Ryan White HIV/AIDS Program (RWHAP) recipients are prohibited from submitting claims for reimbursement for services provided to RWHAP clients to the COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program.
The FY 2020 CARES Act funding provided to Ryan White HIV/AIDS Program (RWHAP) recipients through RWHAP Part A should be used for preventing, preparing for, and responding to COVID-19, as needs evolve for clients of RWHAP recipients. The COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program—authorized by the Families First Coronavirus Response Act, Paycheck Protection Program and Health Care Enhancement Act, CARES Act, Coronavirus Response and Relief Supplemental Appropriations Act, and American Rescue Plan Act of 2021 and administered by HRSA—is not a state compensation program, an insurance policy, a federal or state health benefits program, or an entity that provides health services on a prepaid basis. As such, it does not trigger the payer of last resort provision codified in the RWHAP legislation. RWHAP providers should use their COVID-19 CARES Act funding specifically authorized for the RWHAP patient population, and are prohibited from accessing the Provider Relief Fund for these same services. For those RWHAP providers that provide services to a broad range of patients, claims may be submitted for services provided to non-RWHAP eligible clients.