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Coronavirus Disease (COVID-19) Frequently Asked Questions – Federal Office of Rural Health Policy

Updated: 11/4/2020

We know that many of HRSA’s rural health program recipients and stakeholders are concerned about coronavirus disease 2019 (COVID-19) and its impact on your programs and your communities. We encourage you to be proactive in your emergency preparedness planning and to coordinate with partners at the state and local level in emergency response.

Online Resources for Updated Information

  • CDC Updates on the Coronavirus. The Centers for Disease Control and Prevention (CDC) provides daily updates on the Coronavirus with guidance for health providers and local public health officials.
  • Information for HRSA Grant Programs. Frequently asked questions for multiple programs including Health Centers, National Health Service Corp, 340B Drug Pricing, and other programs.
  • Rural Response to Coronavirus Disease 2019 HRSA Exit Disclaimer. The Rural Health Information Hub has created a guide to help you learn about activities underway to address COVID-19.

Please continue to check this page for updates and contact your Project Officer directly with any questions not addressed below.

To subscribe to FORHP’s weekly newsletter, sign up for Rural Health Updates through HRSA Email Subscriptions HRSA Exit Disclaimer.

We have organized the answers on this page into the following categories:

Rural Health Clinic COVID-19 Testing Program

General

How does the $225 million in Rural Health Clinic COVID-19 Testing Program differ from the recent $10 billion CARES Act Provider Relief Fund targeted rural distribution funding? (Updated: 10/28/2020)

The $225 million for the Rural Health Clinic (RHC) COVID-19 Testing Program is specifically for the implementation and operation of COVID-19 testing and testing related expenses in Rural Health Clinics. Under this distribution, all RHCs listed in either the Centers for Medicare and Medicaid (CMS) Provider of Service file (March 2020) or the CMS Survey & Certification's Quality, Certification and Oversight Reports (QCOR) before May 7, 2020 received a flat payment amount of $49,461.42.

The previous $10 billion CARES Act Provider Relief Fund targeted rural distribution allocated $10 billion for RHCs, rural acute care general hospitals, Critical Access Hospitals (CAHs), and Community Health Center sites located in rural areas to assist in addressing the effects of the COVID-19 pandemic beyond testing. Independent RHCs received a minimum base payment of $100,000 per clinic site plus a percent of their annual expenses, if applicable.

Where are the Rural Health Clinic COVID-19 Testing Program Terms and Conditions located? (Added: 7/16/2020)

Rural Testing Relief Fund Payment Terms and Conditions (PDF - 223 KB)

Testing Criteria & Allowable Use of Funds

What are permissible expenses under the $225 million Rural Health Clinic COVID-19 Testing Program payment? (Added: 5/20/2020)

Rural Health Clinic COVID-19 Testing Program funding may be used for COVID-19 testing and related expenses. As set forth in the Terms and Conditions (PDF - 223 KB), examples of related expenses include, but are not limited to, planning for implementation of a COVID-19 testing program, procuring supplies to provide testing, training providers and staff on COVID-19 testing procedures, and reporting data to HHS on COVID-19 testing activities. Further, the Rural Health Clinic COVID-19 Testing Program funds may be used for building or construction of temporary structures, leasing of properties, and retrofitting facilities as necessary to support COVID-19 testing.

How do RHCs determine if an expense meets the criteria of an allowable use of funds under the Rural Health Clinic COVID-19 Testing Program? (Added: 7/16/2020)

Funding should assist RHCs expand the range of testing and testing-related activities to best address the needs of their local communities. This includes both direct costs of COVID-19 testing and other related expenses. Related expenses are described in the Terms and Conditions (PDF - 223 KB). The RHC must demonstrate that the related expense is directly and reasonably related to the provision of COVID-19 testing services. The related expense must be appropriate given relevant clinical and public health guidance.

For example, the RHC may seek to retrofit the RHC facility to provide space for COVID-19 testing separated from the main clinic area for infection control purposes. However, a questionable use would be applying funds under this program to support a facility expansion planned prior to the COVID-19 pandemic. This may be allowable, but only if the RHC can demonstrate how it uses the expanded space to accommodate COVID-19 testing services in manner consistent with clinical/public health guidelines and community needs, and that other funds were not already obligated for this specific purpose.

