On October 22, 2020, HHS updated its reporting guidance to revise the methodology for calculating lost revenue and expanded the eligibility requirements for the Phase 3 distribution.
Lost revenue calculation
On September 19, 2020, HHS stated that lost revenue would be calculated as the negative change in year-over-year net operating income from patient care related sources. After concerns were voiced from stakeholders and members of Congress, HHS decided to change how lost revenue is calculated to increase flexibility for providers. According to the October 22, 2020 Final Reporting Data Elements, after reimbursing healthcare related expenses attributable to coronavirus that were unreimbursed by other sources, providers may use remaining funds to cover any lost revenue, measured as a negative change in year-over-year actual revenue from patient care related sources.
Phase 3 eligibility
On October 22, 2020, HHS expanded the eligibility for the Phase 3 General Distribution to include the following provider types regardless of whether they accept Medicaid or Medicare:
- Behavioral Health Providers
- Allopathic & Osteopathic Physicians
- Dental Providers
- Assisted Living Facilities
- Nursing Service and Related Providers
- Hospice Providers
- Respiratory, Developmental, Rehabilitative and Restorative Service Providers
- Emergency Medical Service Providers
- Hospital Units
- Residential Treatment Facilities
- Ambulatory Health Care Facilities
- Eye and Vision Services Providers
- Physician Assistants & Advanced Practice Nursing Providers
- Nursing & Custodial Care Facilities
- Podiatric Medicine & Surgery Service Providers
For a detailed description of all eligible Phase 3 General Distribution provider types, visit the PRF website.
We note that this blog updates our blog posted earlier this week on these topics.
Nicole Jobe is a member of Thompson Coburn’s Health Care group.