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Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to Ethnicity and Race

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U.S. Department of Health and Human Services Office of Inspector General report OEI-05-20-00580, July 2023, Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of Populations Served, under Ann Maxwell, Deputy Inspector General for Evaluation and Inspections. The Report in Brief states that communities with greater concentrations of Hispanic/Latino residents were generally associated with less 2020 targeted provider relief funding for hospitals than communities with lower concentrations. It states that high concentrations of Non-Hispanic Black residents were sometimes associated with more funding and that funding levels were not found to be associated with poverty. It describes the method of translating hospital allocations into estimated PRF per person amounts for each U.S. census tract.

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“Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to Ethnicity and Race.” Original at oig.hhs.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/targeted-prf-allocated-to-hospitals-had-differences-by-ethnicity-race/, SHA-256 5940ca2f854fc5c463e178d139671a69157d1e7395cec6fb8c5f85af8374ac54.

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U.S. Department of Health and Human Services

Office of Inspector General



Targeted Provider Relief Funds
Allocated to Hospitals Had Some
Differences with Respect to the
Ethnicity and Race of Populations
Served




Ann Maxwell
Deputy Inspector General
for Evaluation and Inspections
July 2023, OEI-05-20-00580
U.S. Department of Health and Human Services
Office of Inspector General
Report in Brief
July 2023, OEI-05-20-00580


Targeted Provider Relief Funds Allocated to Hospitals Had Some
Differences with Respect to the Ethnicity and Race of Populations
Served
                                                Why OIG Did This Review
 Key Results                                    The COVID-19 pandemic highlighted longstanding inequities,
 Communities with greater                       like disparities in funding levels for health care providers by
 concentrations of Hispanic/Latino              locations and populations served, as well as inequitable access
 residents were generally associated            to quality health care. 1 From the beginning of the pandemic,
 with less 2020 COVID-19 targeted               reports indicated that people of color (e.g., Hispanic/Latino
 provider relief funding for hospitals          and Black Americans) and people from economically
 than communities with lower
                                                disadvantaged communities were at greater risk of COVID-19
 concentrations. This funding disparity
                                                exposure, illness, hospitalization, and death than members of
 raises concerns because
 Hispanic/Latino Americans have been
                                                predominantly Non-Hispanic White communities. 2, 3, 4, 5, 67 In
 more likely to be hospitalized or die          addition, the Centers for Disease Control and Prevention (CDC)
 from COVID-19 than non-Hispanic                considers Hispanic/Latino ethnicity and Black race to be
 White Americans.                               associated with social vulnerability, along with external
                                                stressors such as poverty and poor housing conditions. This
 On the other hand, high concentrations
 of Non-Hispanic Black residents were           means that communities with greater concentrations of
 sometimes associated with more                 Hispanic/Latino residents, greater concentrations of Black
 funding, and funding levels were not           residents, and/or higher rates of people experiencing poverty
 found to be associated with poverty.           may be at a greater risk of experiencing long-term financial
                                                hardship due to disease outbreaks. 8, 9

In April 2020, the U.S. Department of Health and Human Services (HHS) began distributing Provider
Relief Fund (PRF) payments through the Health Resources and Services Administration (HRSA) to
support health care providers, including hospitals, on the front line of the pandemic response. To
respond to the urgent need for health care funding, Congress required HHS to make PRF payments
using the most efficient payment systems practicable. HHS had to make decisions quickly about how to
allocate money in accordance with statutory criteria associated with the funds.

HHS has placed a priority on promoting health equity and reducing health disparities during the
COVID-19 pandemic, including in the distribution of resources. 10, 11 While the PRF was not designed
with the goal of addressing health disparities, understanding how early PRF Targeted Distributions
(Targeted PRF) correlated with racial, ethnic, and economic characteristics of the communities providers
serve can help to inform decisions for future public health funding and the opportunities they present
to advance the health equity goals of HHS.


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How OIG Did This Review
To analyze hospital funding according to populations served, we took allocations to hospitals from the
Targeted PRF in 2020 and translated them into estimated “PRF per person” amounts for each U.S.
census tract (in this report, we also refer to census tracts as “communities”). To do so, we used
Medicare data about the census tracts served by each hospital, and assigned each hospital’s funding
allocations to those census tracts proportionately. We then determined whether there were statistically
significant correlations between PRF per person and the racial, ethnic, and economic composition of the
census tracts. To account for other community characteristics that could help explain differences in PRF
per person, we analyzed rural and nonrural census tracts separately. We conducted this analysis for the
approximately $44 billion in Targeted PRF allocated to hospitals in 2020 through the four allotments
designated for 1) COVID-19 High Impact Area Hospitals, 2) Safety Net Hospitals, 3) Rural Hospitals, and
4) Indian Health Service and Tribal Hospitals.

What OIG Found
Our analysis identified some differences in PRF per person across census tracts with respect to the race
and ethnicity of their residents, but not with respect to poverty rates. Specifically, when we analyzed all
four Targeted PRF allotments combined, we found that communities with greater concentrations of
Hispanic/Latino residents were associated with less PRF per person than communities with smaller
concentrations of Hispanic/Latino residents. In nonrural areas, communities with greater concentrations
of Non-Hispanic Black residents were associated with more PRF per person than communities with
smaller concentrations of Non-Hispanic Black residents, but this pattern did not occur in rural areas.
We did not find a meaningful association between PRF per person and the proportion of residents
experiencing poverty in the community.

When we analyzed the four Targeted PRF allotments individually, we found the most notable trends in
the allotment targeted to rural hospitals (about $9.7 billion): Communities with greater concentrations
of Hispanic/Latino residents or Non-Hispanic Black residents were associated with less PRF per person
than communities with smaller concentrations of Hispanic/Latino Residents or Non-Hispanic Black
residents.

Why This Matters
Differences in hospital funding with respect to the characteristics of the populations hospitals serve—
including race and ethnicity—could potentially exacerbate pre-existing disparities in health outcomes.
If hospitals that serve populations experiencing disparate health outcomes are under-resourced, those
populations may be left with less access to high-quality care, which could widen gaps in health
outcomes.

Health care funding is an important tool that can help HHS contribute to goals of reducing health
disparities, both in the context of COVID-19 and more broadly. We hope that this analysis is useful to
HHS in planning for future emergency funding scenarios and identifying opportunities to support these
goals, to the extent permitted by law.




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BACKGROUND

                     The Provider Relief Fund
                     The Provider Relief Fund (PRF) refers to $178 billion in funds appropriated by
                     Congress in 2020 to prevent, prepare for, and respond to COVID-19, and reimburse
                     health care providers for expenses or lost revenues related to COVID-19. Congress
                     did not require that PRF be allocated in a way that addressed health disparities or
                     build in considerations about which populations were impacted by funding
                     decisions. 12 Congress delegated PRF payment calculation and disbursement to HHS
                     and required HHS to make PRF payments using the most efficient payment systems
                     practicable. 13

                     HHS distributed the PRF through a series of payments (hereafter referred to as
                     allotments) to eligible hospitals and other health care providers with the requirement
                     that funds be used for health-care-related expenses or lost revenue attributable to
                     COVID-19. HHS designed the General Distributions to provide financial relief to
                     providers, including hospitals and other facilities, during the COVID-19 pandemic
                     based on provider characteristics such as Medicare reimbursements and Medicaid
                     and CHIP participation. 14 Targeted Distributions were designed to provide financial
                     relief and address COVID-19 challenges for specific types of hospitals and other
                     facilities based on characteristics such as high numbers of COVID-19 admissions and
                     rural or tribal designations. 15 HHS worked with The Office of the Assistant Secretary
                     for Planning and Evaluation and Health Resources and Services Administration
                     (HRSA), along with multiple stakeholders including third-party contractors, to
                     administer the PRF. In April 2020, HHS designated HRSA as the primary operating
                     division in charge of coordinating and overseeing the creation of payment files,
                     calculation of payment allocations for eligible health care providers and facilities, and
                     disbursement of funds for allotments of the General Distributions and Targeted
                     Distributions.

                     For additional details about the PRF, see Appendix A.


                     Scope and Limitations of Our Evaluation
                     We analyzed the following Targeted PRF allotments that were made to hospitals in
                     2020:
                       COVID-19 High Impact Area Hospitals (hereafter refered to as High Impact
                         Hospitals)
                         • HRSA determined eligibility for this allotment based on hospitals that had
                            high numbers of confirmed COVID-19 positive inpatient admissions in
                            January-June 2020.
                       Safety Net Hospitals
                       Rural Hospitals
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                         Indian Health Service and Tribal Hospitals (hereafter referred to as Tribal
                          Hospitals)

                      For our analysis, we excluded Targeted PRF amounts that were allocated to facilities
                      other than hospitals (such as nursing homes), as well as Targeted PRF amounts that
                      were allocated to children’s hospitals.