Is COVID-19 antibody testing (serology) an allowable use of RHC COVID-19 Testing Program funds? (Added: 7/16/2020)

Yes. Allowable COVID-19 testing includes tests to diagnose active COVID-19 infections and antibody tests to detect past history of SARS-CoV-2, the virus that causes COVID-19.

The CDC released interim guidelines for COVID-19 antibody testing in clinical and public health settings. Different types of assays can be used to determine different aspects of immune response and functionality of antibodies. The tests can be broadly classified to detect either binding or neutralizing antibodies. For more information on both test types, please visit the CDC's Interim Guidelines for COVID-19 Antibody Testing and the FDA's Coronavirus Testing Basics.

Does COVID-19 testing include specimen collection? (Updated: 10/28/2020)

COVID-19 testing for the purposes of the RHC Testing Program is intended to include testing and testing-related services. The collection of specimens is an allowable testing cost.

Does the RHC need to conduct the full testing process to be eligible? (Updated: 10/28/2020)

The RHC does not have to conduct the full laboratory COVID-19 testing to use funds under this program. It may do so should the RHC have such capabilities.

Are RHCs required to perform COVID-19 testing onsite or can the testing occur at another facility? (Added: 7/16/2020)

RHCs may not have the ability to perform COVID-19 testing onsite or they may determine that testing may be carried out more effectively in another setting. Under such a scenario in which the testing is conducted offsite and/or by a third party, the RHC (identified by TIN) that received the funds must be actively involved in the administration and oversight of the testing program. RHCs should utilize this funding to best address the testing needs of their local communities, including administration of tests and/or laboratory services.

For example, the RHC may wish to conduct testing at an affiliated provider facility (e.g., hospital linked to the RHC) or in collaboration with other community entities (e.g., local employer, school, nearby providers). These and other partnerships are allowable. However, the organization represented by the RHC TIN must be able to report accurately and timely information to HHS as requested and demonstrate that it is actively managing the testing program. Further, the program requires that the physical testing site be reasonably situated in the same service area as the RHC to effectively serve the RHC’s patients.

How does insurance payment affect allowable uses of funding under the RHC COVID-19 Testing Program? (Added: 7/16/2020)

RHCs under this program can provide testing for uninsured and insured patients, but, per the Terms and Conditions (PDF - 223 KB), may not use this payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. Other sources of reimbursement include: payments from insurance providers, Medicare, Medicaid, other Provider Relief Fund payments, and other payers (e.g., workers compensation insurance or employer sponsored insurance). Entities providing testing under this program must seek reimbursement for services provided when other sources are obligated to reimburse the RHC for the testing or testing-related services (e.g., patients have public or private insurance that covers COVID-19 testing).

RHCs may use funds for upfront purchase of supplies necessary to implement and operate a testing program, such as test kits, swabs, and personal protective equipment (PPE). Similarly, RHCs may use funds for 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.
Subsequent reimbursement or obligated reimbursement to the RHC for COVID-19 testing and/or testing related services by another external payment source, such as public or private insurance coverage, must be recorded.

For example, should the RHC recoup some of the costs of COVID-19 testing and/or testing related services through insurance reimbursements or other payments, the RHC should maintain a record of the amount of RHC COVID-19 testing money recouped, and ensure those RHC COVID-19 Testing Program funds are used to support unreimbursed COVID-19 testing and/or related expenses consistent with the Terms and Conditions (PDF - 223 KB).

Despite insurance coverage, not all testing-related activities may be reimbursable and RHCs may also apply funds towards these items and services. If there is no way for an RHC to receive reimbursement for a service because no allowable billing code exists, then RHCs may use funds towards this activity for insured patients.

RHC COVID-19 Testing Program Reporting

Who should report data for the RHC COVID-19 Testing Program? (Added: 10/28/2020)

To monitor and assess the program, per the Terms and Conditions (PDF - 223 KB), funded organizations at the Tax Identification Number (TIN) level are required to report the number of tests conducted and the number of positive tests on a monthly basis for the duration of the reporting period retroactively to May 2020.

Where should TIN organizations report data from the RHC COVID-19 Testing Program? (Added: 10/28/2020)

TIN organizations should report data on the RHC COVID-19 Testing Report websiteHRSA Exit Disclaimer. HRSA has funded the National Association of Rural Health Clinics (NARHC) HRSA Exit Disclaimer 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 Testing Report website. If you have additional questions you may email RHCcovidreporting@narhc.org HRSA Exit Disclaimer.

