On August 11, 2020, the U.S. Department of Health and Human Services (HHS) updated the terminology describing the various allocations of the CARES Act Funding through HHS’s Provider Relief Fund, in addition to updating the eligibility criteria for the Medicaid Tranche, which is now referred to as “Phase 2 – General Distribution.”
Terminology
HHS has renamed the first two General Distributions of the CARES Act Funding through the Provider Relief fund as “Phase 1 – General Distribution.” HHS also renamed the Medicaid Tranche as “Phase 2 – General Distribution.”
Phase 2 – General Distribution Eligibility
As for eligibility, HHS initially indicated that providers who received a Phase 1 – General Distribution were not eligible for a Phase 2 – General Distribution (previously known as the Medicaid Tranche). HHS has now reversed its position in the following FAQ document, stating:
“Medicaid and CHIP Providers who have received a payment under Phase 1 of the General Distribution are no longer prohibited from submitting an application under Phase 2 of the General Distribution. Providers who received a previous Phase 1 – General Distribution payment are eligible to apply and, if they have not yet received a payment that is approximately 2% of annual revenue from patient care, may receive additional funds (see pages 22-23).”
Accordingly, Aged & Disabled Waiver assisted living providers that did not apply for the Medicaid Tranche because they are under a TIN that received a General Distribution are now encouraged to apply to the Medicaid Tranche / Phase 2 – General Distribution, as long as the Aged & Disabled Waiver assisted living provider did already receive 2% of revenue from patient care under the Phase 1 – General Distribution.
Applicants should use the Provider Relief Fund Application and Attestation Portal to apply for funds. Eligible provider musts submit their TIN for validation by August 28, 2020 to apply for Phase 2 – General Distribution funds. Payments received as part of the Phase 1 – General Distribution will be taken into account when determining payment amounts for the Phase 2 – General Distribution. More information on how to apply can be found in IHCA/INCAL’s summary here.
Change of Ownership (CHOW) Update
The Phase 2 – General Distribution web portal for Medicaid, CHOW, and Phase 1 – General Distribution awardees who missed the June 3rd deadline for additional funding is up but still is not active. We will provide information as soon as the portal is operational.