                      As a result of focusing on these specific allotments, we analyzed $43 billion of the
                      $46 billion total Targeted PRF allocations that went to hospitals in 2020.

                      We could not assess patterns
                                                               Exhibit 1: The allotments we reviewed
                      in allocations to hospitals
                                                               totaled over $40 billion in Targeted PRF,
                      from General Distributions.
                      Because these distributions              and the allotment targeted at High Impact
                      were allocated to parent                 Hospitals accounted for almost half that
                      companies, data for individual           amount.
                      hospital allocations do not
                      exist in the case of hospitals in
                      hospital systems. The extent
                      to which inclusion of General
                      Distribution allocations may
                      have resulted in different
                      outcomes than those we
                      identified is unknown.

                      We did not review other relief
                      funding that HHS is
                      distributing outside the PRF,
                      such as funds targeted to
                      rural communities through
                      the American Rescue Plan.
                      The extent to which additional
                      funding may have resulted in
                                                               Source: OIG analysis of subset of Targeted PRF allocations after
                      different outcomes than those
                                                               exclusions.
                      we identified is unknown.

                      We were only able to analyze the amounts HRSA allocated to hospitals. Therefore,
                      for the subset of hospitals in our analysis that are owned by a parent organization,
                      we are not able to see where the funds were ultimately distributed. After HRSA
                      calculated allocations for each hospital, HRSA then combined the allocations and
                      distributed a single payment to parent organizations for all of their hospitals. Parent
                      organizations were given flexibility to re-distribute funding to the facilities under
                      their umbrellas at their discretion.



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                      This report describes correlations between Targeted PRF per person and census tract
                      characteristics. Our analysis should not be read to imply that differences in census
                      tract characteristics caused differences in PRF per person. Additionally, we did not
                      assess compliance with Federal requirements.


                     Methodology in Brief
                     To compare funding across populations, we took Targeted PRF allocations to
                     hospitals and translated them into estimated “PRF per person” amounts for each U.S.
                     census tract a based on data about the census tracts served by each hospital. We used
                     Medicare hospital claims to identify the census tracts where each hospital’s patients
                     live. b We attributed each hospital’s Targeted PRF allocations to census tracts
                     proportionally to the number of the hospital’s Medicare claims for patients living in
                     each census tract. Finally, we divided the Targeted PRF amount we attributed to each
                     census tract (i.e., from allocations for all hospitals that served the tract) by the
                     population of the tract. See Exhibit 2 for a diagram illustrating the hospital service
                     area methodology.




                     _____________________________________________________________________________________________________________________________
                     a After excluding tracts in the territories and with data anomalies, we examined PRF per person for 70,342

                     census tracts (96.2% of tracts in the 50 states + DC).
                     b We linked hospital allocations to census tract populations based on Medicare hospital utilization

                     patterns because we do not have access to comprehensive nationwide utilization data from other payers.
                     For Medicaid, although we have access to hospital claims, we were not able to match these to patients’
                     residence census tracts. We conducted a sensitivity test to ensure that this approach did not
                     meaningfully impact our results. See Methodology for more information.
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                     Exhibit 2: Model to illustrate the hospital service area methodology we used
                     to calculate each census tract’s PRF per person




                     After calculating PRF per person for each census tract, we determined whether PRF
                     per person correlated with these demographic and economic characteristics of each
                     census tract: racial and ethnic composition and poverty rates. We performed this
                     analysis for the four Targeted PRF allotments combined, as well as for each of the
                     allotments individually.

                     To account for differences between rural and nonrural communities, we analyzed rural
                     and nonrural census tracts separately based on HRSA’s designations. We examined
                     PRF per person for 14,814 rural census tracts and 55,528 nonrural census tracts.

                     Finally, we created graphs to illustrate the correlations that we found between PRF per
                     person and certain demographic characteristics (e.g., race and ethnicity). We split
                     census tracts into four groups based on the shares of specific races or ethnicities and
                     then compared the PRF per person for each group.

                     See Methodology section for additional details.




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RESULTS

        Across the Targeted PRF allocations we analyzed, both rural and
        nonrural communities with more Hispanic/Latino residents had
        less PRF per person
                                            We analyzed Targeted PRF amounts across all four allotments to
      We analyzed the
                                            identify whether there were any overall funding differences when the
      relationship between
                                            allotments were combined and considered together. We identified
      community
                                            some notable patterns in PRF per person related to race and ethnicity,
      characteristics and OIG’s
                                            which we describe below in detail. Refer to Appendix C for detailed
      estimate of PRF per
                                            results of all community characteristics that we analyzed.
      person, which is based
      on Targeted PRF                       Rural and Nonrural Communities with Greater Concentrations of
      allocations to hospitals              Hispanic/Latino Residents
      in 2020 and data about
      the census tracts served        We found census tracts with greater concentrations of Hispanic/Latino
      by each hospital.               residents were associated with less PRF per person than census tracts
                                      with smaller concentrations of Hispanic/Latino residents. We
                     identified the same trend among both rural and nonrural census tracts, but these
                     differences in PRF per person were larger among rural census tracts.

                     Exhibit 3: In both rural and nonrural census tracts, we found that
                     communities with more Hispanic/Latino residents had less PRF per person.




                     Notes: The bar graphs illustrate the correlations described in the main text of the Results. “Pop” represents the total
                     population that lives in each group of census tracts.

                     Source: OIG analysis of PRF allocations, HHS Protect Data, ACS Data, Medicare hospitals claims and enrollment data,
                     USA Facts COVID-19 data, 2021


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                     In both groups of census tracts, we identified a negative correlation between the
                     proportion of Hispanic/Latino residents in a census tract and the PRF per person (rural
                     correlation coefficient = -0.154, p < .0001; nonrural correlation coefficient = -0.088 c, p
                     < .0001 d,), which means census tracts with greater concentrations of Hispanic/Latino
                     residents were associated with less PRF per person than census tracts with smaller
                     concentrations of Hispanic/Latino residents. These patterns are clear when we split
                     census tracts into groups by their share of Hispanic/Latino residents to represent the
                     correlation results visually, as shown in Exhibit 3. In rural census tracts, census tracts
                     with greater than 15 percent Hispanic/Latino residents were allocated about 16
                     percent less PRF per person than census tracts with less than 5 percent
                     Hispanic/Latino populations. We found a funding difference among nonrural census
                     tracts but with the same notable pattern: nonrural census tracts with greater than 15
                     percent Hispanic/Latino residents were allocated about 6 percent less PRF per person
                     than nonrural census tracts with less than 5 percent Hispanic/Latino residents.

                     See Appendix C for further statistical analysis.


                     Across the Targeted PRF allotments we analyzed, nonrural
                     communities with more Non-Hispanic Black residents had more
                     PRF per person
                     When we analyzed Targeted PRF amounts across all four allotments, we identified a
                     meaningful association for nonrural census tracts, but we did not identify a
                     meaningful association between PRF per person and the concentration of Non-
                     Hispanic Black residents for rural census tracts.

                     Nonrural Communities with Greater Concentrations of Non-Hispanic Black
                     Residents

                     We found nonrural census tracts with greater concentrations of Non-Hispanic Black
                     residents were associated with more PRF per person than census tracts with smaller
                     concentrations of Non-Hispanic Black residents.




                     _____________________________________________________________________________________________________________________________
                     c OIG identified correlations with coefficients less than -0.05 or greater than 0.05 as representing

                     meaningful associations. For example, some researchers may consider only stronger correlations, such as
                     those with coefficients less than -0.10 or greater than 0.10, as representing meaningful associations.
                     d Generally, a p-value less than 0.05 indicates a statistically significant correlation. Correlation coefficients

                     represent the strength of the correlation: coefficients closer to -1.0 indicate a stronger inverse
                     relationship, a coefficient of 0 indicates no relationship, and coefficients closer to 1.0 indicate a stronger
                     direct relationship.
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                     Exhibit 4: In nonrural census
                     tracts, we found that
                     communities with more Non-
                     Hispanic Black residents had
                     more PRF per person.
                     We identified a positive
                     correlation between the
                     proportion of Non-Hispanic Black
                     residents in a nonrural census
                     tract and PRF per person
                     (correlation = 0.136, p < .0001).
                     Nonrural census tracts with
                     greater than 15 percent Non-
                     Hispanic Black residents were
                     allocated about 32 percent                 Notes: The bar graph illustrates the correlations described in the
                                                                main text of the Results. “Pop” represents the total population that
                     more PRF per person than                   lives in each group of census tracts.
                     census tracts with less than 5
                     percent Non-Hispanic Black                 Source: OIG analysis of PRF allocations, HHS Protect Data, ACS
                                                                Data, Medicare hospitals claims and enrollment data, USA Facts
                     populations.                               COVID-19 data, 2021

                     Rural Communities and Concentrations of Non-Hispanic Black Population

                     When we analyzed the Targeted PRF amounts across all four allotments for rural
                     census tracts, we did not identify a meaningful association between the PRF per
                     person and concentrations of Non-Hispanic Black residents. The correlation between
                     the proportion of Non-Hispanic Black residents and PRF per person is close to zero,
                     indicating no meaningful association (correlation = 0.021, p = 0.01).



