Update on Recent Funding from HRSA

Dear Regional Partners, 

I am pleased to share with you that today, a new application cycle for $25.5 billion in COVID-19 provider funding has opened.  Applicants are able to apply for both Provider Relief Fund (PRF) Phase 4 and American Rescue Plan (ARP) Rural payments during the application process. PRF Phase 4 is open to a broad range of providers with changes in operating revenues and expenses. ARP Rural is open to providers who serve ruralbeneficiaries covered by Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP).

See a detailed list of eligible provider types and application instructions here.

Applications must be received by October 26, 2021 at 11:59 p.m. ET. Providers who have previously created an account in the Provider Relief Fund Application and Attestation Portal and have not logged in for more than 90 days will need to first reset their password before starting a new application. In order to streamline the application process and minimize administrative burdens, providers will apply for both programs in a single application.Yesterday, the U.S. Department of Health and Human Services (HHS) awarded nearly $1 billion in American Rescue Plan funding to nearly 1,300 Health Resources and Services Administration (HRSA) Health Center Program-funded health centers in all 50 states, the District of Columbia, and the U.S. territories to support major health care construction and renovation projects. These awards will strengthen our primary health care infrastructure and advance health equity and health outcomes in medically underserved communities, including through projects that support COVID-19 testing, treatment, and vaccination.  Health centers will use this funding for COVID-19-related capital needs, constructing new facilities, renovating and expanding existing facilities to enhance response to pandemics, and purchasing new state-of-the-art equipment, including telehealth technology, mobile medical vans, and freezers to store vaccines.    FY 2021 American Rescue Plan Funding for Health Center Construction and Capital Improvements award recipients in Region 6 can be found here. Recent awards of over $5 Million to Expand Services at HRSA’s Health Center Program School-Based Service Sites can be found here
Recent awards of over $48 Million to Health Centers for Ending the HIV Epidemic in the U.S. Initiative can be found here

Finally, on September 17, 2021 HRSA announced nearly $350 million in awards to every state across the nation to support safe pregnancies and healthy babies. Funding will expand home visiting services to families most in need, increase access to doulas, address health disparities in infant deaths, and improve data reporting on maternal mortality. 

FY2021 awards to strengthen maternal and child health in Region 6 can be found here: 

Our team at the HRSA Office of Intergovernmental and External Affairs (IEA) remain committed to supporting your COVID-19 response efforts.  Please do not hesitate to reach out to us with questions, concerns, or requests for support and engagement.

Best,
Jeri D. Pickett
HRSA Regional Administrator, Region 6

Change to Provider Relief Funds FAQs

NRHA wanted to notify you of a change to the Provider Relief Fund on justifying what is allowable under expenses.  Page 21 of the attached FAQ from 9.13.21 has eliminated the term “marginal” in the last sentence (see below).  Providers must still relate and document the expenses claimed (net of other reimbursements) to COVID as noted in this and other FAQs.  This clarification in policy also appears to be consistent with the feedback members are receiving when talking with the HRSA PRF hotline.  

How do I determine if expenses should be considered “expenses attributable to coronavirus not reimbursed by other sources?” (Modified 9/13/2021) 
Expenses attributable to coronavirus may include items such as supplies, equipment, information technology, facilities, personnel, and other health care-related costs/expenses for the period of availability. The classification of items into categories should align with how Provider Relief Fund payment recipients maintain their records. Providers can identify their expenses attributable to coronavirus, and then offset any amounts received through other sources, such as direct patient billing, commercial insurance, Medicare/Medicaid/Children’s Health Insurance Program (CHIP); other funds received from the federal government, including the Federal Emergency Management Agency (FEMA); the Provider Relief Fund COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured (Uninsured Program); the COVID-19 Coverage Assistance Fund (CAF); and the Small Business Administration (SBA) and Department of the Treasury’s Paycheck Protection Program (PPP). Provider Relief Fund payments may be applied to the remaining expenses or costs, after netting the other funds received or obligated to be received which offset those expenses. The Provider Relief Fund permits reimbursement of marginal increased expenses related to coronavirus provided those expenses have not been reimbursed from other sources or that other sources are not obligated to reimburse. 

NRHA recommends you speak with your financial advisors/council on what this change may mean to your PRF expenditures and reporting. 

