FEDERAL FUNDING SOURCE
|H8E Grants||H8F Grants||Capital Improvement (C8E)||Provider Relief Fund (PRF)||Uninsured Claims Program||Paycheck Protection Program||FCC Telehealth Grants|
|Last updated 6/17/21-- see bright green|
|Other Names||ECT grants (Expanded Capacity for COVID-Testing)||American Rescue Plan Act (ARPA) operational grants|
ARPA Capital Improvement grants
|CARES Fund, or PRF (part of Public Health and Social Services Emergency Fund)||HRSA Reimbursement Program for Uninsured Patients (administered by UnitedHealth/ OptumPay)||Paycheck Protection Program||FCC Telehealth Grants|
|General Purpose (see details below)||Testing and testing-related activities||"to prevent, mitigate, and respond to COVID-19 and to enhance health care services and infrastructure" See list of official six purposes below at *||"for COVID-19 related capital needs and to construct new facilities, renovate and expand existing facilities, and purchase new equipment" Capital projects must cost at least $500,000. (These funds can NOT be combined with any funds under H8F.)||"to reimburse… eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus"||To reimburse provider on a patient-specific basis for the testing and treatment costs associated with caring for uninsured patients with suspected or actual COVID-19||Forgivable loans to incentivize small businesses to keep their workers on the payroll||"to support health care providers’ use of telehealth services in combating the COVID-19 pandemic"|
|Administered by||HRSA/ BPHC||HHS, through contract with United Health/ Optum Pay||HRSA, through contract with United Health/ Optum Pay||Small Business Administration||Federal Communication Commission (FCC)|
|In what law||Paycheck Protection Program and Health Care Enhancement Act (PPPHCEA)||American Rescue Plan Act (ARPA)||American Rescue Plan Act (ARPA)||Established in CARES ($100B); expanded in PPPHCEA ($75B)||The Families First and PPHCE Acts each appropriated $1 billion to reimburse providers for testing the uninsured; also, a portion of the Provider Relief Fund will be used for this purposes, including to reimburse for COVID-19 treatment costs for uninsured persons.||Created in CARES Act, expanded in Paycheck Protection Program and Health Care Enhancements Act (PPPHCEA)||CARES Act|
|Total Amount||$600 million||$6.076 billion to support 1,376 CHC grantees; TBD for Look-Alikes||Around $1 billion||$175B (as of mid-May), split into "pots" -- see below.||TBD. Will depend at least in part on claims submitted. It is possible that funds may run out before all claims are paid.||$670 billion ($349B in CARES; $321B added in PPPHCEA)||$200 million|
|Signed into law on||April 24, 2020||March 11, 2021||March 11, 2021||Mar. 27 (CARES) & Apr. 24 (PPPHCEA)||Varies (at least 3 laws involved)||Mar. 27 (CARES) updated Apr. 24 (PPPHCEA) and June 5 (PPP Flexibility Act)||March 27, 2020|
|ELIGIBLE RECIPIENTS||CHC grantees and LALs||CHC grantees and LALs||CHC grantees -- but not Look-Alikes||$50 billion shared among all health care providers nationally, distributed in two rounds (called "General Distribution")||$10 billion shared among rural hospitals, Rural Health Clinics, "rural" FQHCs||$20 billion to be shared among all providers who are still showing significant losses in income between 2019 and 2020, and a few newly-eligible provider types.||All health care providers nationally who incurred costs for treating uninsured patients.||Small businesses with up to 500 employees* per organization who can certify that “[c]urrent economic uncertainty makes this loan request necessary to support the[ir] ongoing operations.” (*Only the hospitality & food industries can count employees per site.)||Non-profit and public providers that fall into one of eight provider types. FQHCs are one of these provider types. Both rural and urban providers are eligible.|
|AWARDS TO CHCs||General Distibution||PRF funds for rural providers||"Phase 3" of General Distribution|
|Date awards were issued||Around May 7||April 1, 2021||Not yet awarded. CHCs will need to apply before receiving them.||First round ($30B total): Distributed April 10 (or soon after.) Second round ($20B total): Distributed on a rolling basis, starting April 24||Many around May 1, but some not till late May.||Close to half of the awards were made on 12/16/2020; the remaining awards were made through January 2021.||Providers could start submitting claims through HRSA portal on May 6; reimbursement will be sent starting on May 18.||The application window opened on April 3, and closed on April 16 when funds were exhausted. It reopened on April 27 after PPPHCEA provided more funding & will close June 30.||Varies. As of mid-May, the FCC has been making a few dozen awards per week.|
