RHCs funded under the RHC COVID-19 Testing and Mitigation (RHCCTM) Program may apply any of the payments to COVID-19 testing, COVID-19 testing-related expenses, COVID-19 mitigation, and COVID-19 mitigation-related expenses.
COVID-19 Testing Expenses
COVID-19 testing described in the RHC COVID-19 Testing and Mitigation Terms and Conditions include, but are 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 not limited to:
- Laboratory (complete laboratory and/or partial laboratory cycle (i.e., phases))
- Testing site (onsite 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).
COVID-19 Mitigation Expenses
COVID-19 mitigation includes efforts, activities, and strategies to reduce or prevent local COVID-19 transmission and minimize morbidity and mortality of COVID-19 in places such as schools, workplaces, and healthcare organizations, described in the RHC COVID-19 Testing and Mitigation Terms and Conditions and in the CDC Community Mitigation Framework. Community mitigation efforts aim to reduce the rate at which someone infected comes in contact with someone not infected, or reduce the probability of infection if there is contact. The more a person interacts with different people, and the longer and closer the interaction, the higher the risk of COVID-19 spread. Mitigation activities may include, but are not limited to:
Case investigation
Case investigation is the process of working with a person (patient) who has been diagnosed with COVID-19, and includes, but is not limited to:
- Discuss patient test result or diagnosis
- Assess patient symptom history and health status
- Provide instructions and support for self-isolation and symptom monitoring
- Identification of people (contacts) who may have been exposed to COVID-19
Additional case investigation information and resources for health departments are available from the CDC.
Contact tracing
Contact tracing is the process of notifying people (contacts) of their potential exposure to SARS-CoV-2, the virus that causes COVID-19 and includes, but is not limited to:
- Provide information about the virus
- Discuss their symptom history and other relevant health information
- Instructions for self-quarantine and monitoring for symptoms
- Support and referrals to testing, clinical services, and other essential support services
Additional contact tracing information and resources for health departments are available from the CDC.
Screening
Testing asymptomatic persons without recent known or suspected exposure to SARS-CoV-2 for early identification, isolation, and disease prevention. Screening testing as a prevention strategy can improve detection of SARS-CoV-2. Widespread testing (e.g., within cohorts) with rapid isolation of infected individuals may facilitate reopening of businesses, communities, and schools (e.g., in-person instruction in K-12 schools) with less risk of a surge in local cases.
Post-COVID conditions management
Post-COVID conditions can occur in patients who had varying degrees of illness during acute infection, including those who had mild or asymptomatic infections. Post-COVID conditions are referred to as a wide variety of names, including post-acute COVID-19, long-term effects of COVID, long COVID, post-acute COVID syndrome, chronic COVID, long-haul COVID, late sequelae, and others, as well as the research term post-acute sequalae of SARS-COV-2 infection (PASC).
Post-COVID conditions can be considered a lack of return to a usual state of health following acute COVID-19 illness. It might also include development of new or recurrent symptoms that occur after the symptoms of acute illness have resolved. Post-COVID conditions include, but are not limited to:
- Health consequences that are present more than 4 weeks after infection with SARS-CoV-2.3
- Multiorgan system effects of COVID-19
- Multisystem inflammatory syndrome (MIS)
- Autoimmune conditions
- Longer effects of COVID-19 treatment or hospitalization
- Long COVID
The best way to prevent long-term complications is to prevent COVID-19. There are ways to mitigate patient post-COVID conditions and lessen symptoms over time. You are encouraged to provide options for managing or treating post-COVID conditions and symptoms. Post-COVID mitigation includes, but is not limited to:
- Education, rehabilitation, prevention, treatment, and support services including support for activities of daily living
- Post-acute COVID care clinics
- Post-acute COVID patient appointments
- Resources for support
- Survivor support groups
- COVID-19 aftercare
3 The time frame of more than four weeks provides a rough approximation of effects that occur beyond the acute period, but the timeframe might change as the CDC learns more.
Health behavior promotion
Promote behaviors that prevent the spread of COVID-19, and includes but is not limited to:
- Healthy hygiene practices
- Stay at home when sick
- Practice physical distancing to lower the risk of disease spread
- Referrals to testing, clinical services, and support services
- Cloth face coverings (i.e., masks)
Maintain healthy environments
- Clean and disinfect
- Ensure ventilation systems operate properly and increase circulation of outdoor air
- Ensure all water systems are safe to use
- Modify layouts to promote social distance of at least 6 feet between people
- Install physical barriers and guides to support social distancing if appropriate
COVID-19 Testing-Related Expenses
Related testing expenses are described in the RHC COVID-19 Testing and Mitigation Program Terms and Conditions and the RHC COVID-19 Testing Program Terms and Conditions. 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:
- 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
- Test kits
Personal protective equipment (PPE)
Personal protective equipment, commonly referred to as "PPE", includes, but is not limited to:
- Facemasks
- Eye protection
- Gowns
- Gloves
- N95 and other respirators
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
- Incentive pay
- 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
COVID-19 Mitigation-Related Expenses
Related COVID-19 mitigation expenses are described in the RHC COVID-19 Testing and Mitigation Program Terms and Conditions. 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 and/or COVID-19 mitigation activities. The related expense must be appropriate given relevant clinical and public health guidance. Related expenses include, but are not limited to:
Workforce
- Planning for implementation of a COVID-19 mitigation program
- Training providers and staff on COVID-19 mitigation activities
- Hiring providers and staff to carry out COVID-19 mitigation activities
- Reporting data to HHS on COVID-19 mitigation activities
- Expenses to secure and maintain adequate personnel to carry out COVID-19 mitigation 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
- Incentive pay
- Childcare
- Transportation
- Temporary housing
Health care setting/facility
- Building or construction of temporary structures as necessary to support mitigation activities
- Leasing of properties as necessary to support mitigation
- Retrofitting facilities as necessary to support mitigation and infection control
CDC recommends a layered approach to reduce exposures to SARS-CoV-2 and other infectious diseases which includes using multiple mitigation strategies, including but not limited to recommendations found in the CDC Guidelines for Environmental Infection Control in Health-Care Facilities.
Digital technologies
Digital technologies to strengthen the core capacity to support the public-health response to COVID-19 including, but not limited to:
- Population surveillance
- Case identification
- Contact tracing
- Evaluation of interventions on the basis of mobility data and communication with the public
Unallowable Expenses
RHC CTM Program funds may NOT be used for direct provider-to-patient vaccine administration (i.e., shot-in-arm). Direct provider-to-patient vaccine administration does NOT include associated costs and add-on services necessary to facilitate or in conjunction with the direct provider-to-patient vaccine administration.
The following HRSA programs cover the cost of vaccine administration:
*For allowable expenses under the Rural Health Clinic COVID-19 Testing Program, visit the RHCCT Program page.