Update of COVID-19 Therapeutics from HHS/ASPR

We wanted to share an update from the Department of US Health and Human Services around policies related to allocation, distribution, and administration efforts surrounding the current monoclonal antibody therapeutics available to combat the COVID-19 pandemic.  

Beginning Monday, September 13th HHS made a change to their distribution process to coordinate through a state/territory-coordinated system.  The intent of this change is to maintain equitable distribution, both geographically and temporally providing states and territories with consistent, fairly distributed supply over the coming weeks and while the USG works to procure additional supply.  Key to this change is that administration site (i.e. providers) will not be able to order mAbs directly from the distributor and must work with their state/territory to access the supply.  

Weekly distribution amounts will be determined based on weekly reports of new COVID 19 cases and hospitalizations in addition to data on inventories.  Weekly distribution determinations posted on phe.gov/mabs

HHS Announced 60 Day Grace Period for PRF Reporting

In addition to making $25.5 billion in new funding available for health care providers affected by the COVID-19 pandemic, in light of the challenges providers across the country are facing due to recent natural disasters and the Delta variant, HHS (Department of Health & Human Services) announced Friday a final 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.

New Provider Relief Funds available – $25.5 billion

The Biden-Harris Administration announced today that the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), is making $25.5 billion in new funding available for health care providers affected by the COVID-19 pandemic.  This funding includes $8.5 billion in American Rescue Plan (ARP) resources for providers who serve rural Medicaid, Children’s Health Insurance Program (CHIP), or Medicare patients, and an additional $17 billion for Provider Relief Fund (PRF) Phase 4 for a broad range of providers who can document revenue loss and expenses associated with the pandemic.  View the press release for the PRF Phase 4 here.  For more information on eligibility requirements and the application process for PRF Phase 4 and ARP Rural payments, visit: https://www.hrsa.gov/provider-relief/future-payments.

Covid-19 Community Vaccine Program

The Mississippi State Department of Health (MSDH) has launched a Covid-19 Community Vaccine Program, aimed at vaccinating home bound patients. MSDH is currently looking for providers in the following counties to participate in the program: Montgomery, Grenada, Jefferson, Carrol, Leflore, and Wilkinson.

If you are interested in becoming a CCVP provider, please view the following information: Covid-19 Community Vaccination Program (CCVP)

NRHA Events Going Virtual

As an organization serving and consisting of public health leaders, NRHA has a responsibility to abide by and serve as a model for proper health precautions. That is why we have made the difficult decision to shift the association’s Rural Health Clinic and Critical Access Hospital Conferences to a virtual environment.

The fourth wave of the COVID-19 pandemic is hitting harder than anyone expected. While Delta variant forecasts are difficult to project, the situation is unlikely to improve between now and this fall.

For these reasons, we ask for your patience as we transition our RHC and CAH Conferences away from our plans to host in Kansas City. As usual, you can register for these events at reduced virtual rates, and all content will be available Sept. 21-24 and on demand at your convenience for a full year.


View virtual rates here…

At NRHA, the health and well-being of our members and all rural Americans is our top priority. We do not want to risk contributing to the spread of this deadly virus, and we don’t want to place rural health care workers, hospitals, and health systems under any more pressure than they already face. 

We know it is not ideal, but virtual events allow NRHA to present – and you to experience – even more educational content than at an in-person event. NRHA will utilize the same platform as our 2021 Annual Rural Health Conference, by far our most intuitive and seamless virtual environment. 

Though this is certainly not what any of us had planned, we look forward to seeing everyone virtually this fall. Rural America is nothing if not resourceful, and together we will continue to overcome the challenges we face. 

How RHCs Should Be Reimbursed for Monoclonal Antibody Infusions

We have received several calls and e-mails in the last few weeks regarding monoclonal antibody infusions in the rural health clinic setting. Tommy Barnhart with the National Rural Health Association provided this breakdown of MA injection reimbursement.

Click here to view a CMS transmittal for freestanding RHCs issued 4/30/21 effective for cost reports ending after 3/31/2021. 

