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Rural Health Clinic COVID-19 Testing (RHCCT) Program

The period of availability for the Rural Health Clinic Testing (RHCCT) Program was January 27, 2020 through December 31, 2021.

The RHCCT Program provided COVID-19 testing and expanded access to testing in rural communities as mandated by Public Law 116-139, the Paycheck Protection Program and Health Care Enhancement Act.

The $225 million awarded to the Rural Health Clinic (RHC) COVID-19 Testing Program was specifically for the implementation and operation of COVID-19 testing and testing-related expenses in RHCs.

Eligible RHCs received a flat payment amount of $49,461.42.

RHC COVID-19 Testing Program Terms and Conditions (PDF - 224 KB)

Important Dates

Rural Health Clinic COVID-19 Testing Program

Implemented under the Paycheck Protection Program and Health Care Enhancement Act of 2020 (Public Law 116-139)

Date Details
January 27, 2020 RHCs funded under the RHC COVID-19 Testing Program could apply RHC COVID-19 Testing Program funds to allowable expenses incurred after the declaration of the HHS Public Health Emergency (January 27, 2020).
May 2020 $49,461.42 HHS payment distribution.
November 2020 Registration and reporting due.
Mandatory monthly reporting must be submitted through the RHC COVID-19 Reporting Portal.

RHCs that received funding in distributions occurring after May 2020 (e.g., December 2020) were required to report testing data starting with the month RHC COVID-19 Testing Program funds were received (e.g., December 2020). RHCs that received funding after May 2020 could voluntarily choose to report their testing data prior to the receipt of funds.
December 2020 $49.461.42 HHS payment distribution (for RHCs not funded in May 2020).
December 31, 2021 Final expenditure date for RHC COVID-19 Testing Program funds.
January 31, 2022 Final reporting date for the RHC COVID-19 Testing Program.

Allowable Expenses

RHCs funded under the RHC COVID-19 Testing Program may apply any of the payments to COVID-19 testing and COVID-19 testing-related expenses.

COVID-19 Testing Expenses

COVID-19 testing described in the RHC COVID-19 Testing Program Terms and Conditions (PDF - 224 KB) includes, but is not limited to:

Viral tests to diagnose active COVID-19 infections

  • A viral test checks specimens from your nose or your mouth to find out if you are currently infected with the virus that causes COVID-19. Two types of viral tests are uses: nucleic acid amplification tests (NAATs) and antigen tests.1
  • Viral tests can also be used as screening tests to reduce transmission of SARS-CoV-2 by identifying infected (symptomatic and exposed) persons who need to isolate from others.
  • Viral tests can be performed in the following settings including, but are not limited to:
    • Laboratory (complete laboratory and/or partial laboratory cycle (i.e., phases))
    • Testing site (on-site and/or off-site/third-party COVID-19 testing with active RHC involvement in the administration and oversight)
    • At home or anywhere else (prescription and/or non-prescription (i.e., home collection, direct-to-consumer, over-the-counter)). 2, 3

1 Centers for Disease Control. (2021).

2 U.S. Food and Drug Administration. (2021).

3 U.S. Department of Health and Human Services, Office of the Inspector General. (2021).

Antibody testing (serology) tests to diagnose past COVID-19 infections

  • Antibody or serology tests look for antibodies in your blood to determine if you had a past infection with the virus that causes COVID-19.
  • Antibody tests should not be used to diagnose a current infection with the virus that causes COVID-19, except in instances in which viral testing is delayed.
  • An antibody test may not show if you have a current infection because it can take 1-3 weeks after the infection for your body to make antibodies.4

4 Centers for Disease Control. (2021).

Other tests that the Secretary and/or Centers for Disease Control and Prevention determines appropriate in guidance

COVID-19 Testing-Related Expenses

Related testing expenses are described in the RHC COVID-19 Testing Program Terms and Conditions (PDF - 224 KB). The RHC must demonstrate that the related expense complies with all federal cost principles and is directly and reasonably related to the provision of COVID-19 testing activities. The related expense must be appropriate given relevant clinical and public health guidance. Related expenses include, but are not limited to:

Supplies to provide testing

Supplies to provide COVID-19 testing include, but are not limited to:

  • Test kits
  • Swabs
  • Storage (e.g., refrigerator, freezer, temperature-controlled cabinet)
  • Storage unit door safeguards (e.g., self-closing door hinges, door alarms, door locks)
  • Sharps disposal containers
  • Temperature monitoring equipment

Personal protective equipment (PPE)

Personal protective equipment, commonly referred to as "PPE", includes, but is not limited to:

  • N95 and other respirators
  • Facemasks
  • Eye protection
  • Gowns
  • Gloves