                     Across the Targeted PRF allotments we analyzed, there was no
                     meaningful association between the proportion of residents
                     experiencing poverty and PRF per person
                     We did not find a meaningful association between PRF per person and the proportion
                     of people experiencing poverty in rural or nonrural communities across the country.
                     The correlation coefficients between poverty rates and PRF per person are very small
                     for both rural and nonrural census tracts (nonrural census tracts: correlation = -0.030,
                     p < .0001; rural census tracts: correlation = 0.040, p < .0001).




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                     Findings Related to Additional Race Groups

                     For Non-Hispanic White residents, we found results that were opposite the
                     results for Non-Hispanic Black residents. Specifically, census tracts with greater
                     concentrations of Non-Hispanic White residents were associated with less PRF
                     per person than census tracts with smaller concentrations of Non-Hispanic
                     White residents in both nonrural and rural census tracts, though the correlation
                     was stronger in nonrural census tracts. These results logically make sense as
                     proportion of Non-Hispanic White and Non-Hispanic Black populations in
                     census tracts likely have an inverse relationship.

                     We found correlations between PRF per person and concentrations of
                     additional race groups. We did not focus our major takeaways on these groups
                     because they comprise relatively small proportions of the population in our
                     analysis. For example, we found a negative correlation between the proportion
                     of Non-Hispanic residents that identify as “Other Race” in a census tract and the
                     PRF per person, and this correlation was stronger in nonrural census tracts.
                     Additionally, in our analysis of the Tribal Hospitals allotment specifically, we
                     found a positive correlation between the proportion of Non-Hispanic American
                     Indian/Alaska Native (AI/AN) residents in a census tract and the PRF per person,
                     indicating that greater concentrations of Non-Hispanic AI/AN residents were
                     associated with higher PRF per person from that allotment.

                     See Appendix C for additional details.




        In the PRF allotment targeted to rural hospitals, communities
        with more Hispanic/Latino and Non-Hispanic Black Residents
        had less PRF per person
                     In addition to analyzing Targeted PRF amounts across all four allotments, we analyzed
                     each allotment individually. Targeted PRF was allocated with different funding
                     formulas in the different allotments, so understanding the results of specific
                     allotments can help inform future funding decisions.

                     We found the most notable trends in the Rural Hospitals allotment. We found two
                     similar trends in this allotment: Communities with greater concentrations of
                     Hispanic/Latino residents were associated with less PRF per person than communities
                     with smaller concentrations of Hispanic/Latino residents, and communities with
                     greater concentrations of Non-Hispanic Black residents were associated with less PRF
                     per person than communities with smaller concentrations of Non-Hispanic Black
                     residents.



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                     In the sections below, we only present the results related to rural census tracts, and
                     not nonrural census tracts, because there was only a small percentage of the Rural
                     Hospitals allotment that was allocated to rural hospitals that served nonrural
                     communities. However, we did see similar trends in nonrural census tracts as well.
                     See Appendix C for detailed analysis.

                     The Rural Hospitals Allotment and Hispanic/Latino Residents

                     When looking within each individual Targeted PRF allotment, the overall trend of less
                     PRF per person to census tracts with greater concentrations of Hispanic/Latino
                     residents (as described in the first result) was also evident in the Rural Hospitals
                     allotment.

                     Exhibit 5: Among rural census
                     tracts, we found that
                     communities with more
                     Hispanic/Latino residents had
                     less PRF per person in the Rural
                     Hospitals allotment.
                     The overall pattern we identified in
                     the analysis across all four Targeted
                     PRF allotments (i.e., less PRF per
                     person allocated to hospitals that
                     served communities with greater
                     concentrations of Hispanic/Latino
                     residents) appears to be driven
                     primarily by the differences within      Notes: The bar graph illustrates the correlations described in the
                     the Rural Hospitals Allotment,           main text of the Results. “Pop” represents the total population
                                                              that lives in each group of census tracts.
                     specifically. In the Rural Hospitals
                     allotment, we identified a negative      Source: OIG analysis of PRF allocations, HHS Protect Data, ACS
                                                              Data, Medicare hospitals claims and enrollment data, USA Facts
                     correlation between the
                                                              COVID-19 data, 2021
                     concentration of Hispanic/Latino
                     residents in a rural census tract and the PRF per person (rural correlation = -0.149, p <
                     .0001). Among the three other individual Targeted PRF allotments (High Impact
                     Hospitals, Safety Net Hospitals, Tribal Hospitals), the correlations between the
                     concentration of Hispanic/Latino residents and PRF per person were smaller or close
                     to zero. See Appendix C for specific correlation coefficients for each allotment.

                     The Rural Hospitals Allotment and Non-Hispanic Black Residents

                     In the Rural Hospitals allotment, rural communities with greater concentrations of
                     Non-Hispanic Black residents were associated with less PRF per person than rural
                     communities with smaller concentrations of Non-Hispanic Black residents. For the
                     Rural Hospitals allotments, we found a negative correlation between PRF per person



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                     and concentration of Non-Hispanic Black population in rural census tracts (correlation
                     = -0.117, p < .0001). e

                     Exhibit 6: Among rural census
                     tracts, we found that communities
                     with more Non-Hispanic Black
                     residents had less PRF per person
                     in the Rural Hospitals allotment,
                     but this trend was offset by the
                     opposite pattern in two other
                     allotments.




                      Notes: The bar graphs illustrate the correlations described in the main text of the Results. “Pop” represents the total
                      population that lives in each group of census tracts.

                      Source: OIG analysis of PRF allocations, HHS Protect Data, ACS Data, Medicare hospitals claims and enrollment data,
                      USA Facts COVID-19 data, 2021



                     We found that this trend related to Non-Hispanic Black residents was offset by the
                     opposite pattern in other individual allotments (see Exhibit 6), which may explain why,
                     as noted previously, we did not find a meaningful association between PRF per person
                     and concentration of Non-Hispanic Black residents in rural communities when looking
                     across all four Targeted PRF allotments. When we analyzed the High Impact Hospitals
                     _____________________________________________________________________________________________________________________________
                     e The correlation in the Tribal Hospitals allotment was also negative (correlation = -0.067, p < .0001).
                                                                                                                            We
                     did not include this allotment in Exhibit 6 because the dollar amounts per person across all rural census
                     tracts are too small to be visible on the same scale. The total money targeted to Tribal Hospitals was
                     much smaller than the other allotments.
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                     allotment and the Safety Net Hospitals allotment individually, we found a positive
                     correlation between PRF per person and concentration of Non-Hispanic Black
                     population in rural census tracts (for rural census tracts, High Impact Hospitals
                     allotment correlation = 0.286, p < .0001; Safety Net Hospitals allotment correlation =
                     0.234, p < .0001).




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CONCLUSION

                     While the PRF was not specifically intended to address health disparities, health care
                     funding, in general, is an important tool that can help HHS contribute to goals of
                     reducing health disparities by supporting communities and populations with greater
                     risk of poor health outcomes, both in the context of COVID-19 and more broadly.
                     HHS has prioritized health equity and reducing health disparities, especially during
                     the COVID-19 pandemic. 16, 17 Many HHS programs, including those that target
                     funding and resources, are meant to reach underserved populations and address
                     disparities. Further, HHS’s emergency preparedness goals include responding to
                     public health emergencies in ways that meet the needs of at-risk populations, which,
                     in the case of COVID-19, may include people of color and people from communities
                     experiencing higher rates of poverty. 18, 19

                     Understanding the relationship between the PRF per person and community
                     characteristics such as race, ethnicity, and income can help to inform HHS on
                     decisions about allotting future emergency funding. For example, in the PRF
                     allotment targeted to rural hospitals, communities with more Hispanic/Latino and
                     Non-Hispanic Black Residents had less PRF per person. However, Hispanic/Latino
                     Americans have been more likely to be hospitalized or die from COVID-19 than non-
                     Hispanic White Americans. Thus, it may be especially important to consider HHS’s
                     goal to reduce health disparities when allocating emergency funding to rural
                     communities in the future.