|How amounts determined||BPHC formula||HHS formula (in short, will total 2% of FQHC's 2018 net patient revenue)||HHS formula||Each applicant will receive funding to bring total Federal support provided up to 88% of their reported lost revenues and net change in expenses caused by the coronavirus pandemic in the first half of 2020||Depends on how many claims the CHC submits||The loan amount and the forgiveness amount are two separate calculations. Info on Loan Amount is directly below. Calculation of Forgiveness Amount is more complex, involving amounts spent on payroll and other eligible expenses, and any reductions in headcount and wages.||Depends on how much the CHC applied for|
|Formula for calculating award amount||$98,329 base, plus $15 per patient in 2019 UDS||Base value of $500,000 plus $125 per patient and $250 per uninsured patient (from 2019 UDS)|
$500,000 base plus $11 per patient.
|First $30B distributed based on provider's share of national Medicare fee-for-service revenues (called Phase One.). Remaining $20 billion (Phase 2) distributed so that the total from both rounds will be 2% of the provider's 2018 net patient revenue.||$103,253 per FQHC site.||Providers are reimbursed at Medicare fee schedule rates.||Loan Amount: Applicants can borrow 250% of their average monthly payroll expenses (subject to an annualized limit of $100K per employee) up to a total of $10 million. All loans capped at $10 million.||Each applicant can request up to $1 million. Funding covers 100% of costs for eligible services and devices. Grantees must purchase the covered devices and services themselves, and then invoice the FCC monthly to be reimbursed.|
|Notes||Bank deposits labelled something like "HHS stimulus relief. "||Definition of "rural" FQHCs||See memo available on NoddlePod for more info.||HRSA requires the use of unique diagnosis codes -- see "Eligible Claims & Coding" on the FAQ doc on the portal webpage. Tests for uninsured persons who are asymptomatic and/or whose results are negative ARE covered -- but only if the proper "Z code" is included on the claim.||There has been significant variation in how long FQHCs waited to have their applications funded, with those submitted through small local banks generally being funded faster.||FCC Order on COVID-19 Telehealth Program|
|Application required before funds provided?||Not for CHC grantees. Yes for Look-Alikes - NOLO published 5/18; applications due June 2||No||Yes||No||No||Yes. Applications due by 11/6.||Patient-specific claims must be submitted through portal - https://coviduninsuredclaim.linkhealth.com/||Yes. Both the Application for Funding and the Application for Forgiveness must be submitted through lenders, rather than directly to the SBA.||Yes -- the FCC is funding eligible applications on a first-come-first-served basis.|
|Notes||By May 31, 2021 CHCs must submit info to BPHC re: how they will use them. https://bphc.hrsa.gov/program-opportunities/american-rescue-plan/award-submission||Funds can be used for up to 5 discrete projects||Despite initial comments, applications submitted early did NOT receive preference for funding.||From an accounting perspective, these funds should be treated the same as reimbursement from other government or private insurers.||CHCs have generally had more success applying through small local banks than larger national ones.||PCAs and HCCNs can apply on behalf of multiple CHCs, as a "consortium."|
|TERMS & CONDITIONS||CHCs must approve the T&Cs for each PRF distribution that they received, even though the contents are the same each time. Thus, a FQHC that received two payments from the $50B General Distribution plus funding for being a rural FQHC would need to approve 3 sets of PRF T&Cs.||CHCs must approve both sets of T&Cs below:||No fees. Interest rate of 1%. No payments due until 10 months after the end of the 24-week covered period. Any amount that is not forgiven must be paid off within 5 years.||No official T&Cs yet available. However, the FCC order announcing the program provides details on expectations.|
