As we previously reported, on April 10, 2020, HHS issued the first disbursement of $30 billion from the CARES Act Emergency Relief Fund for Providers (Relief Fund). On April 24, 2020, HHS announced a second disbursement of $20 billion from the Relief Fund. Per HHS, the second disbursement is intended to “augment [recipients’] allocation so that the whole $50 billion general distribution is allocated proportional to providers’ share of 2018 net patient revenue.” While recipients did not have to apply in order to receive these funds, both disbursements are accompanied by Terms and Conditions that impose strict eligibility and usage requirements. Notably, HHS updated the first Terms and Conditions document to match several of the requirements included in the second Terms and Conditions document—however, the Terms and Conditions for these two disbursements are not entirely identical and there are differences. Kathie McDonald-McClure and Victoria Fuller of Wyatt prepared an update to their prior article about the second disbursement of Relief Funds, the Terms and Conditions and the compliance requirements. Click here to read more.