CARES Act Round 3

The Department of Health and Human Services (HHS) has issued another round of funding under the CARES Act Provider Relief Fund (PRF).  Many of you have already applied for and received a payment in the amount of 2% of your 2019 revenues from the fund.  This third round of funding opens the application window back up for those that:

  • did not receive funding in the first or second rounds or received an incorrect amount
  • whose business was not in operation in 2019 but was in the first quarter of 2020
  • or those that could potentially obtain an “add-on” payment for “lost revenues”

HHS has defined “lost revenues” vaguely and we are not sure who would qualify and who would not, but it does not appear that there is no penalty for applying.  See the release from the ADA below with additional information.

https://www.ada.org/en/publications/ada-news/2020-archive/october/hhs-announces-phase-3-of-the-provider-relief-fund

Along with the announcement of additional funding, the HHS provided some additional color on the reporting requirements for any PRF recipient.  It now appears that the HHS is requiring that all PRF funds be spent by June 30, 2021 on healthcare-related expenses such as supplies, equipment, or training related to COVID-19. (You did not miss this first time around. This is a new requirement added after funds were distributed for Phase 1 and 2.)  If the practice cannot show that the funds were spent on healthcare-related expenses, then you can point to lost revenue from 2019 to 2020 as a use of funds, however, how this lost revenue is defined is vague in our opinion. 

Should you chose to accept funds from Phase 3 or if you have accepted funds from Phases 1 or 2 of this program, you should be aware that the HHS is requiring that you report your use of funds but they have not released how or where to report this information yet.  Any practice that has accepted funds should do their best to keep their accounting and books as up to date as possible so that information can be reported to HHS to justify the amounts received as soon as the reporting mechanism is available.

If you choose to move forward with the application, you can apply at the link below.  Terms and conditions for Phase 3 funding are linked below as well.

https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html

https://mcusercontent.com/e45b7853c957a421fe5b7e1b2/files/0fb3f75f-4a81-4a93-8c9c-cebcbe951c90/terms_and_conditions_phase_3_general_distribution_relief_fund.pdf