T&Cs for first round ($30B) of $50B
|Rural PRF T&Cs||T&Cs for Testing Reimbursement||Initial Regulation||FCC Order|
T&Cs for second round ($20B) of $50B
|T&Cs for Treatment Reimbursement|
|Key T&Cs||Most are identical to standard HHS grant conditions (aka "Legislative Mandates) that grantees are already well familiar with-- e.g., funds may not be used for abortion, lobbying; also, limits on Executive pay. Also prohibits billing out-of-network patients more than in-network patients.||Uninsured persons may not be charged any copays or cost-sharing, for testing or treatment. Fees previously collected must be refunded. See BPHC FAQ on this topic.||To be eligible for a loan, must certify that “[c]urrent economic uncertainty makes this loan request necessary to support ongoing operations.” To be eligible for forgiveness, requirements include spending the funds on eligible expenses (see below) during the 8 weeks after receiving the loan. Reductions in headcount and wage reductions can reduce the amount forgiven. As of 6/3, Congress is considering extending the 8-week window.||Competitive bidding not required -- see para 31. FQHCs may use funds differently from what they proposed in their application , as long as the expenses meet the eligibility requirements -- see para. 17 of the FCC Order.|
|For more info||BPHC webpage on H8E grants||https://bphc.hrsa.gov/program-opportunities/american-rescue-plan||HHS FAQs on Provider Relief Fund||HHS Press Release on on first Phase 3 awards||https://coviduninsuredclaim.linkhealth.com/||SBA PPP website||FCC program webpage|
|KEY UPCOMING DEADLINES See Tab 2 for a list of deadlines in date order||April 10, 2021 (See note directly below)||July 14, 2021||June 24, 2021||The first progress report -- covering all PRF funds spent in CY2020 -- was originally due by 2/15/2021, but on 1/15/2021, HHS postponed the due date indefinitely. Second and final report -- covering any PRF funds spent in CY2021 - due by July 31, 2021. See https://www.hhs.gov/about/news/2021/01/15/hhs-announces-provider-relief-fund-reporting-update.html||Winter/ Spring 2021||Aug - Oct 2021 (at end of 10 month deferral following the completion of the 24 week covered period)||Monthly, and after project completion|
|What is due||Quarterly Progress Reports are required until all activities supported with the funds are completed and all funds are drawn down; e.g., CHCs that completed all activities and drawn down all funds related to all 3 awards (H8C, H8D, and H8E) prior to 1/1/21 will not be required to submit a report on 4/10/2021.||Progress Report||Application due in EHB/||PRF Reporting requirements published 6/11/2021 at https://www.hhs.gov/sites/default/files/provider-post-payment-notice-of-reporting-requirements-june-2021.pdf||Claims must be filed within 365 days of date of service. However, as funding could run out before all claims are paid, CHCs should submit claims promptly.||New application for loan forgiveness -- updated to reflect new law -- available at https://home.treasury.gov/news/press-releases/sm1036||Invoices must be submitted to the FCC monthly. After project completion, must report to FCC "on the effectiveness of the... funding on health outcomes, patient treatment, health care facility administration, and any other relevant aspects of the pandemic."|
|For more info||ECT Reporting Guidance||https://bphc.hrsa.gov/program-opportunities/american-rescue-plan||https://bphc.hrsa.gov/program-opportunities/american-rescue-plan/arp-capital-improvements||Portal for attesting to T&Cs||https://coviduninsuredclaim.linkhealth.com/claims-and-reimbursement.html||Article summarizing Interim Final Rules published late May. Additional rules expected.||Paragraphs 29, 30 , and 34. Details in final report TBD.|
|Progress Reports||While separate reporting is required for each funding grant, all reports should address: 1. An overall status update with percentage of activities completed.|
2. Narrative updates on the activities that have been completed, are in progress, and/or are planned, under the following applicable categories: Staff and patient safety; Testing; Maintaining or increasing health center capacity and staffing levels; Telehealth; Minor alteration/renovation activities (when applicable – only for H8D and H8E awards)
