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HHS Announces an Additional $20 Billion In Provider Relief Grants

Client Alert

The U.S. Department of Health and Human Services (“HHS”) announced an additional $20 billion in new funding for providers on October 1, 2020. Eligible providers include those that have already received Provider Relief Fund payments as well as previously ineligible providers, such as those who began practicing in 2020, and an expanded group of behavioral health providers confronting the emergence of increased mental health and substance use issues exacerbated by the pandemic. The new Phase 3 General Distribution is designed to balance an equitable payment of 2% of annual revenue from patient care for all applicants plus an add-on payment to account for revenue losses and expenses attributable to COVID-19. All new applicants will need to attest to the Terms & Conditions

Who is eligible to receive Phase 3 Funding?

  • Providers who previously received, rejected or accepted a General Distribution Provider Relief Fund payment. Providers that have already received payments of approximately 2% of annual revenue from patient care may submit more information to become eligible for an additional payment.
  • Behavioral Health providers, including those that previously received funding and new providers. The Phase 3 release specifically mentions that addiction counseling centers, mental health counselors, and psychiatrists will be able to receive funding but, presumably, a full list will be released soon.
  • Healthcare providers that began practicing January 1, 2020 through March 31, 2020. This includes Medicare, Medicaid, CHIP, dentists, assisted living facilities and behavioral health providers.

What are the criteria for payment?

  • All provider submissions will be reviewed to confirm they have received a Provider Relief Fund payment equal to approximately 2 percent of patient care revenue from prior general distributions. Applicants that have not yet received Relief Fund payments of 2 percent of patient revenue will receive a payment that, when combined with prior payments (if any), equals 2 percent of patient care revenue.
  • With the remaining balance of the $20 billion budget, HRSA will then calculate an equitable add-on payment that considers the following:
    • A provider’s change in operating revenues from patient care;
    • A provider’s change in operating expenses from patient care, including expenses incurred related to coronavirus; and
    • Payments already received through prior Provider Relief Fund distributions.

What is the application period?

  • October 5, 2020 through November 6, 2020.
  • HHS encourages providers to apply early to expedite HHS’s review process and payment calculations.

If you have any questions about Provider Relief Funds, please contact Ashley Watson at abwatson@bmdllc.com


Compounding GLP-1 Drugs - Recent Updates

Recent guidance from the Ohio Board of Pharmacy (“BOP”) indicates that providers should generally use the FDA approved GLP-1 drug, rather than a non-FDA approved compounded version of the medication. Importantly, if a GLP-1 drug is commercially available, it cannot be copied through compounding. Currently, compounded copies of Tirzepatide and Semaglutide are not permitted.

Top Compliance Risks for Ohio Med-Spas in 2025

The Ohio Board of Pharmacy has increased inspections of med-spas holding Terminal Distributor of Dangerous Drugs (TDDD) licenses, with many facing enforcement actions in 2025. Common issues include purchasing from unlicensed distributors, improper drug storage, inadequate recordkeeping, and insufficient prescriber oversight. Understanding these risks and maintaining compliance can help protect your practice from penalties and license suspension.

Pre and Postnuptial Agreements | Necessary, Maybe, What Happened to Forever?

Both Florida and Ohio now allow clients to enter into a prenuptial or postnuptial agreement prior to marriage or after marriage (Ohio previously did not allow postnuptial agreements). Both documents have statutory guidelines that must be followed in terms of execution and financial disclosure.

DHS Ends All Employment Authorization Auto-Extensions

Effective October 30, 2025, DHS ends all automatic work authorization renewals. The 540-day extension applies only to renewals filed before this date, and there is no grace period for expired EADs filed on or after October 30. Employers must audit EADs, train staff, ensure I-9 compliance, and plan for work authorization gaps. Penalties for noncompliance can be severe.

CMS’s Rural Health Funding Announcement

CMS has announced a $50 billion Rural Health Transformation (RHT) Program to improve healthcare access, quality, and outcomes in rural communities. All states are eligible to apply for funding by November 5, 2025. Half of the funds will be distributed equally, with the remainder based on state-specific factors. The program supports evidence-based initiatives, workforce recruitment, and access to treatment services, with awards assessed annually