Workforce

  • Planning for implementation of a COVID-19 testing program
  • Training providers and staff on COVID-19 testing procedures
  • Hiring providers and staff to carry out COVID-19 testing procedures
  • Reporting data to HHS on COVID-19 testing activities
  • Expenses to secure and maintain adequate personnel to carry out COVID-19 testing if the activity generating the expense and/or the expenses were necessary to secure and maintain adequate personnel, such as:
    • Offering hiring bonuses and retention payments
    • Overtime pay
    • Mental health and stress management resources
    • Other fringe benefits
    • Childcare
    • Transportation
    • Temporary housing

Health care setting/facility

  • Building or construction of temporary structures
  • Leasing of properties
  • Retrofitting facilities as necessary to support COVID-19 testing

Unallowable Expenses

RHCCT Program funds may NOT be used for direct provider-to-patient vaccine administration (i.e., shot-in-arm).

The following HRSA programs covered the cost of vaccine administration:

Insurance & Reimbursement

RHC COVID-19 Testing Program

RHCs could apply funds to the remaining expenses or indirect costs attributable to COVID-19 testing, mitigation, and testing and mitigation related expenses (i.e., overhead costs) after netting the other funds received or obligated to be received which offset those expenses. The RHC COVID-19 Testing Program permitted reimbursement of marginal increased expenses related to COVID-19 testing and testing-related expenses.

HRSA encouraged the use of RHC COVID-19 Testing Program funds to cover remaining expenses or indirect costs (i.e., overhead costs) so that providers could respond to the coronavirus public health emergency by maintaining health care delivery capacity.

  • RHCs could use any reasonable method of estimating the expenses or indirect costs (i.e., overhead costs) attributable to COVID-19 testing and testing-related expenses that are not covered by other payments.
  • RHCs should maintain appropriate records and cost documentation to support these estimates.

RHCs could use funds for:

  • Testing-related activities not reimbursable by insurance coverage
  • Insured patients if the payment received for the COVID-19 test does not fully reimburse the cost
  • Upfront purchase of supplies necessary to implement and operate a testing program, such as test kits, swabs, and personal protective equipment (PPE)
  • Other startup costs needed to implement a testing program including, but not limited to, retrofitting facilities or hiring staff to carry out COVID-19 testing

RHCs could NOT use funds to:

  • Reimburse expenses or losses that have been reimbursed from other Provider Relief Fund payments or from the COVID-19 Uninsured Program (i.e., you may not reimburse expenses more than once).
  • Reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. Other sources of reimbursement include:
    • Insurance providers
    • Medicare
    • Medicaid
    • Other payers (e.g., workers compensation insurance or employer sponsored insurance)

Reporting

Data Reporting: Who, What, When, Where, Why, How

WHO: Funded TIN organizations.
WHAT:

Basic information, including:

  • Number of and location of testing sites (active and inactive);
  • Information on the use of funds;
  • Total number of tests conducted; and
  • Number of COVID-19 positive tests.
  • At-home COVID-19 tests (optional).
WHEN: Required reporting monthly for the duration of the reporting period.5 See important dates for specific program details.
WHERE: TIN organizations reported data on the RHC COVID-19 Reporting Portal.
WHY: To monitor and assess the program.5
HOW: HRSA funded the National Association of Rural Health Clinics (NARHC) to provide technical assistance to RHCs on the RHC COVID-19 Testing Program. As part of the cooperative agreement, NARHC developed the RHC COVID-19 Reporting Portal. If you have additional questions, you may email RHCcovidreporting@narhc.org.

5 Per the Terms and Conditions (PDF - 224 KB). HRSA intends to use this information to evaluate the effectiveness of the program at an aggregate level. The reporting requirement does not include any personally identifiable, patient-level information.

Data Reporting

RHCs (or their TIN organizations) were not required to do COVID-19 testing. Zero was an allowable entry on the month-by-month reporting page of the RHC COVID-19 Reporting Portal; however:

  • The RHC COVID-19 Testing Program funds must be used for COVID-19 testing or COVID-19 related expenses per the Terms and Conditions (PDF - 224 KB).
  • The RHC COVID-19 Testing and Mitigation Program funds must be used for COVID-19 testing and mitigation, or COVID-19 testing and mitigation related expenses per the Terms and Conditions (PDF - 174 KB).

RHC COVID-19 Testing Program reporting was mandatory for all TIN organizations that accepted corresponding program funds and did not replace any other reporting requirements that RHC organizations had with respect to COVID-19, such as those required for public health surveillance purposes and the Provider Relief Fund.

TIN organizations that accepted RHC COVID-19 Testing Program funding were required to continue reporting on the RHC COVID-19 Reporting Portal monthly for the RHCCT program, even after the funding was fully spent, until January 31, 2022. 