3. Changes to activities from what you submitted to HRSA in the initial post-award reporting requirement response.
4. Issues or barriers in the use of the funding and/or implementing the planned activities.
|TBD||Contents of report outlined on page 2 of T&Cs. While details still TBD, will require submission of "documents to substantiate that these funds were used for increased healthcare-related expenses or lost revenue attributable to coronavirus, and that those expenses or losses were not reimbursed from other sources and other sources were not obligated to reimburse them." For more info, see * at bottom of this column.||None.||No Progress Reports required. However, the SBA has stated that it will "review" all loans over $2 million both for compliance with requirements and to verify economic necsesity. Loans below $2 million may be reviewed for compliance, but not economic necessity.||No Progress Reports required|
|ELIGIBLE EXPENSES||Note that there are strict prohibitions on "double-dipping" -- meaning that no expense may be billed to more than one program (including your standard 330 grant.) See Tab 3 of this spreadsheet for an overview of double-dipping and rebudgeting.|
|Official purpose of funding, per statute and/ or Federal agency:||"to purchase, administer, and expand capacity for testing to monitor and suppress COVID-19. Funding may support a wide-range of testing and testing-related in-scope activities that may change as COVID-19 needs evolve within your community"||See * below for the 6 allowable uses of these funds.||"to reimburse… eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus". All PRF funds may be used for the same purposes, regardless of whether they were distributed from the first $30B, the next $20B, or the set-aside for rural providers.||"COVID-19 testing and testing-related visits for uninsured individuals, as well as treatment for uninsured individuals with a COVID-19 diagnosis"||"a direct incentive for small businesses to keep their workers on the payroll." Loans can be fully forgiven if at least 60% of the total is used for payroll costs, with the reaminder used for mortgage interest, rent, and utilities. With certain exceptions*, employers who lay off employers or reduce wages are ineligible for full forgivenes.||“to purchase telecommunications, information services, and connected devices to provide connected care services in response to the pandemic.” Also, the program “will only fund monitoring devices (e.g., pulse-ox, BP monitoring devices), that are themselves connected... not unconnected devices that patients can use at home and then share the results with their medical professional remotely.” FQHCs can use funds differently from what they proposed in their application -- see para. 17 of theFCC Order|
|Comments/ Strategies||This is the most restrictive of the HHS funding sources (other than the reimbursement for uninsured patients.) CHCs must be able to tie all uses of these funds directly to testing-related activities.||This is the only program that explicitly states that funds may be used to compensate for "lost revenues." Also, unlike with a grant application, CHCs are not required to proactively describe what costs will be covered with these funds, which increases flexibility. However, they will later need to submit documents demonstrating that they were used for allowable purposes. (See "Progress Reports" above.)||CHCs must apply proactively for these funds, which are limited to very specific expenses (testing and treatment costs for uninsured persons.) Also, funds may run out before all claims are paid. Therefore, CHCs should submit all appropriate claims ASAP, and ensure that costs reimbursed through this program are not billed to other Federal programs.||All CHCs should be able to get 100% of their PPP loans forgiven. To have 100% forgiven, at least 60% of funds must be used for payroll costs during the eligible period -- so CHCs should aim to allocate enough payroll costs here to maximize the amount forgiven. Reductions in headcount and wages will reduce the amount forgiven, subject to "safe harbors" described below.*||Funds may be used only for devices and services related to telehealth. However, within this framework, CHCs have significant flexibiilty -- the FCC explicitly allows funds to be used for expenses that differ from those proposed in the application, as long as they are eligible. (See para. 17 of Order.) Also, uses do not have to br directly tied to COVID-19 patients. (See para. 19)|