                     We hope that this analysis is useful to HHS in planning for future emergency funding
                     scenarios and identifying opportunities to support these goals, to the extent
                     permitted by law. Given that emergency funding, like PRF, is designed to respond to
                     an unexpected and urgent need for health care funding and the Department will have
                     to make decisions quickly about how to allocate money, effective planning could help
                     ensure HHS emergency funding is allocated in ways that meet the needs of at-risk
                     populations and further reduce health disparities. Because statutory parameters can
                     impact HHS’s ability to direct funding, it may also be important for HHS to engage
                     with Congress regarding the authority needed to most effectively consider health
                     equity, alongside other priorities like efficiency and expeditiousness, in emergency
                     funding scenarios.




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METHODOLOGY

                     Data Sources
                     PRF allocations

                     HRSA provided OIG with data on all Targeted PRF allocations by provider CMS
                     Certification Number (CCN) that were allocated during calendar year 2020.

                     Hospital data

                     We used data related to individual hospitals from HHS Protect. HHS Protect is a
                     COVID-19 data hub managed by HHS. 20 We used this data source to identify
                     hospitals and their locations.

                     Data from HHS Protect rely on reports submitted by hospitals. HHS Protect was
                     rolled out for use on April 10, 2020. 21

                     Medicare hospital claims and enrollment data

                     We used Medicare Part A and B claims data and Part C encounter data from calendar
                     years 2020 and 2021 to identify the service area of each hospital. We used hospital
                     inpatient and outpatient claims of discharges to identify the Medicare patients who
                     were served by each hospital, and then used Medicare enrollment files to identify the
                     census tracts where those patients live.

                     Census tract characteristics

                     We used Census American Community Survey (ACS) 2019 5-year estimates for census
                     tract social factors: percent of each self-identified race and ethnicity and percent of
                     residents with income less than the poverty level (poverty rate) Census. 22

                     The ACS data are self-reported, based on a sample, and are subject to sampling
                     variability. A relatively small sample of each census tract’s population responded to
                     the ACS survey, and respondents were instructed to choose which category best fits
                     with how they self-identify.

                     In the ACS survey, respondents are asked to self-identify their race. In 2019,
                     respondents were presented the following options and told to “check all that apply”:
                     White, Black or African Am., American Indian or Alaska Native, Asian Indian, Chinese,
                     Filipino, Japanese, Korean, Vietnamese, Native Hawaiian, Guamanian or Chamorro,
                     Samoan, Other Asian, Other Pacific Islander, Some other race. 23 The ACS 5-year
                     estimates data combine multiple Asian races into one category and multiple Native



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                     Hawaiian/Pacific Islander races into one category. f For this study, we further
                     combined Asian and Native Hawaiian/Pacific Islander to one category. We considered
                     respondents as “Other Race” by combining the count of respondents who selected
                     “Some other race” with the count of respondents who checked more than one race.

                     In the ACS survey, respondents were asked about their ethnicity separate from race.
                     Respondents were presented five options: 1) not Hispanic, Latino, or Spanish origin, 2)
                     Yes, Mexican, Mexican Am., Chicano, 3) Yes, Puerto Rican, 4) Yes, Cuban, 5) Yes,
                     another Hispanic Latino, Spanish origin (with a text box below to Print origin). Option
                     1 categorizes individuals into not Hispanic, Latino, or Spanish origin while options 2-5
                     categorize individuals into Hispanic, Latino, or Spanish origin. Because ethnicity is
                     separate from race, respondents of Hispanic, Latino, or Spanish origin could select any
                     of the races presented.

                     To simplify our analysis, we combined ACS respondent data about races and
                     ethnicities to create the following groups: Hispanic (of any race); non-Hispanic White;
                     non-Hispanic Black; non-Hispanic Asian or Native Hawaiian/Pacific Islander (Asian);
                     non-Hispanic American Indian/Alaska Native (AIAN); non-Hispanic Other Race (other
                     than White, Black, Asian, AIAN); or more than one Race (other Race).

                     To define rural and nonrural census tracts, we used HRSA’s list of rural tracts. HRSA
                     identifies rural vs. nonrural census tracts using Rural-Urban Commuting Area (RUCA)
                     codes created by the U.S. Department of Agriculture’s Economic Research Service. 24

                     To determine the distance from each census tract to the nearest hospital, which we
                     used as a control in our regression models, we used Medicare enrollment data for
                     enrollee addresses and the HHS Protect data above for hospital locations. For each
                     Medicare enrollee, we calculated the straight-line distance to each hospital and
                     determined the minimum distance. We then assigned the census-tract minimum
                     distance as the median of all the minimum distances for beneficiaries living in that
                     census tract.

                     COVID-19 deaths

                     We used county COVID-19 death count estimates from calendar year 2020 from
                     USAFacts.org. USAFacts is a nonpartisan non-profit organization that collects and
                     shares public data reported by state and local governments. 25 The USAFacts data
                     provide the cumulative cases and deaths by county from January 22, 2020, through
                     December 31, 2020. Because census-tract level data on COVID-19 deaths were not
                     available, we assigned data from each county to the individual census tracts located in
                     that county. Data from USAFacts rely on measurement and reporting from state- and
                     local-level public health agencies. 26 As such, data collection and reporting
                     methodologies may vary.

                     _____________________________________________________________________________________________________________________________
                     f We used ACS Table B03002, “Hispanic or Latino Origin By Race.”


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                     Data Analysis
                     We analyzed the relationship between PRF per person and the racial, ethnic, and
                     economic composition of each census tract. Specifically, we analyzed these variables:
                     concentration of Hispanic/Latino residents, concentration of each race group (e.g.,
                     Non-Hispanic Black), and concentration of residents experiencing poverty. For our
                     regression modeling, we also analyzed COVID-19 deaths per capita and distance to
                     the nearest hospital.

                     Calculating PRF allocations per person

                     We used Targeted PRF allocation data that we received directly from HRSA to
                     calculate the total amount of Targeted PRF for each hospital. We summed all
                     Targeted PRF allotments that were allocated in 2020 except for the allotment targeted
                     to children’s hospitals. We excluded this allotment because we used Medicare data to
                     assign PRF dollars to census tracts, as described below.

                     We analyzed allocation amounts to most hospitals that were allocated Targeted PRF,
                     including acute care hospitals, tribal hospitals, and critical access hospitals. We
                     excluded 20 hospitals that were allocated Targeted PRF but were not required to
                     submit COVID-19 data in HHS Protect, for example, rehabilitation and psychiatric
                     hospitals. 27

                     After calculating the Targeted PRF amounts across all four allotments for each
                     hospital, we calculated “PRF per person” for each census tract using data about
                     hospital service areas. We used Medicare claims and enrollment data to identify the
                     census tracts of the Medicare patients who had Medicare inpatient or outpatient
                     claims from each hospital during calendar year 2020 or 2021. For each hospital, we
                     then assigned PRF dollars to each census tract in its service area, proportional to the
                     number of claims for patients who live in each census tract. For each census tract, we
                     summed all the money assigned from all hospitals that served that census tract.
                     Lastly, we divided Targeted PRF amounts across all four allotments for each census
                     tract by the population of that census tract. See Exhibit 7 (same as Exhibit 2 from
                     Background) for a diagram of the hospital service area methodology using a very
                     simple example to illustrate. We repeated this same methodology for each of the
                     individual allotments of funding (High Impact Hospitals, Safety Net Hospitals, Rural
                     Hospitals, and Tribal Hospitals), using the same hospital service areas.




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                     Exhibit 7: Model to illustrate the hospital service area methodology we used
                     to calculate each census tract’s PRF per person




                     Excluded census tracts

                     We calculated PRF per person for all census tracts in which Medicare beneficiaries
                     served by hospitals live. However, we then excluded a small number of census tracts
                     from the analyses. We limited our analysis to tracts in 50 States and DC, excluding
                     tracts in U.S. territories. We also excluded census tracts with missing population
                     characteristics, especially low population estimates, and data anomalies. Specifically,
                     we excluded tracts with fewer than 100 residents or fewer than 10 Medicare enrolled
                     residents per ACS estimates, tracts with greater than 50% of the residents living in
                     institutional settings per ACS, and tracts that were outliers when we compared
                     Medicare enrollment counts and the ACS estimates of the number of people with
                     Medicare coverage. We excluded 5% of tracts for final analysis of 70,342 tracts.

