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Provider Relief Fund Introduces Phase 3 General Distribution

At the beginning of the 2019 Novel Coronavirus (“COVID-19”) pandemic, Congress created the Provider Relief Fund (“PRF”) through the CARES Act in order to help providers who were financially impacted by COVID-19. In total, Congress approved $175 million for the PRF, to be distributed by the Department of Health and Human Services (“HHS”). Up until October 1, 2020, there were two phases for general funding, and multiple targeted allocations. The Phase 1 General Distribution allocated $30 billion to eligible providers, and the Phase 2 General Distribution allocated $20 billion to eligible providers. In addition to those general distribution, HHS also provided several targeted allocations, including to areas which were highly impacted by COVID-19, rural healthcare providers, and skilled nursing facilities

On October 1, 2020, HHS announced it would be allocating an additional $20 billion as its Phase 3 General Distribution. This Phase 3 General Distribution is intended for providers who were either excluded from the initial two phases, or who were eligible under the first two phases but require additional funding to cover ongoing financial losses accrued during the pandemic. The application period for this funding opened on October 5, 2020 and will end on November 6, 2020. HHS urges providers to apply as soon as possible. The applications are accepted on a rolling basis, so HHS asks that providers not apply the last day or week that the application period is open.

The following providers are eligible for Phase 3 General Distribution funding: (1) Providers who have previously received, rejected or accepted a General Distribution PRF payment; (2) behavioral health providers, including those that have previously received funding; and (3) healthcare providers that began practicing January 1, 2020 through March 31, 2020. All providers who receive payments must attest to receiving the payment and accept the associated Terms and Conditions.

The following criteria will be considered when HHS is making payment determinations: (1) Whether the provider has previously received a PRF payment equal to 2% of patient care revenue; (2) any change in operating revenues from patient care; (3) any change in operating expenses from patient care; and (4) any payment already received through prior PRF distributions that are under 2% of patient care revenue.

As noted above, behavioral health providers are now highly encouraged to apply. Although some were eligible for earlier general distributions, HHS has made it a point to include all behavioral health providers as eligible providers in this Phase 3 General Distribution. As the COVID-19 pandemic has progressed, prevalence of symptoms of anxiety have increased from 8.1% in 2019 to 25.5% in 2020, and prevalence of symptoms of depressive disorder grew from 6.5% in 2019 to 24.3% in 2020. As a result, many behavioral health providers had to adopt new telehealth technologies to provide patient care—which requires a copious amount of funding. This distribution is seeking to support all these providers.

For over 35 years, Wachler & Associates has represented healthcare providers and suppliers nationwide in a variety of health law matters. If you or your healthcare entity has any questions pertaining to Provider Relief Fund reporting, audits, or healthcare compliance, please contact an experienced healthcare attorney at 248-544-0888 or

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