Updates

Toyon is pleased to provide this update on the CARES Act Public Health and Social Services Emergency Fund (PHSSEF). Toyon’s updates on the PHSSEF will be issued as a series this August. The first update applies to “Round Two” of CARES relief funding from July 2020. During the rest of August, Toyon will be providing these other important updates:

Toyon’s Take on HHS Reports due February 14, 2021 – HHS is releasing funding and documentation reporting instructions by August 17. Recipients have 45 days from the end of 2020 (Sunday, February 14, 2021) to report COVID-19 related expenditures through December 31, 2020.
Toyon’s Take on PHSSEF and Cost Reporting – Key takeaways on the importance of filed cost reports and the PHSSEF.

In July, HHS announced a second round of $14 billion related to three targeted distributions from the PHSSEF.

$10 billion High Impact Payments
$3 billion Safety Net Payments
$1 billion Rural Payments

Toyon is preparing estimates on PHSSEF qualification and funding for hospitals nationally. Please contact Fred Fisher if you would like an evaluation for your hospital(s).

Fred Fisher — fred.fisher@toyonassociates.com
888.514.9312
Toyon’s Covid-19 Funding Resources

HHS Releases $14 billion of “Round Two” Funds
Listed below is further insight on HHS’s Round Two targeted funding distributions totaling $14 billion. Based on a current tally of the PHSSEF, HHS committed to spend $116.4 billion of the $175 billion, leaving $58.6 billion remaining in the fund (not accounting for the HRSA COVID-19 Uninsured Program).

$10 Billion Round Two High Impact Payments
On July 17, HHS announced distribution of High Impact payments eligible to more than 1,000 providers
reporting any of the following (based on data submitted June 15):

Over 161 COVID-19 admissions between January 1 and June 10, 2020.
One COVID-19 admission per day.
A disproportionate intensity of COVID admissions that exceeds the average ratio of COVID
admissions per bed. Responding to an FAQ dated July 22, HHS states the average
admissions per bed ratio (threshold) is 0.54864.

Eligible hospitals are paid $50,000 per COVID-19 admission. In Round One, payment per admission
was $76,975, and included a DSH add-on. High Impact payments received from Round One were
considered in the second distribution.
As of August 3,HHS distributed $9.1 billion of the 10 billion, leaving $900 million HHS will likely be
paying hospitals over the coming weeks.

$3 Billion Round Two Safety Net Payments
On July 10, HHS announced $3 billion in Round Two distribution of Safety Net payments. In this
Second Round, HHS acknowledged shortcomings of qualifying hospitals for safety net payments in
Round One. HHS accounts for recognizing an additional 215 hospitals as safety nets in Round Two by
expanding safety net criteria as follows:

Like Round One, providers must have an Uncompensated Care Cost per Bed measurement at
or over $25,000. In Round Two, HHS corrected this measurement, “annualizing” this data, so
hospitals with short cost reporting periods are properly evaluated.
Like Round One, providers must also have a profitability margin of 3% or less to qualify for
safety net payments. In Round Two, HHS expanded this measurement by evaluating 5 years of financial data reported on the Medicare cost report Worksheet G-3 (as opposed to Round One whereby HHS evaluated one year of financial data). Hospitals qualified in Round Two with a
“profit margin threshold of less than or equal to 3% averaged consecutively over two or more of
the last five cost reporting periods.”
In Round Two, providers still must have a DSH percentage equal to or greater than 20.2% to
qualify for safety net funds (no change from Round One).

$1 Billion in Round Two Rural Payments
On July 10, HHS also announced $1 billion in Round Two distributions for rural providers. In Round Two, sole community hospitals (SCH), Medicare dependent hospitals (MDH), and hospitals in small metro areas with fewer than 250,000 people qualified for payment. Hospitals are eligible for funds of 1% of operating expenses with a minimum payment of $100,000, a supplement of $50 for each “rural inpatient day,” and a maximum payment of $4.5 million. HHS also made payments to rural inpatient psychiatric facilities, inpatient rehabilitation facilities, and long-term acute care hospitals.

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Category: Rural Health

CARES PRF Update

COVID-19 Funding Update

CARES Act Funding Update

In July, HHS announced a second round of $14 billion related to three targeted distributions from the PHSSEF.

$10 billion High Impact Payments

$3 billion Safety Net Payments

$1 billion Rural Payments

Here TO HELP