                     Statistical analysis

                     For all allotments combined, and separately for the four allotments, we performed the
                     following statistical analysis to understand the relationships between PRF per person
                     and census tract community characteristics.

                     Correlation analysis. To examine the relationships between PRF per person and
                     census tract population characteristics, we calculated Pearson correlation coefficients.
                     We did this separately for rural and nonrural census tracts. We used log transformed
                     variables in the correlation analysis to reduce the influence of outliers.

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                     We reported a correlation between variables as those with a Pearson correlation
                     coefficient greater than 0.05 or less than -0.05 and a p-value less than .05. We
                     reported “no meaningful association” between variables when Pearson correlation
                     coefficients were between -0.05 and 0.05, even if those correlations were statistically
                     significant.

                     Regression analysis. To understand relationships between multiple variables, we ran
                     linear regressions controlling for COVID-19 deaths in January 22-June 10, 2020, and
                     June 11-December 31, 2020, distance to the nearest hospital, and the census tract
                     social factors (proportion of each race and ethnicity group and proportion of
                     population experiencing poverty) to understand which factors were associated with
                     PRF per person while controlling for the other factors in the model. Specifically, we
                     used the following independent variables: proportion of Hispanic/Latino, Non-
                     Hispanic Black, Non-Hispanic Asian/PI, and Non-Hispanic AI/AN residents, residents
                     who identify as Non-Hispanic Other Race, proportion of people experiencing poverty,
                     2020 COVID-19 deaths per capita, and distance to the nearest hospital. We used the
                     same set of independent variables across all regression models so that it would be
                     more possible to compare the estimated parameters among models. We log
                     transformed both the dependent and independent variables in all regression models
                     to reduce the influence of outliers.

                     Graphics. To highlight the notable correlations that we discuss in the main report, we
                     summarized the correlation analysis by creating bar graphs. We subdivided the
                     census tracts into groups based on the population characteristics (percent
                     Latino/Hispanic and percent non-Hispanic Black). For each of these groups, we
                     calculated the total PRF divided by the total population and then compared the PRF
                     per person across the groups. We created the groups by using interval cutoffs. For
                     example, we compared PRF per person for tracts with 0-<5% Hispanic/Latino, 5%-
                     <10% Hispanic/Latino, 10%-<15% Hispanic/Latino, and 15% or higher
                     Hispanic/Latino. The group labeled 0-<5% Hispanic/Latino was created by including
                     census tracts with equal to or greater than 0% of Hispanic/Latino residents and less
                     than 5% of Hispanic/Latino residents. 5%-<10% Hispanic/Latino was created by
                     including census tracts with equal or to greater than 5% Hispanic/Latino residents and
                     less than 10% Hispanic/Latino residents. We continued to use this method for the last
                     two interval cutoff groups.


                     Scope
                     For this evaluation, we analyzed the Provider Relief Funds allocated in Targeted
                     Distributions to hospitals during calendar year 2020. We did not examine General
                     Distributions because allocations could not be always linked to individual hospitals.
                     We excluded the Targeted Distribution targeted to children’s hospitals because the
                     hospital service area distribution limited to people covered by Medicare may not be
                     representative of children’s hospital service areas.

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                     Our analysis was limited to Targeted PRF allocated to hospitals in calendar year 2020.
                     This means our analysis does not provide information regarding any PRF allocated to
                     non-hospital providers, or about any PRF that were distributed after the end of 2020.

                     Our analysis should not be read to imply that differences in census tract
                     characteristics caused differences in PRF per person. Additionally, we did not assess
                     compliance with Federal requirements.


                     Limitations
                     We could not assess the patterns in allocations from the General Distribution with
                     respect to county population characteristics because data for individual hospital
                     allocations do not always exist. General Distribution payments were not always
                     allocated at the facility level because, in the case of hospitals in hospitals systems,
                     they were instead allocated directly to parent companies. Further, we were only able
                     to analyze Targeted Distribution amounts HRSA allocated to hospitals initially, not
                     where the funds were ultimately distributed, because parent organizations, which can
                     include multiple hospitals located in different areas, were given flexibility to re-
                     allocate and distribute funding to facilities under their umbrella at their discretion.
                     Therefore, we could not assume parent organizations disbursed the money in any
                     certain way. It is unknown the extent to which General Distribution allocations may
                     have changed the outcomes we identified, particularly for hospitals that did not
                     receive any funding through the Targeted Distribution but did receive funding
                     through later phases of the General Distribution.

                     However, researchers have raised concerns about the equity of the earlier phases of
                     General Distributions. A study published in the Journal of the American Medical
                     Association suggested that the formulas used to allocate money may have favored
                     hospitals that primarily serve White and higher-income populations. 28 Specifically,
                     initial distributions were allocated proportionally to hospitals’ past revenues.
                     Hospitals that primarily serve White populations tend to have higher revenues, on
                     average, than hospitals that primarily serve people of color and whose patients are
                     more likely to be covered by Medicaid or underinsured. 29, 30 However, because
                     General Distribution payments were often calculated and reported at the parent
                     organization level, there is not comprehensive data on how much individual facilities
                     and providers qualified for.

                     We used Medicare data in our calculation of PRF per person, rather than information
                     on all hospital patients, because we do not have access to comprehensive nationwide
                     utilization data from other payers that could be matched with residence census tracts.
                     Medicare claims data might not always be representative of the full population that
                     receives care at any given hospital. Although we do have hospital utilization from
                     Medicaid, we could not effectively match Medicaid enrollees to their residence census
                     tracts so we could not use this data.

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                     In this study, we used demographic data about characteristics of people living in
                     census tracts. Geography is a proxy that can help us understand the potential impact
                     on certain individuals, but it is not a substitute for lived experiences of individuals.

                     Additionally, we used county-level data for 2020 COVID-19 deaths because 2020
                     COVID-19 deaths data were not available at the census tract level.


        Standards
                     We conducted this study in accordance with the Quality Standards for Inspection and
                     Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.




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APPENDIX A

        Detailed information about Provider Relief Fund and related
        relief funding
                     Provider Relief Fund

                     The PRF refers to relief funds appropriated by Congress to the Public Health and
                     Social Services Emergency Fund based on the Coronavirus Aid, Relief, and Economic
                     Security (CARES) Act in March 2020, the Paycheck Protection Program and Health
                     Care Enhancement Act (PPHCEA) in April 2020, and the Coronavirus Response and
                     Relief Supplemental Appropriations (CRRSA) Act in December 2020. The CARES Act
                     provided $100 billion, the PPHCEA added $75 billion, and the CRRSA Act added an
                     extra $3 billion. 31, 32, 33

                     Through these Acts, Congress delegated PRF payment calculation and disbursement
                     to HHS and required HHS to make PRF payments using the most efficient payment
                     systems practicable. 34 Congress appropriated these funds “to prevent, prepare for,
                     and respond to coronavirus, domestically or internationally, for necessary expenses to
                     reimburse health care providers for health care related expenses or lost revenues that
                     are attributable to coronavirus.” 35 Additionally, some of the PRF appropriations were
                     used for claims reimbursement programs and COVID-19 Coverage Assistance Fund. 36,
                     37



                     HHS worked with The Office of the Assistant Secretary for Planning and Evaluation
                     and Health Resources and Services Administration (HRSA), along with multiple
                     stakeholders including third-party contractors, to administer the PRF. In April 2020,
                     HHS designated HRSA as the primary operating division in charge of coordinating
                     and overseeing the creation of payment files, calculation of payment allocations for
                     eligible health care providers and facilities, and disbursement of funds for allotments
                     of the General Distributions and Targeted Distributions. g

                     General Distributions

                     General Distributions were intended to provide financial relief to providers, including
                     hospitals and other facilities, during the COVID-19 pandemic based on characteristics
                     such as participation in Medicare or Medicaid. 38 General Distributions consisted of
                     four phases of allotments. 39, 40, h Phase 1 consisted of a total of $41.9 billion to
                     _____________________________________________________________________________________________________________________________
                     g According to HRSA, third-party contractors developed the methodology and determined the calculated

                     payments files for hospitals and providers. Then, HRSA and the third-party contractors identified
                     ineligible hospitals and providers. Lastly, the United Health Group allocated final calculated distributions
                     to the eligible providers.
                     h Dollar amounts for General Distribution Phases 1-3 allotments are current as of January 2023.


