New Federal Provider Relief Funding Now Available 
Including for Behavioral Health Providers

In a busy week last week, the U.S. Department of Health and Human Services (HHS) announced the availability of $20 billion more in provider relief funding and another extension of the Public Health Emergency (PHE) for 90 more days to run until January 21st. Doing so will permit the continuation of a number of important emergency authorities, such as the broad expansion of Medicare and Medicaid-covered telehealth.

HHS's announcement about the availability of an additional $20 billion in relief funding for Jewish human service provider agencies specifically highlighted relief for behavioral health providers and providers that have already received relief payments. The new funding is intended to offset financial losses and changes in operating expenses due to COVID-19. In addition, some providers who were previously ineligible are invited to apply. HHS' application portal for this new round of funding is now open as of Monday, October 5, 2020. Applications are due by November 6, 2020.

In earlier distributions, HHS released over $100 billion in relief funding to providers. For eligible providers, this new funding (Phase 3) is intended to supplement the two percent of annual patient revenue for which providers were previously eligible. 

Significantly, HHS' announcement highlights the availability of designated funding for behavioral health providers who are addressing the surge in mental health and substance use needs exacerbated by the pandemic. The Administration's press release cites the findings of a recent Centers for Disease Control report that depression and anxiety rates are rising and notes that behavioral health providers are shouldering the burden of responding to this challenge. The release also publicly acknowledges the substantial investments in telehealth technologies behavioral health providers made to support their sudden and widespread pivot to this modality as traditional face-to-face counseling was restricted, as well as the fact that some Medicare or Medicaid behavioral health providers still have not received provider relief payments. To facilitate this designated funding, HHS curated a list of the nation's behavioral health providers eligible for funding, which includes, for example, mental health counselors, addiction counseling centers, and other behavioral health providers. This new distribution by HHS follows from earlier outreach to HHS by JFNA, NJHSA and many other mental health advocates alerting the Administration to the fact that the earlier relief distribution efforts were not reaching behavioral health providers.   

Eligible Providers
  • Providers that previously received, rejected, or accepted a provider relief fund payment.
  • Providers that already received payments greater than two percent of annual patient revenue may submit more information for an additional payment. 
  • Behavioral health providers, including those that previously received funding and new providers. 
  • Healthcare providers that began practicing January 1, 2020 through March 31, 2020, across all eligible provider types.  This includes Medicare, Medicaid, CHIP, dentists, assisted living facilities and behavioral health providers.
Payment Methodology - Apply Early

After ensuring that all eligible providers receive their two percent of annual patient revenue, HHS will provide supplemental relief payments with the remaining funds based on the following criteria:
  • The change in operating revenues from patient care between the first quarter of 2020 to the second quarter of 2020. 
  • The amount of expenses incurred related to COVID-19. 
  • Individual payments already received through provider relief fund distributions. 
Providers will receive one aggregate payment from these two payment considerations. To ensure payment, HHS is urging providers to submit their applications early so that their information can be verified and validated timely. This must be done before a payment can be made.

Application Deadline
  • October 5, 2020 through November 6, 2020.
  • HHS will host webinars to assist providers with the application process and their call center will be available to address additional questions.
Funding for this Phase 3 General Distribution was made possible through the CARES act and the Paycheck Protection Program and Health Care Enhancement Act, which allocated $175 billion in relief funds to hospitals and other healthcare providers. Learn more here.  

Please feel free to reach out to Elizabeth Cullen, Counsel for Health Policy, if you have any questions