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The American Rescue Plan Act of 2021

Weekly PRF Update

There still have been no updates from HHS for reporting on PRF payments for the 2020 calendar year, but the passage of the American Rescue Plan (ARP) Act of 2021 offered new details on the requirements for a new round of PRF payments.

Section 1150C appropriates another $8.5B to the Provider Relief Fund. Below we have the details of who is eligible for these payments and what we can glean from this law for your current reporting cycle.

Weekly Insights: The American Rescue Plan Act

$8.5B in PRF Payments Details:

  • It is an application-based system and these will not be automatic payments distributed by HHS.
  • Calculation of a provider’s payment will be determine at a later time by the Secretary of HHS.
  • This funding is only eligible to providers located in a rural area or a provider who serves rural patients within a metropolitan statistical area with a population <500,000.
  • Payments are still for healthcare providers and their healthcare related COVID-19 expenses and Lost Revenues.
  • Lost Revenues still defers to the June 2020 FAQ from HHS which allows a comparison to actual and budgeted revenue. The budget must have been established and approved prior to March 27, 2020.
  • COVID-19 healthcare related expenses definitions have not changed but the law provided the following examples:
    • Building or construction of temporary structures
    • Purchase of medical supplies and equipment including PPE and testing supplies
    • Providing increased workforce and training – including maintaining staff, obtaining additional staff, or both
    • Operation of an emergency operation center
    • Retrofitting a facility, providing for surge capacity
    • Other expenses determined appropriate by the Secretary of HHS

Key Takeaways from the American Rescue Plan Act:

  1. The population is limited. Only rural providers will be eligible for additional payments from the Provider Relief Fund.
  2. The definition of lost revenues still defers to using budgeted revenue as approved by March 27, 2020. Without the administrative rules at this time, it appears that calendar year COVID-19 expenses and Lost Revenues will still be used to support these additional payments, on top of any payments you may have already received. Again, for many rural providers, this may limit how much of any additional payments you can keep.

As in past messages, we encourage you to continue working on identifying all expenses related to COVID-19 that were used to plan, prepare for, and respond to coronavirus while we await the start of reporting.

Additionally, when the Secretary of HHS releases information for the next round of applications we recommend you apply as the administrative rules around this next round of PRF payments may allow for additional time periods for COVID-19 expenses and lost revenues.

Even if you don’t believe you can support your current PRF payments, we would encourage you to apply as the rules change often and, to date, we have had very little input from the current administration as to how they will oversee reporting.

To Download a PDF version of this blog post, click here. If you have any questions about the American Rescue Plan Act and PRF payments, contact your local Blue & Co, Advisor or Michael Alessandrini.

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