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                     providers who billed Medicare fee-for-service in calendar year 2019. 41 Phase 2
                     consisted of $4.5 billion to providers that participated in state Medicaid/Children’s
                     Health Insurance Plan or Medicaid managed care plans, dental providers, assisted
                     living facilities, and certain Medicare providers. 42 Phase 3 consisted of $19.5 billion to
                     providers previously eligible for earlier phases, while also expanding to additional
                     provider types such as behavioral health providers. 43 Phase 3 payment calculations
                     included a deduction of all prior PRF payments for providers that received any PRF
                     funds. 44 Phase 4 has consisted of $15.4 billion to providers previously eligible for
                     earlier phases. Phase 4 payments consisted of 1) base payments based on providers’
                     reported changes in revenues and expenses from July 1, 2020, to March 31, 2021; and
                     2) bonus payments based on providers’ level of participation in Medicaid, the
                     Children’s Health Insurance Program, and Medicare. 45, i

                     According to HRSA, General Distribution payments were sometimes allocated and/or
                     disbursed to parent organizations, rather than individual facilities or providers. At the
                     beginning of the pandemic, health care facilities experienced immediate financial
                     hardship. 46 HHS made payments quickly to provide financial support to ensure
                     providers such as hospitals could sustain services. 47 The CARES Act required HHS to
                     use the most efficient payment systems practicable to provide PRF payments. 48
                     According to HHS guidance, any parent organization with more than one facility was
                     allowed to allocate and distribute funding to the facilities under its umbrella at its
                     discretion. 49

                     Targeted Distributions

                     Targeted Distributions were intended to provide financial relief to address added
                     COVID-19 challenges, specific types of hospitals, and other facilities based on certain
                     metrics and characteristics (e.g., high numbers of COVID-19 admissions, rural or tribal
                     designations). Targeted Distributions consisted of several allotments that each had
                     different formulas and methodologies to determine PRF payment amounts. 50

                     Targeted Distributions consisted of several allotments, some of which included
                     payments to hospitals. j, 51 The High Impact allotment consisted of $20.7 billion to
                     hospitals that had a high number of confirmed COVID-19 positive inpatient
                     admissions. 52 The Rural allotment consisted of approximately $11 billion to rural
                     hospitals including rural acute care general hospitals and Critical Access Hospitals
                     (CAHs), primarily based on facility operating expenses. 53 The IHS and Tribal Hospitals
                     allotment consisted of $494 million to IHS and tribal facilities based on facility or
                     program operating expenses and estimated service population. 54 The Safety Net
                     Hospitals allotment consisted of $13.9 billion to Safety Net Hospitals, acute care
                     hospitals, and children’s hospitals based on profit margin, proportion of Medicare


                     _____________________________________________________________________________________________________________________________
                     i Dollar amount for General Distribution Phase 4 allotment is current as of January 2023.

                     j Not all $178 billion of the PRF has been allocated to hospitals and providers.


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                     patients, and proportion of Medicaid patients for the children’s hospitals. 55 Exhibit 8
                     describes the metrics used for each PRF Targeted Distribution allotment.

                     Exhibit 8: 2020 PRF Targeted Distribution allotments that included hospitals
                      Targeted PRF
                      Allotments            Total Amounts                Metric Used to Target Allotments

                      COVID-19 High         $20.7 billion                Number of COVID-19 positive inpatient admissions
                      Impact Area
                      (High Impact
                      Hospitals)

                      Safety Net            $12.8 billion                Proportion of the individual facility score (number of facility
                      Hospitals: Acute                                   beds multiplied by Medicare Disproportionate Patient
                      Care Facilities                                    Percentage for an acute care facility) to the cumulative
                                                                         facility scores

                      Rural Hospitals       $10.7 billion                Base payments plus operating expenses (including lost
                      and Clinics                                        revenue) of rural acute care hospitals and CAHs, operating
                                                                         expenses of Sole Community Hospitals, Medicare
                                                                         Dependent Hospitals, & Rural Referral Center Hospitals in
                                                                         Small Metro Areas

                      Safety Net            $1.1 billion                 Proportion of the individual facility score (facility beds
                      Hospitals:                                         multiplied by Medicaid only ratio) to the cumulative facility
                      Children’s                                         scores
                      Hospitals

                      Indian Health         $0.49 billion                Base payments plus operating expenses of IHS and Tribal
                      Services and                                       Hospitals and estimated service population
                      Tribal Hospitals


                     Notes: These amounts represent the total number of dollars distributed in the listed Targeted PRF allotments. They do
                     not represent the subset of Targeted PRF allotments that were in OIG’s analysis.

                     Source: HRSA, Provider Relief Fund Past Payments Targeted Distributions website. 56 Dollar amounts are current as of
                     November 2022.

                     According to HRSA, Targeted Distribution allotments were allocated for each
                     individual facility and were either distributed to individual facilities or rolled up and
                     distributed to parent organizations.

                     Related COVID-19 Relief Funding

                     In addition to PRF, HHS, through HRSA, began distributing American Rescue Plan
                     payments to rural health care providers in November 2021. These funds were
                     intended to address the disproportionate impact of COVID-19 on rural health care
                     providers and rural communities. 57 These payments were based on characteristics
                     such as Medicare reimbursements for services to rural beneficiaries. 58




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                     Related OIG Work

                     The Office of Inspector General (OIG) is conducting strategic oversight of HHS’s
                     pandemic response and recovery efforts, including additional reviews related to the
                     PRF. For example, OIG found that HHS and HRSA developed controls related to
                     selected PRF program requirements to ensure that providers received the correct PRF
                     payments from the Phase 1 General Distribution in a fast, fair, and transparent manner
                     but that some of those controls could be improved. 59




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APPENDIX B

        Rural and Nonrural Census Tracts
                     Hospitals serving rural census tracts were allocated more PRF per person than
                     hospitals serving nonrural census tracts. The PRF per person in rural census tracts was
                     $218 per person, which is 81% higher than the PRF per person in nonrural census
                     tracts.

                     The COVID-19 pandemic has impacted urban and rural populations differently. The
                     disease initially spread most rapidly in large metropolitan areas (nonrural), which
                     aligns with the fact that most of the U.S. population lives in dense, urban regions. By
                     late October 2020, the number of cumulative COVID-19 cases in rural areas exceeded
                     those in urban areas. 60

                     In addition, the racial and ethnic makeup of rural and nonrural census tracts differs
                     considerably. Exhibit 9 summarizes many of the differences in specific racial and
                     ethnic group populations between rural and nonrural census tracts.

                     Because of these differences, we analyzed rural and nonrural census tracts separately
                     based on HRSA’s designations.

                     Exhibit 9: Statistics on nonrural and rural census tracts
                                                      Mean in Nonrural                    Mean in Rural
                                                        Census Tracts                     Census Tracts
                                                      (n = 55528 tracts)                (n = 14814 tracts)
                      2020 COVID-19                         106.87                            108.92
                      Deaths/100,000
                      residents
                      % Poverty                              13.96%                            15.99%
                      % Non-Hispanic Black                   14.86%                             7.80%
                      % Non-Hispanic Asian/PI                 6.21%                             0.95%
                      % Non-Hispanic AI/AN                    0.39%                             1.71%
                      % Non-Hispanic Other                    2.81%                             2.08%
                      Race
                      % Non-Hispanic White                   57.05%                            78.98%
                      % Hispanic/Latino                      18.68%                             8.48%
                     Note: 2020 COVID-19 deaths represent the total deaths during the range of dates included in our study, January 22,
                     2020, to December 31, 2020.

                     Source: OIG Analysis of USAFacts COVID-19 data, ACS data, HRSA Rural Census Tract Designations.




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APPENDIX C

        Detailed Statistical Analysis for All PRF and Individual Waves
                     We found that the median PRF per person across the four allocations was $106, and
                     PRF per person ranged between $49 per person and $203 per person.

                     Correlation Analysis Results

                     In the main report, we reported on the correlation coefficients between PRF per
                     person and proportion of Hispanic/Latino ethnicity, Non-Hispanic Black, and
                     proportion of people experiencing poverty for all Targeted PRF allotments. We also
                     performed the same analysis with regards to the following census tract characteristics:
                     proportion of Non-Hispanic Asian/PI residents, Non-Hispanic AI/AN residents,
                     residents who identify as Non-Hispanic Other Race, 2020 COVID-19 deaths per capita,
                     and distance to the nearest hospital. Exhibit 10 shows the correlation coefficients for
                     each of these characteristics in all Targeted PRF allotments. We calculated two sets of
                     correlation coefficients for all Targeted PRF allotments: 1) using only nonrural census
                     tracts and 2) using only rural census tracts.