Dates for Allowable expenses
|First eligible date||Jan. 20, 2020||January 2020||January 1, 2020 (Per FAQ dated 6-2-20)||Feb. 4, 2020||The day the loan was received, or the start of following pay period||Unclear. Grantees must purchase items upfront and invoice FCC for reimbursement. Unclear if purchases made before award data are eligible.|
|Last eligible date||12 months from date of award||Sept. 30, 2022||UPDATED 5-10-21 - All funds must be expended by either 6/30/21 or 7/31/2021 (per FAQ dated 7-30-20). Clear answer coming ASAP Any funds not expended by that date must be returned to HHS.||TBD||24 weeks after the first eligible date, and not later than Dec. 31, 2020. (Previous limit was 8 weeks.)|
|Regular salary/ wages - no special circumstances||Yes, but only to the extent directly related to testing||Yes||Yes, if "attributable to the coronavirus".||No||YES - but each individual's payroll costs (excluding fringe benefits) is capped at an $100K annualized amount - roughly $46K total for any one employee||Only if directly relatable to the activities funded under the FCC grant.|
|Fringe, including health premiums & retirement contributions|
|Hazard pay||UPDATED 4-16: Yes, but for hazard pay/ bonuses, you must have P&Ps in place that address this type of pay, & document that you are following them.||No|
|Paid leave for exposed or vulnerable staff||No|
|Maintaining staffing levels, including among those unable to perform regular duties due to C-19||Yes, but only to the extent directly related to testing||Yes|
|Increasing capacity and staffing levels during the COVID emergency||Yes||Yes. Must be able to explain why the capacity increase is "attributable to the coronavirus."||YES - forgivable||Only if directly relatable to the activities funded under the FCC grant.|
|Individual salary amounts above $197,300||Total Federal Funds -- across ALL funding sources (both COVID-19, H80, and other) -- for any single individual may not exceed $197,300. Any salary above this amount must be paid with non-Federal funds.|
|Mortgage Principal||No||No*||No||Yes. Not necesary to show that is "attributable to the coronavirus" (See HHS FAQ from 6/2.)||No||Not eligible or forgivable||No|
|Mortgage Interest||YES - forgivable. Recommend billing as much of these costs as possible to PPP|
|Minor A&R||Yes, but only to the extent directly related to testing||Yes, but may not exceed $500,000 in total across all sites.||No -- These funds must be used for "major" projects -- meaning ones costing at least $500K.||Yes, if "attributable to the coronavirus"||Not eligible or forgivable|
|Purchase or upgrade EHR||No||Yes||"Costs related to EHR initiation, ongoing operations, & maintenance are NOT allowed.||Yes, if "attributable to the coronavirus"||No||Not eligible or forgivable||No|
|Support remote staff (e.g., laptops, training)||No|
|Enhance electronic tracking, data exchange, reporting, & billing||Only if you can directly relate it to testing|
|Equipment and Devices||Only if you can directly relate it to testing||Yes||Yes, if "attributable to the coronavirus"||No||Not eligible or forgivable||YES - Recommend billing all telehealth here first|
|Services (e.g., broadband)||No||YES - Recommend billing all telehealth here first|
|Testing and Treatment Expenses (exclusive of payroll & equipment. Includes PPP & other supplies.)|
|Testing-related expenses||Yes (including antibody & serological testing)||Yes||Yes, if "attributable to the coronavirus"||Yes -- to the extent that they are specific to an uninsured individual. Recommend submitting as many claims are appropriate, and doing so early.||Not eligible or forgivable||No|
|No||Not directly -- but (with BPHC approval) can be used to cover allowable costs that could not otherwise be sustained given the lost revenue. (May be easier to allocate lost revenues to PRF funds)||The Consolidated Appropriations Act enacted in late December ordered HHS to return to its original definition of "lost revenues", for purposes of determining appropriate uses of PRF funds in CY2020 (but not for CY2021.) This definition -- originally published in FAQs on June 19, 2020 -- reads as "any revenue that a health care provider lost due to coronavirus" calculated using "any reasonable method”. As a result, the definitions that HHS issued in Sept and Oct 2020 are no longer in effect. See here for more info: https://www.hhs.gov/sites/default/files/provider-post-payment-notice-of-reporting-requirements-january-2021.pdf||No||Not eligible or forgivable||No|