What information is required for RHC COVID-19 Testing Program reporting? (Added: 10/28/2020)

RHC COVID-19 Testing Program reporting includes basic information on the RHC organization, the number of and location of testing sites (active and inactive), information on the use of funds, the total number of tests conducted, and the number of COVID-19 positive tests. 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.

How often do RHCs/TIN organizations need to update their information on RHCcovidreporting.com? (Added: 10/28/2020)

RHCs are required to provide information monthly.

Are RHCs (or their TIN organizations) required to do COVID-19 testing? (Added: 10/28/2020)

No. Zero is an allowable entry on the month-by-month reporting page of RHCcovidreporting.com HRSA Exit Disclaimer. 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 - 223 KB).

Do I need to report RHC COVID-19 Testing Program data on RHCcovidreporting.com if I report COVID-19 testing for data for the Provider Relief Fund? (Added: 10/28/2020)

Yes. The RHC COVID-19 Testing Program reporting system is mandatory for all TIN organizations that accepted RHC COVID-19 Testing Program funds and does not replace any other reporting requirements that RHC organizations may have with respect to COVID-19, such as those required for public health surveillance purposes and the Provider Relief Fund.

How long do RHCs need to report data on RHCcovidreporting.com for the RHC COVID-19 Testing Program? (Added: 10/28/2020)

Data reporting requirements are expected to continue for the foreseeable future. HRSA will issue guidance as more information becomes available.

Do RHCs need to continue reporting data on RHCcovidreporting.com after RHC COVID-19 Testing Program funds have been spent? (Added: 10/28/2020)

Yes. RHCs that accepted RHC COVID-19 Testing Program funding should continue reporting on RHCcovidreporting.com HRSA Exit Disclaimer monthly even after the funding has been spent.

RHC COVID-19 Testing Program Funding Mechanism

What is the Rural Health Clinic COVID-19 Testing Program funding amount? (Added: 5/20/2020)

Each RHC with an active CMS Certification Numbers (CCN) listed in the CMS Provider of Service file (March 2020) or the CMS Survey & Certification's Quality, Certification and Oversight Reports (QCOR) before May 7, 2020 received a uniform, flat amount of  $49,461.42.

Who is eligible to receive the Rural Health Clinic COVID-19 Testing Program funds? (Added: 5/20/2020)

All RHCs that have CMS Certification Numbers (CCNs) and are listed in either the CMS Provider of Service file (March 2020) or the CMS Survey & Certification's Quality, Certification and Oversight Reports (QCOR) before May 7, 2020, were eligible to receive Rural Health Clinic Testing funds.

If an organization has multiple RHC sites, which RHC will receive the Rural Health Clinic COVID-19 Testing Program funds? (Added: 5/20/2020)

Rural Health Clinic COVID-19 Testing Program funds will be distributed to the banking account information associated with the organization’s billing TIN, based on the organization’s number of eligible RHC sites. Billing TINs receiving a payment that operate more than one RHC site have discretion to distribute the payment among their RHC sites.

How did HHS disperse the $225 million Rural Health Clinic COVID-19 Testing Program funds? (Updated: 10/28/2020)

Most Rural Health Clinic Testing funds were dispersed electronically based upon banking account information associated with the organization’s TIN. If the organization’s TIN does not have a bank routing number associated with it, the organization will receive a paper check.

How was the Rural Health Clinic COVID-19 Testing Program ACH deposit transaction labeled? (Added: 7/16/2020)

The automatic payments were sent via Optum Bank with “COVID*RuralHealthTestingPmt*HHS.GOV” in the payment description.

My RHC did not receive Rural Health Clinic COVID-19 Testing Program funds but believe we should have. Why did this occur? What should we do? (Updated: 10/28/2020)

All RHCs that have CMS Certification Numbers (CCNs) and are listed in either the CMS Provider of Service file (March 2020) or the CMS Survey & Certification's Quality, Certification and Oversight Reports (QCOR) before May 7, 2020, were eligible to receive Rural Health Clinic COVID-19 Testing Program funds. Some RHCs may not have received funds during the first disbursement on May 20, 2020 for reasons detailed below.