                     The purpose of this report was to analyze correlations between PRF per person and
                     community demographic characteristics, including race, ethnicity, and economic
                     status. Because of this, we did not focus on the correlations between PRF per person
                     and 2020 COVID-19 deaths or PRF per person and distance to the nearest hospital,
                     even though these correlations were often stronger than that of the variables we
                     discussed in our main findings.

                     Please note that most of the census tracts have small percentages of residents that
                     identify as Non-Hispanic “Other Race” (a race not listed or more than one race), Non-
                     Hispanic Asian/PI, and Non-Hispanic AI/AN (please see Appendix B for further
                     details).




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                     Exhibit 10: Results for correlation analysis for all Targeted PRF allotments in
                     nonrural tracts and rural tracts
                         Note: Census tract characteristics were log transformed in all regression models.

                                                All Targeted PRF Allotments
                                          Pearson Correlation Coefficients (p-values)
                                             Nonrural Tracts (n = 55528 tracts)
 Census
 Tract      2020           2020                                                 % Non-
 Charact-   COVID          COVID         % Non-       % Non-       % Non-       Hispanic                     % Non-                  Distance
 eristics   Deaths         Deaths        Hispanic     Hispanic     Hispanic     Other        %               Hispanic    %           from
            (Jan–Jun)      (Jun–Dec)     AIAN         Asian        Black        Race         Hispanic        White       Poverty     hospital
 PRF per         0.637         0.015        -0.097        -0.034       0.136       -0.142       -0.088          -0.192      -0.030       -0.125
 Person
 p-value       <.0001          0.0006       <.0001       <.0001       <.0001       <.0001       <.0001         <.0001      <.0001       <.0001
                                                  Rural Tracts (n = 14814 tracts)
 Census     2020           2020                                                 % Non-
 Tract      COVID          COVID         % Non-       % Non-       % Non-       Hispanic                     % Non-                  Distance
 Charact-   Deaths         Deaths        Hispanic     Hispanic     Hispanic     Other        %               Hispanic    %           from
 eristics   (Jan–Jun)      (Jun–Dec)     AIAN         Asian        Black        Race         Hispanic        White       Poverty     hospital
 PRF per         0.021         0.082         0.072        -0.101       0.021       -0.072       -0.154          -0.060       0.040       -0.251
 Person
 p-value       0.0113         <.0001        <.0001       <.0001       0.0096       <.0001       <.0001         <.0001      <.0001       <.0001



                     We also calculated correlation coefficients between PRF per person and community
                     characteristics for each individual Targeted PRF allotment. Exhibits 11-14 show those
                     correlation coefficients for High Impact Hospitals, Safety Net Hospitals, Rural
                     Hospitals, and Tribal Hospitals allotments. We calculated correlation coefficients
                     separately for nonrural and rural census tracts.




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                          Exhibit 11: Results for correlation analysis for High Impact Hospitals
                          allotments in nonrural tracts and rural tracts
                          Note: Census tract characteristics were log transformed in all regression models.

                                                 High Impact Hospitals Allotments
                                              Pearson Correlation Coefficients (p-values)
                                                 Nonrural Tracts (n = 55528 tracts)
 Census
 Tract        2020          2020                                                 % Non-
 Charact-     COVID         COVID            % Non-     % Non-      % Non-       Hispanic                  % Non-                     Distance
 eristics     Deaths        Deaths           Hispani    Hispanic    Hispanic     Other        %            Hispanic                   from
              (Jan–Jun)     (Jun–Dec)        c AIAN     Asian       Black        Race         Hispanic     White        % Poverty     hospital
 PRF per          0.795          -0.024        -0.159       0.060       0.156       -0.142       -0.009       -0.186        -0.104         -0.139
 Person
 p-values       <.0001          <.0001        <.0001       <.0001       <.0001       <.0001       0.0343       <.0001      <.0001         <.0001
                                                    Rural Tracts (n = 14814 tracts)
 Census       2020          2020                                                 % Non-
 Tract        COVID         COVID            % Non-     % Non-      % Non-       Hispanic                  % Non-                     Distance
 Charact-     Deaths        Deaths           Hispani    Hispanic    Hispanic     Other        %            Hispanic                   from
 eristics     (Jan–Jun)     (Jun–Dec)        c AIAN     Asian       Black        Race         Hispanic     White        % Poverty     hospital
 PRF per          0.514          0.096         -0.102      -0.029       0.286       -0.101       -0.029       -0.164        -0.046          0.007
 Person
 p-values       <.0001          <.0001        <.0001       0.0004       <.0001       <.0001       0.0004       <.0001      <.0001         0.3739




                          Exhibit 12: Results for correlation analysis for Safety Net Hospitals allotments
                          in nonrural tracts and rural tracts
                          Note: Census tract characteristics were log transformed in all regression models.

                                                  Safety Net Hospitals Allotments
                                              Pearson Correlation Coefficients (p-values)
                                                 Nonrural Tracts (n = 55528 tracts)
 Census
 Tract        2020             2020                                                   % Non-
 Charact-     COVID            COVID           % Non-       % Non-       % Non-       Hispanic                  % Non-                 Distance
 eristics     Deaths           Deaths          Hispanic     Hispanic     Hispanic     Other        %            Hispanic   %           from
              (Jan – Jun)      (Jun – Dec)     AIAN         Asian        Black        Race         Hispanic     White      Poverty     hospital
 PRF per            0.264            0.044        -0.029       -0.018        0.153       -0.068        0.017      -0.224      0.093       -0.133
 Person
 p-values         <.0001           <.0001         <.0001      <.0001       <.0001       <.0001       <.0001       <.0001     <.0001       <.0001
                                                    Rural Tracts (n = 14814 tracts)
 Census       2020             2020                                                   % Non-
 Tract        COVID            COVID           % Non-       % Non-       % Non-       Hispanic                  % Non-                 Distance
 Characteri   Deaths           Deaths          Hispanic     Hispanic     Hispanic     Other        %            Hispanic   %           from
 stics        (Jan – Jun)      (Jun - Dec      AIAN         Asian        Black        Race         Hispanic     White      Poverty     hospital)
 PRF per            0.118            0.057        -0.032       -0.078        0.234       -0.020       -0.066      -0.124      0.191        0.003
 Person
 p-values         <.0001           <.0001         <.0001      <.0001       <.0001         0.015      <.0001       <.0001     <.0001       0.7052




Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of
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                         Exhibit 13: Results for correlation analysis for Rural Hospitals allotments in
                         nonrural tracts and rural tracts
                         Note: Census tract characteristics were log transformed in all regression models.

                                                  Rural Hospitals Allotments
                                            Pearson Correlation Coefficients (p-values)
                                               Nonrural Tracts (n = 55528 tracts)
 Census
 tract       2020           2020                                                  % Non-
 Charact-    COVID          COVID           % Non-        % Non-     % Non-       Hispanic                   % Non-                     Distance
 eristics    Deaths         Deaths          Hispanic      Hispanic   Hispanic     Other       %              Hispanic      %            from
             (Jan–Jun)      (Jun – Dec)     AIAN          Asian      Black        Race        Hispanic       White         Poverty      hospital
 PRF per         -0.348           0.137          0.140      -0.314      -0.198       -0.056      -0.319          0.271        -0.032        0.252
 Person
 p-values       <.0001          <.0001         <.0001       <.0001      <.0001      <.0001       <.0001        <.0001         <.0001       <.0001
                                                     Rural Tracts (n = 14814 tracts)
 Census      2020           2020                                                  % Non-
 Tract       COVID          COVID           % Non-        % Non-     % Non-       Hispanic                   % Non-                     Distance
 Character   Deaths         Deaths          Hispanic      Hispanic   Hispanic     Other       %              Hispanic      %            from
 istics      (Jan – Jun)    (Jun – Dec)     AIAN          Asian      Black        Race        Hispanic       White         Poverty      hospital
 PRF per          -0.167          0.074          0.015      -0.097      -0.117       -0.065      -0.149          0.111         0.001       -0.310
 Person
 p-values       <.0001          <.0001          0.0763      <.0001      <.0001      <.0001       <.0001        <.0001         0.8842       <.0001




                         Exhibit 14: Results for correlation analysis for Tribal Hospitals allotments in
                         nonrural tracts and rural tracts
                         Note: Census tract characteristics were log transformed in all regression models.