|Purchase of land||No||No.||No. (BPHC has stated this explicitly.)|
|Interest on non-mortgage debt obligations incurred before 2/15/2020||No||Unclear||Yes, if "attributable to the coronavirus"||No||IS an eligible use of fund, but is NOT forgiveable.||No|
|Expand enabling services||Yes||Not eligible or forgivable|
|General staff training|
|Community outreach and education|
|*Mortgage costs are incorporated into the indirect cost rate for many FQHCs; for others, billing mortage cost to a Federal grant would create a Federal interest in the property, and therefore is not recommended.||* Per the BPHC ARPA/ H8F webpage -- https://bphc.hrsa.gov/program-opportunities/american-rescue-plan/award-submission -- this funding may be used for the following six purposes: 1. Plan, prepare for, promote, distribute, administer, and track COVID–19 vaccines, and to carry out other vaccine-related activities. 2. Detect, diagnose, trace, and monitor COVID–19 infections and related activities necessary to mitigate the spread of COVID–19, including activities related to, and equipment or supplies purchased for, testing, contact tracing, surveillance, mitigation, and treatment of COVID-19. 3. Purchase equipment and supplies to conduct mobile testing or vaccinations for COVID-19, purchase and maintain mobile vehicles and equipment to conduct such testing or vaccinations, and hire and train laboratory personnel and other staff to conduct such mobile testing or vaccinations, particularly in medically underserved areas. 4. Establish, expand, and sustain the health care workforce to prevent, prepare for, and respond to COVID–19, and to carry out other health workforce-related activities. 5. Modify, enhance, and expand health care services and infrastructure. 6. Conduct community outreach and education activities related to COVID–19.|| Some highlights of the PRF reporting requirements dated 1-15-2021:|
• PRF funds must be spent to cover unreimbursed COVID-related expenses before they can be allocated to lost revenues.
• The definition of “COVID-related expenses” continues to be broad, and can include mortgage payments, HIT systems, utilities, etc. As in previous version of the reporting requirements, providers receiving over $500,000 in PRF funding must report their expenses in greater detail than those receiving less than $500,000.
• Definition of “lost revenues”:
o For CY 2020, providers can define “lost revenues” in one of three ways:
1. Difference between CY2019 and CY2020 actual patient care revenue
2. Difference between 2020 budgeted and 2020 actual patient care revenue. Providers who use this approach must provide evidence and attestation that their budgeted revenue was determined prior to March 27, 2020.
3. Using “any reasonable method of estimating revenue”. Providers using this approach must describe their methodology, explain why it is reasonable, and demonstrate that the lost revenues were due to COVID. HHS explicitly states that providers using this approach are more likely to be audited.
o For CY 2021, providers are not permitted to calculate lost revenues using “any reasonable method” Rather Jan-June 2021 actual revenue must be compared to 2019 actual revenue or 2020 budgeted revenue for the same 6-month period.
• As in previous version of the reporting requirements, providers receiving over $500,000 in PRF funding must report their expenses in greater detail than those receiving less than $500,000.
• If a provider earned interest in PRF payments, they must provide information on that interest and how it was used.
|* Per law passed in early June, generally, borrowers who reduced wages levels or lay off/ furlough employees after February 15, 2020 are not eligible to have their full PPP loan forgiven. However, if they meet any of these three requirements, they qualify for a “safe harbor” and can have 100% of their loan forgiven: |
1. Borrower restores employment and wage levels to their 2/15/2020 levels by December 31, 2020. (The original end date was June 30; it was extended in early June.)
2. Borrower is both unable to rehire its former employees, or to hire similarly qualified employees for unfilled positions by 12/31/20.
3. Borrower is unable to return to its pre-February 15, 2020, level of business activity due to COVID-19-related worker or customer safety requirements.