RHCs that did not have an active electronic funds transfer established with HHS will receive a paper check in the mail, which is a slower process. In a limited number of cases, an RHC did not have an active Tax Identification Number (TIN) linked to their CCN as on file with HHS; therefore, HHS could not complete payment on May 20, 2020. Some RHCs might have had other issues needing resolution prior to payment associated with their TINs.

In the case of RHCs with TIN issues, HHS investigated these cases and issued payment if the RHC otherwise met eligibility criteria and is in good standing with applicable Federal programs.

What actions must an RHC take after receipt of the Rural Health Clinic COVID-19 Testing Program funds? (Added: 5/20/2020)

Each organization was required to complete the attestation process to accept or reject the Rural Health Clinic Testing funds within 45 days of receipt of payment via ACH or within 60 days of check payment issuance. Not returning the payment or attesting to the receipt of funds within this timeframe will be viewed as acceptance of the terms and conditions.

How can a TIN operating multiple RHCs verify that the correct amount of Rural Health Clinic COVID-19 Testing Program funding was received? (Added: 7/16/2020)

HHS provided Rural Health Clinic COVID-19 Testing Program funding in the amount of $49,461.42 for each eligible RHC with a unique CMS Certification Number (CCN) associated with an eligible Tax Identification Number (TIN). TIN organizations should have received $49,461.42 times the number of RHCs it operates.

Our TIN operates multiple RHCs, but received payment for an RHC that we closed or sold to another owner, in addition to payment for the other RHCs we still operate. What should we do? (Added: 7/21/2020)

If an organization that sold, terminated, transferred, or otherwise disposed of a provider that was included in its most recent tax return gross receipts or sales (or program services revenue) figure can attest to meeting the Terms and Conditions (PDF - 223 KB), it may accept the funds. The Terms and Conditions (PDF - 223 KB) place restrictions on how the funds can be used. In particular, all recipients will be required to substantiate that these funds were used for COVID-19 testing and related expenses, and that those expenses were not reimbursed from other sources and other sources were not obligated to reimburse them.

How do RHCs return Rural Health Clinic COVID-19 Testing Program funds? (Updated: 10/28/2020)

RHCs may return a payment via the attestation portal within the attestation period and indicate they are rejecting the funds. The CARES Act Provider Relief Fund Payment Attestation Portal will guide RHCs through the attestation process to reject the funds. To return the money, the RHC needs to contact their financial institution and ask the institution to refuse the received Automated Clearinghouse (ACH) credit by initiating an ACH return using the ACH return code of “R23 - Credit Entry Refused by Receiver." If a RHC received the money via ACH they must return the money via ACH. If the RHC was paid via paper check, after rejecting the payment in the attestation portal, the RHC should destroy the check if not deposited or mail a paper check to UnitedHealth Group with notification of their request to return the funds. If the financial institution will not allow them to return the payment electronically please contact United Health Group’s Provider Support Line at (866) 569-3522.

TIN organizations that received and subsequently returned the funding are not required to report data on the RHC COVID-19 Testing Report website HRSA Exit Disclaimer.

Resources

Where can I go for more information on implementing a COVID-19 testing program? (Added: 5/20/2020)

HRSA funded National Association of Rural Health Clinics (NARHC) HRSA Exit Disclaimer under a cooperative agreement to support the recipients of RHC COVID-19 Testing Program funds in alignment with the Terms and Conditions (PDF - 223 KB). Under this award, NARHC and subrecipient, National Organization of State Offices of Rural Health (NOSORH) HRSA Exit Disclaimer, provide technical assistance (TA) through webinars, direct consultation with RHC stakeholders, and a RHC COVID-19 Testing Data Report website (RHC CTR) HRSA Exit Disclaimer on the NARHC webpage HRSA Exit Disclaimer.

The Centers for Disease Control and Prevention (CDC) published information for healthcare professionals on COVID-19 Testing.

Where can I find additional FAQs on the Provider Relief Fund, such as FAQs on the attestation portal? (Added: 7/16/2020)

Additional FAQs on the Provider Relief Fund are available from Department of Health and Human Services (HHS) CARES Act Provider Relief Fund: FAQs.

