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Policy Update: Vaccines Mandates, Workplace Safety Standards, and Provider Relief Fund Updates

Temperatures are finally coming down everywhere. Is there anywhere where October isn’t a
beautiful month? Unfortunately, Delta continues to plague us and COVID-19 dominates our update this month.

Vaccines Mandates and Workplace Safety Standards

Back on September 17th, you likely received a special communication from Aledade’s Chief
Medical Officer, Dr. Emily Maxson regarding OSHA workplace standards and vaccine mandates
coming in the future from the federal government. Aledade provides a toolkit for the OSHA
standards. CMS is charged with developing the vaccine mandate regulations for health care
entities and those are expected this month. It is highly likely that all practices that are certified by
CMS (i.e. have a CMS certification like FQHCs/RHCs) will be included. We also believe it is more
likely than not that private practices will be included. We will send out a special notification once
we know for sure.

Provider Relief Fund Updates

New Funding

The fourth round of PRF applications is open now through October 26, 2021, with $25.5 billion in
available funding. This round prioritizes medium and small providers, those who have a larger
percentage of Medicare, Medicaid, or CHIPs patients, and those that provide care to patients in
rural areas. Payment will be based on changes in quarterly operating revenues and expenses. The rules are more generous than round three and we strongly encourage every practice to apply. HRSA will determine eligibility. Any provider who has at least one claim for a rural beneficiary will receive a minimum payment. Therefore you should check yes on being considered for the rural payment (also known as ARP). HRSA will determine if it applies to you and you are just asking for the determination to occur, not attesting that you qualify. Find FAQs here.

Reporting Deadline

In last month’s policy update, we said that was our last reminder for the September 30 deadline
to report on funds received. Now, you’ll hear us mention it two more times. HHS has implemented a 60-day grace period for providers to report on their use of payments. You now have until November 30, 2021, before HHS initiates enforcement actions for noncompliance.

Upcoming Government Actions

The threat of a government shutdown passed without incident and the government is funded
through December 3rd. The Public Health Emergency is up for renewal soon and will be renewed.

Recent Aledade Policy Resources

Casey summarized our 23-page physician fee schedule comment letter. Casey and Britainy pulled together a comprehensive white paper on telehealth. Caroline and Hannah worked with Dr. Randy Walker on how the way we are influencing state policy in Arkansas can be a blueprint across the country.

Thank you for everything you are doing and please stay safe.