RHCs that received RHC COVID-19 Testing Program funding in distributions occurring after May 2020 (e.g., December 2020) were required to report testing data from the month RHC COVID-19 Testing Program funds were received (e.g., December 2020) until the end of the RHC COVID-19 Testing Program reporting period (January 2022). RHCs that received funding after May 2020 could voluntarily choose to report their testing data prior to the receipt of funds.

RHC COVID-19 Payment Process

Payment

  • RHC COVID-19 Testing Program funds were distributed to the banking account information associated with the organization’s billing TIN, based on the organization’s number of eligible RHC sites.
  • TIN organizations receiving payment that own and operate more than one RHC site could choose to distribute funds equally to RHC sites or pool-funds to achieve program goals in their local communities and RHC service areas.
  • RHC COVID-19 Testing Program were dispersed electronically to the bank account associated with the billing TIN organization.
  • TIN organizations received a paper check if HRSA did not have an associated bank routing number.
  • TIN organizations received $49,461.42 times the number of RHCs they operate.
  • Automatic payments were sent via Optum Bank with payment description “COVID*RuralHealthTestingPmt*HHS.GOV” or “COVID*ARPAct*RHCCTMPmt*HHS.GOV”.

Attestation

  • TIN organizations were required to complete the attestation process within 45 days of receipt of RHC COVID-19 Testing Program payment via ACH.
  • TIN organizations that retained RHC COVID-19 Testing Program payment for at least 45 days after receipt of RHC COVID-19 Testing Program payment via ACH or 60 days after check payment without contacting HHS regarding remittance of the funds were deemed to have accepted the Terms and Conditions (PDF - 224 KB).
  • A public list of TIN organizations and their payments is available on TAGGS6 once providers attest to receiving the money and agree to the Terms and Conditions. Providers that retained the funds past 45 days of receipt of RHC COVID-19 Testing Program payment, but did not attest, were included in the public release of providers and payments.

6 TAGGS includes current total amounts attested to by providers from each of the Provider Relief Fund distributions, including the General Distribution and Targeted Distributions.

Return Payment

Change of Ownership

The RHC COVID-19 Testing Program followed the Provider Relief Fund guidance. Please reference Ownership Structures and Financial Relationships in the CARES Act Provider Relief Fund Frequently Asked Questions (PDF - 520 KB).

Closeout Process

Period of Availability

  • RHCs funded under RHCCT Program could apply RHCCT Program funds to allowable expenses incurred after the declaration of the HHS Public Health Emergency (January 27, 2020).
  • RHCCT Program funds were required to be expended no later than December 31, 2021.

RHC COVID-19 Reporting Portal TIN Self-Certification

  • RHCs were required to complete final RHC Testing Reporting by January 31, 2022. RHCs could self-certify they spent all RHCCT Program funds in the period of availability or returned the full or partial remaining RHCCT Program funds to HHS.  Available self-certification selections included the following choices:
    • Fully Spent: TIN spent all of the funds or can identify allowable, otherwise unreimbursed incurred expenses for the entire RHCCT Program payment of $49,461.42 per RHC between January 27, 2020 and December 31, 2021.
    • Partially spent and completed partial return: TIN did not spend all of the funds or identify allowable, otherwise unreimbursed incurred expenses for the entire RHCCT Program payment of $49,461.42 per RHC between January 27, 2020 and December 31, 2021, and completed the partial return process for the remaining amount of funds.
    • Fully Returned: TIN completed the full return process for the RHCCT Program payment of $49,461.42 per RHC.
    • Funds remaining and have not completed full or partial return: TIN did not spend all of the funds or identify allowable, otherwise unreimbursed incurred expenses for the entire RHCCT Program payment of $49,461.42 per RHC between January 27, 2020 and December 31, 2021, and will complete the full or partial return process by March 2, 2022 (PDF - 706 KB).
    • Not applicable: TIN did not receive the RHC COVID-19 Testing Program payment of $49,461.42 and only received the RHC COVID-19 Testing and Mitigation Program payment of $100,000 per RHC.
  • Provider received “Closeout 2021 Form Submitted” email from “Rural Health Clinic COVID-19 Testing Report (RHC CTR) RHCcovidreporting@narhc.org with the provider’s submitted response.  

Resources

  • NARHC video walk through  of how to complete reporting requirements and closeout RHC reporting responsibilities for the RHC COVID-19 Testing (RHCCT) Program.

Archive: RHC COVID-19 Testing Resources

  • Program FAQs (PDF) Upcoming

Contact

  • For questions about the RHC COVID-19 Testing or Testing and Mitigation Programs, email RHCCOVID-19Testing@hrsa.gov.
  • For the most up to date information on the Rural Health Clinic COVID-19 Testing and Mitigation Program, visit the RHCCTM Program webpage.
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