COVID-19 & Rural Health Clinics
**NARHC will update this page with additional resources throughout the COVID-19 Pandemic**
Rural Health Clinic Testing Fund
Beginning on May 20th, all rural health clinics received just under $50,000 for COVID-19 testing. The following links to the terms and conditions and the FAQ will provide you some guidance on how to spend this money. We understand that there are some important questions (such as how to treat this money on the RHC cost report) that are not yet answered, and we will update this space when we learn more.
The IRS did clarify on July 6th that provider relief fund money would count as gross income for tax filing purposes in an FAQ. However, tax exempt organizations would still be exempt. The RHC testing fund is technically different than the provider relief fund but it would still not qualify as a qualified disaster relief payment under section 139.
COVID-19 RHC testing terms and conditions: https://www.hhs.gov/sites/default/files/terms-and-conditions-rural-testing-relief-fund.pdf
Covid-19 RHC testing fund Health Resources and Services Administration (HRSA) FAQ: https://www.hrsa.gov/rural-health/coronavirus/frequently-asked-questions
Covid-19 RHC testing fund webinars: https://www.narhc.org/narhc/TA_Webinars1.asp
RHC COVID-19 Testing Fund MANDATORY Reporting Tool
- May 2020 through September 2020 reporting must be completed no later than the end of October 2020.
- October 2020 reporting must be completed before the end of November 2020.
- November 2020 reporting must be completed before the end of December 2020.
Provider Relief Fund
RHCs have received multiple tranches or allocations of money from the federal government to help with COVID-19. It is important for RHCs to understand why they received the money they did, and what strings may be attached to each allocation.
RHC-Relevant Allocations Table
Details on all provider relief fund allocations can be found at the HHS website: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/index.html
Medicare telehealth policy has shifted dramatically for the entire healthcare industry in response to COVID-19. Rural health clinic telehealth policy has also shifted significantly, but in different ways than fee-for-service providers.
The following chart breaks down the types of telehealth services RHC can bill for and how to bill for them.
All RHCs billing for telehealth should review the MLN Matters document: New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE) ~ https://www.cms.gov/files/document/se20016.pdf
Public Health Emergency Duration
The Secretary of Health and Human Service posts their Public Health Emergency Declarations here: https://www.phe.gov/emergency/news/healthactions/phe/Pages/default.aspx
The last declaration was made effective on April 26th and will need to be renewed after 90 days. It is our full expectation that Health and Human Services Secretary Alex Azar will renew this declaration before the expiration.
Commercial payers may issue their own policies with their own timelines that may or may not depend on the federal government’s declaration of a public health emergency.