Supplemental Health Care Policy Update – September 14, 2021

September 21, 2021

In this update: 

  • Provider Relief Fund (PRF) Updates
    • HHS to Distribute $17 Billion through Phase 4 of PRF and Additional $8.5 Billion to Rural Providers
    • HHS Releases Calculation Details for Phase 3 of PRF
    • HHS Provides 60-Day Grace Period for First PRF Reporting
  • NYC DOHMH and MCOs to Reimburse Providers for Counseling Unvaccinated Medicaid and MA Patients

Provider Relief Fund Updates

HHS to Distribute $17 Billion through Phase 4 of PRF and Additional $8.5 Billion to Rural Providers
On September 10th, the Department of Health and Human Services (HHS) announced that its Health Resources and Services Administration (HRSA) will make $17 billion available to providers affected by the Covid-19 pandemic through Phase 4 of the PRF. Providers may apply beginning September 29th. 

HHS intends to use a new methodology to allocate these funds to favor small- and medium-sized providers and providers who serve Medicare and Medicaid populations, as follows:

  • 75% of the allocation will be based on reported revenue losses and Covid-19-related expenses from July 1, 2020 to March 31, 2021. Providers will be separated into three groups:
    • Large providers will receive a base reimbursement of a percentage of their losses and Covid-19 expenses.
    • Medium and small providers will receive this base reimbursement plus a supplement, which will be higher for small providers than medium providers.
    • HHS will determine the exact parameters of these payments after all applications are received. No provider should expect to receive more than 100% of their reported losses and Covid-19 expenses.
  • 25% of the allocation will be based on providers’ total amount and type of services provided to Medicare, Medicaid, and CHIP enrollees. 
    • The total amount of services will be calculated as a dollar figure, with all services priced at Medicare rates (except for some “services provided predominantly in Medicaid and CHIP”). 
    • Eligible providers who serve any Medicare, Medicaid, or CHIP patients living in rural areas will receive a minimum payment.

HHS will also provide a separate $8.5 billion to rural providers, as allocated in the American Rescue Plan (ARP). These payments will be calculated similarly to the second allocation above, based on quantity and type of service provided to Medicare, Medicaid, and CHIP enrollees.

The 2020 year-end Consolidated Appropriations Act (CAA) required HHS to disburse at least 85 percent of the remaining funds in the PRF through Phase 4, indicating that roughly $3 billion of unobligated PRF funds remain. More information on Phase 4 is available here.

HHS Releases Calculation Details for Phase 3 of PRF
HHS also released information about how the allocations for Phase 3 of the PRF were calculated. The Phase 3 amount was calculated as :

  • 2% of the reported annual patient care revenue (APCR); or 
  • 88% of an outlier-adjusted calculation of lost revenues and Covid-19-related expenses. Specifically:
    • If a provider reported that losses/expenses for a quarter were more than 50% of the APCR, HHS reduced their losses/expenses to the mean for their provider type. For example, for a home and community-based services (HCBS) provider, the level of losses/expenses would have been reduced from their reported amount (greater than 50% of APCR) to 3% of APCR.
    • HHS reduced all reported amounts that were more than one standard deviation away from the mean for the provider’s type to that level. For example, any primary care practice reporting losses/expenses of more than 15.61% of their reported APCR had their losses/expenses reduced to 15.61% of APCR. 
    • For new providers in 2019 or 2020, losses were capped at the median for their provider type. 

Payments were then reduced by any previous Phase 1 or 2 PRF funds received. As a result, about 31 percent of applications received $0 in Phase 3. An additional 5 percent required manual validation. Providers may request a reconsideration of the amount they received by contacting PRFReconsiderations@hrsa.gov. 

The methodology document is available here.

HHS Provides 60-Day Grace Period for First PRF Reporting
HHS also announced that it would offer a 60-day grace period to providers who received PRF funds before June 30, 2020. Such providers had to expend their PRF allocation by June 30, 2021, and were required to report their use of the funds by September 30, 2021. However, HHS has stated it will not initiate collection activities or enforcement actions during the grace period, allowing such providers until November 29th to report. 

HHS’s press release is available here.

NYC Update

NYC DOHMH Offers Reimbursement for Counseling Unvaccinated Medicaid and MA Patients
On September 9th, the New York City Department of Health and Mental Hygiene (DOHMH) announced in a Health Advisory (available here) the launch of a new program that reimburses primary care providers for reaching out to patients to encourage vaccination against Covid-19. Through this program, which will run through October 31st, DOHMH is partnering with certain Medicaid and Medicare Advantage plans to compensate enrolled primary care providers to:

  • Initiate outreach to counsel eligible unvaccinated patients in their patient panel;
  • Counsel them to obtain Covid-19 vaccination; and 
  • Arrange for vaccination either at the provider’s facility or by assisting the patient in securing an appointment for vaccination. 

Current plans participating in the program are Healthfirst, MetroPlus Health, Empire BCBS/HealthPlus, and Amida Care. Additional plans are expected to join the program. Participating health plans will give providers the names of eligible Medicaid and Medicare Advantage members. 

The “Complete Counseling Session” will be a billable encounter requiring at least 3 minutes of counseling. It may be provided by a licensed health care provider at a rate of $50 per session, or by the health care provider’s non-clinical designee at a rate of $25 per session. Requirements for the Complete Counseling Session and sample language for initiation of the conversation are available in the provider toolkit here. More details on the program are available here. 

DOHMH will host a webinar this Friday, September 17th at 1pm to review this payment program as well as its simultaneous advisory directing all clinicians to provide unvaccinated individuals with vaccine information. Registration for the webinar is available here.