Among other things, it adds lines on Worksheet A specific to Covid vaccine administration (line 31.10) and monoclonal antibody (line 31.11) expenses and new columns on Worksheet B-1 to calculate reimbursement.  The calculation is similar to flu and pneumonia and reimbursed through the cost report in addition to the AIR.  For Covid and monoclonal antibody, this includes Medicare Advantage in addition to traditional Medicare.  As with flu and pneumonia, there is no method to bill the MAC for these services.  Hospital forms have not been adjusted yet but expect those to be done likewise soon.  FQHC forms have been updated similar to freestanding RHC. 

We will continue to work to improve the way that RHCs can bill for vaccine and monoclonal antibody infusions, especially during the critical time in our state’s healthcare system. Please contact us with any further questions.

Summary of the COVID-19 Emergency Temporary Standard (ETS) Rulemaking

On June 21, 2021, the Occupational Safety and Health Administration (OSHA) released an emergency temporary standard (ETS) rulemaking with the goal of protecting health care workers from occupational exposure to COVID-19 in settings where people with COVID-19 are reasonably expected to be present.  

As an ETS, the rule because effective when published on June 21, 2021.  Health care employers are required to be compliant with the sections of the rule on July 6, 2021, or July 21, 2021, depending on the provision.  

NRHA feels the timeline for compliance with this regulation is onerous.  Additionally, we believe the 916-page ETS is overly burdensome for rural providers, requiring health care employers to go above and beyond what many have already put in place following CDC guidelines such as social distancing barriers, patient screening, and a wholistic COVID-19 plan.  

Some requirements to note within the ETS include:  

  • Providers must develop and implement a COVID-19 plan  
  • Providers must limit and monitor points of entry to mitigate COVID-19 exposure  
  • Providers must ensure employees wear facemasks when indoors and when operating a vehicle with another person (this includes employees who are not directly caring for patients) and other restrictions on PPE  
  • Providers must require employees stay at least six feet apart from all other people when indoors except in situations where that is not possible 
  • Employer must install cleanable or disposable solid barriers at each fixed workstation located outside of direct patient care areas, where each employee is not able to be separated by all other people by at least six feet 
  • Provisions regarding proper ventilation with their heating, ventilation, and air conditioning (HVAC) systems to ensure that the amount of outside air circulated is maximized  

The ETS applies to a number of settings where suspected or confirmed COVID-19 patients are treated, including hospitals, home health care works, nursing homes, assisted living facilities, EM, and ambulatory care facilities.  It does not apply to settings where all employees are full vaccinated, non-employees are screened prior to entry and suspected or confirmed COVID-19 patients are not present.   

NRHA believes these regulations listed above will be particularly difficult for rural providers to comply with. Additionally, we have already heard from several members that they believe the facemask and social distancing requirements will run contrary to both the science and the current state and Federal guidelines for individuals who have been vaccinated. Further, implementing overly burdensome cleaning guidelines, installing physical barriers, and ensuring proper ventilation will be particularly difficult for rural providers already operating on slim margins. Health care providers could have used the PRF allocations to implement these kinds of regulations over the past 15-months, but instead OSHA implemented this rulemaking after the deadline for the majority of rural providers use of the funds.   

NRHA plans to submit comments on this ETS ahead of the July 21, 2021, deadline. In our comments, NRHA will urge OSHA to remove, or at a minimum delay, this regulation from taking effect. Health care providers have done an outstanding job of keeping their patients and employees safe throughout the COVID-19 pandemic. Adding a burdensome regulation like the ETS proposes will not protect patients or employees.  Rather it will pull limited staff and financial resources in directions that could be better used providing health care to patients during the ongoing pandemic. Further, NRHA believes the rule is being implemented at an unnecessary point in the pandemic. Providers have had COVID-19 protocols in place for over 15 months. Adding new regulations from OSHA at this time is not needed for patients and employers to feel safe in the health care setting.  

NRHA encourages members to comment on this regulation if you believe it will be overly burdensome to comply with, especially given the tight timeline turnaround. OSHA released a subsequent message saying they have determined that no changes to the ETS are necessary at this time, so we believe comments expressing the need for removal, or delay, of the regulation will be important to OSHA’s decision-making process. NRHA will share our comments for the regulation in the coming days so you can read them as a guidepost in crafting your own comments.  

You can find the rule posted on Regulations.gov here. Additionally, OSHA has posted related summaries, fact sheets, and compliance assistance materials and tools hereComments are due to the Federal Register by July 21, 2021.