Funding and Other Resources

Has HRSA has made a decision to extend grant submission deadlines amid the COVID-19 pandemic, or will HRSA consider extending grant submission deadlines on a case-by-case basis? (Added: 3/27/2020)

At this time, we have extended the Notice of Funding Opportunity (NOFO) submission deadlines for three rural health programs:

We encourage you, if possible, to submit an application prior to the published deadline in Grants.gov. We will continue to monitor and assess if, and when, the deadlines for other NOFOs need to be extended. Please see the COVID-19 Grantee Frequently Asked Questions for information about requesting an extension from HRSA's Division of Grants Policy to a published NOFO deadline.

What funding for rural hospitals is available from the Coronavirus Aid, Relief, and Economic Security Act (P.L. 116-136)? (Revised: 5/1/2020)

The Health Resources and Services Administration’s (HRSA) Federal Office of Rural Health Policy received $150 million through the Coronavirus Aid, Relief, and Economic Security (CARES) Act to support small rural hospitals responding to the COVID-19 health crisis. These funds have been awarded to state Small Rural Hospital Improvement Program (SHIP) grantees to assist small rural hospitals.

Telehealth

What changes to telehealth policy have been implemented to respond to the COVID-19 pandemic? (Updated: 8/3/2020)

How can rural health care providers get help to start or expand telehealth services for our patients? (Updated: 8/3/2020)

Travel

My program includes activities providing on-site TA to hospitals using consultants. If the hospital needs to cancel or the consultants need to travel, is there flexibility to delay items on my work plan? (Added: 3/20/2020)

Yes, you should adjust the schedule to make sure hospitals are able to meet the needs of the community and that your consultants are comfortable with travel. You could look into potential alternative methods to continue to provide some technical assistance (through phone calls or video conferencing) in the short term, but we understand that delaying timelines could be the best option.

Our coalition has scheduled group meetings as part of HRSA-funded activities. We will be unable to meet in the near future, as we are all health care professionals in some capacity. Do you have any guidance on next steps? (Added: 3/20/2020)

We understand that meetings, both virtual and in-person, may be reduced or canceled as a result of COVID-19. If you need to make changes to your work plan, please stay in contact with your FORHP point of contact to keep us informed of specific changes in your HRSA approved work plan goals and objectives, and the impact those specific changes would have on your HRSA project.

How does COVID-19 impact my ability to travel to fulfill the project-related activities of my HRSA grant? (Added: 3/20/2020)

We recommend abiding by the recommendations and regulations of your state and local officials as well as using your best judgement regarding grant-funded travel. FORHP understands that this is a public health emergency and that you may need to change or postpone some grant activities, including those requiring travel. Please continue to monitor the CDC website for updates and to find information about COVID-19. If you are planning to travel as part of your grant, please ensure you have up to date domestic and/or overseas travel information from the CDC travel advisory website. You can also find updates via the State Department travel advisory site.

Grants Management

How should recipients of rural health grants and cooperative agreements manage activities and services in the event that critical staff members are unable to work due to either illness or COVID-19 quarantine? (Added: 3/27/2020)

HRSA’s FORHP recognizes that many recipients are working to address or may be impacted by COVID-19 emergencies within their communities, which may impact their ability to meet grant requirements. We encourage recipients to continue to provide rural health services and grant activities in a safe and efficient manner. Please talk with your project officer regarding alternative approaches to planned activities. Once the emergency has waned, we will work with you on the completion of required activities.

What flexibilities are available to recipients of rural health grants if our projects and activities are interrupted or we are unable to complete required reports? (Added: 3/27/2020)

Please see the HRSA COVID-19 Grantee Frequently Asked Questions and discuss your specific situation with your FORHP project officer.

Health Care Delivery and Policy Information

What flexibility has CMS provided for rural and critical access hospitals (CAHs) to support the COVID-19 response? (Updated: 3/27/2020)

CMS is waiving the requirements that Critical Access Hospitals limit the number of beds to 25, and that the length of stay be limited to 96 hours. CMS has developed a COVID-19 fact sheet for health care providers (PDF - 430 KB) that addresses this and other frequently asked questions. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website.

I participate in quality measurement and reporting efforts as part of my grant-related activities and/or as a health care entity. Have there been any changes to quality reporting requirements due to the COVID-19 pandemic? (Updated: 3/27/2020)

On March 22, 2020, CMS announced relief for clinicians, providers, hospitals, and facilities that participate in the Quality Reporting Programs in response to COVID-19. Read the release for full details.

What information is available for rural health care providers? (Updated: 8/25/2020)

Date Last Reviewed:  November 2020