                                                  Tribal Hospitals Allotments
                                            Pearson Correlation Coefficients (p-values)
                                               Nonrural Tracts (n = 55528 tracts)
 Census
 Tract       2020          2020                                               % Non-
 Charact-    COVID         COVID          % Non-      % Non-      % Non-      Hispanic                    % Non-                       Distance
 eristics    Deaths        Deaths         Hispanic    Hispanic    Hispanic    Other       %               Hispanic                     from
             (Jan–Jun)     (Jun–Dec)      AIAN        Asian       Black       Race        Hispanic        White          % Poverty     hospital
 PRF per        -0.092         0.062         0.448       -0.035      -0.055       0.079        0.057          0.037           0.037          0.001
 Person
 p-values      <.0001         <.0001       <.0001        <.0001      <.0001      <.0001       <.0001         <.0001         <.0001         0.8141
                                                     Rural Tracts (n = 14814 tracts)
 Census      2020          2020                                               % Non-
 Tract       COVID         COVID          % Non-      % Non-      % Non-      Hispanic                    % Non-                       Distance
 Charact-    Deaths        Deaths         Hispanic    Hispanic    Hispanic    Other       %               Hispanic                     from
 eristics    (Jan–Jun)     (Jun–Dec)      AIAN        Asian       Black       Race        Hispanic        White          % Poverty     hospital
 PRF per        -0.008         -0.008        0.641        0.015      -0.067       0.262        0.044         -0.283           0.104          0.045
 Person
 p-values      0.3218         0.3462       <.0001        0.0673      <.0001      <.0001       <.0001         <.0001         <.0001         <.0001




Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of
Populations Served                                                                                                30
OEI-05-20-00580
                     Regression Analysis Results

                     We used multivariable linear regressions to determine if the relationships we
                     identified in the correlation analyses remain when all the census tract characteristics
                     are included in a single model. Our regressions control for COVID-19 deaths in
                     January 22-June 10, 2020, and June 11-December 31, 2020, distance to the nearest
                     hospital, and the census tract social factors (proportion of each race/ethnicity group,
                     proportion of population experiencing poverty) to understand which factors were
                     related to PRF per person while controlling for the other factors in the model. We log
                     transformed both the dependent and independent variables in all regressions to
                     reduce the influence of outliers. We report regression results for the five different
                     outcomes: all Targeted PRF allotments per person and each of the four individual
                     allotments per person (High Impact Hospitals, Safety Net Hospitals, Rural Hospitals,
                     and Tribal Hospitals). In addition to examining all tracts in a single model, we
                     modeled the relationships by HRSA designation.

                     It should be noted that the variation in PRF per person is more fully explained by the
                     included community characteristics for the High Impact Hospitals, Tribal and Rural
                     Hospitals allotments and less well explained in the models for Safety Net Hospitals
                     allotments as indicated by the Adjusted R-Squared values. We also tested alternative
                     models for Rural, Tribal and Safety Net Hospitals that received PRF in those
                     allocations. This substantially improved the Adjusted R-Squared for the Safety Net
                     Hospitals models, but the resulting set of independent variables would have been
                     different from the models for High Impact Hospitals. Results in Exhibits 15-19 should
                     be interpreted with this limitation of the models in mind.

                     Exhibit 15: Linear regression model results for all Targeted PRF allotments
                     Note: Census tract characteristics and PRF per person were log transformed in all regression models.

                                          All Targeted PRF Allotments
                               Linear Regression Model of Targeted PRF per Person
                                                Nonrural                                                 Rural
                                            (n =55528 tracts)                                      (n = 14814 tracts)
                             Estimate           Std. Error        p-value            Estimate          Std. Error           p-value
 Intercept                              3.488             0.040             <.0001             5.928             0.046                <.0001
 COVID-19 Deaths Jan-Jun                0.550             0.003             <.0001             0.009             0.004                0.0345
 COVID-19 Deaths Jun-Dec               -0.061             0.008             <.0001             0.028             0.006                <.0001
 % Non-Hispanic AI/AN                   0.043             0.010             <.0001             0.140             0.008                <.0001
 % Non-Hispanic Asian/PI               -0.074             0.004             <.0001            -0.133             0.011                <.0001
 % Non-Hispanic Black                   0.045             0.003             <.0001            -0.012             0.005                0.0226
 % Non-Hispanic Other Race             -0.163             0.006             <.0001            -0.111             0.010                <.0001
 % Hispanic/Latino                     -0.070             0.004             <.0001            -0.125             0.005                <.0001
 % Poverty Rate                        -0.057             0.006             <.0001             0.010             0.012                0.3751
 Distance                              -0.053             0.006             <.0001            -0.252             0.007                <.0001
 Adjusted R-Squared                                                         0.4273                                                    0.1359




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OEI-05-20-00580
                      Exhibit 16: Regression model results for High Impact Hospitals allotments
                      Note: Census tract characteristics and PRF per person were log transformed.

                                       High Impact Hospitals Allotments
                               Linear Regression Model of Targeted PRF per Person
                                                Nonrural                                                  Rural
                                            (n = 55528 tracts)                                      (n = 14814 tracts)
                             Estimate           Std. Error        p-value            Estimate          Std. Error            p-value
 Intercept                             1.636              0.045             <.0001             2.418             0.073                 <.0001
 COVID-19 Deaths Jan-Jun               0.988              0.003             <.0001             0.420             0.007                 <.0001
 COVID-19 Deaths Jun-Dec              -0.157              0.009             <.0001             0.018             0.010                 0.0722
 % Non-Hispanic AI/AN                 -0.077              0.011             <.0001            -0.017             0.013                 0.2035
 % Non-Hispanic Asian/PI              -0.035              0.005             <.0001            -0.038             0.018                  0.032
 % Non-Hispanic Black                  0.124              0.004             <.0001             0.211             0.008                 <.0001
 % Non-Hispanic Other Race            -0.245              0.007             <.0001            -0.117             0.016                 <.0001
 % Hispanic/Latino                     0.047              0.004             <.0001            -0.009             0.009                 0.3203
 % Poverty Rate                       -0.272              0.007             <.0001            -0.374             0.019                 <.0001
 Distance                              0.015              0.007             0.0391             0.044             0.010                 <.0001
 Adjusted R-Squared                                                          0.655                                                     0.3073



                      Exhibit 17: Linear regression model results for Safety Net Hospitals
                      allotments
                      Note: Census tract characteristics and PRF per person were log transformed in all regression models.

                                        Safety Net Hospitals Allotments
                               Linear Regression Model of Targeted PRF per Person
                                                Nonrural                                                  Rural
                                            (n = 55528 tracts)                                      (n = 14814 tracts)
                             Estimate           Std. Error        p-value            Estimate          Std. Error            p-value
 Intercept                             2.331              0.057             <.0001             2.150             0.085                 <.0001
 COVID-19 Deaths Jan-Jun               0.232              0.004             <.0001             0.052             0.008                 <.0001
 COVID-19 Deaths Jun-Dec               0.030              0.011             0.0051            -0.008             0.012                 0.4744
 % Non-Hispanic AI/AN                  0.046              0.013             0.0005            -0.031             0.016                 0.0451
 % Non-Hispanic Asian/PI              -0.016              0.006             0.0066            -0.117             0.021                 <.0001
 % Non-Hispanic Black                  0.090              0.005             <.0001             0.180             0.010                 <.0001
 % Non-Hispanic Other Race            -0.118              0.009             <.0001            -0.011             0.019                 0.5697
 % Hispanic/Latino                    -0.006              0.005             0.1873            -0.085             0.010                 <.0001
 % Poverty Rate                        0.060              0.008             <.0001             0.326             0.022                 <.0001
 Distance                             -0.131              0.009             <.0001             0.042             0.012                 0.0006
 Adjusted R-Squared                                                         0.0921                                                     0.0789




Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of
Populations Served                                                                                                32
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                      Exhibit 18: Linear regression model results for Rural Hospitals allotments
                      Note: Census tract characteristics and PRF per person were log transformed in all regression models.

                                           Rural Hospitals Allotments
                               Linear Regression Model of Targeted PRF per Person
                                                Nonrural                                                 Rural
                                            (n = 55528 tracts)                                     (n = 14814 tracts)
                             Estimate           Std. Error        p-value            Estimate          Std. Error            p-value
 Intercept                             1.561              0.042             <.0001             5.918             0.059                 <.0001
 COVID-19 Deaths Jan-Jun              -0.229              0.003             <.0001            -0.103             0.005                 <.0001
 COVID-19 Deaths Jun-Dec               0.220              0.008             <.0001             0.065             0.008                 <.0001
 % Non-Hispanic AI/AN                  0.250              0.010             <.0001             0.069             0.011                 <.0001
 % Non-Hispanic Asian/PI              -0.203              0.004             <.0001            -0.190             0.014                 <.0001
 % Non-Hispanic Black                 -0.160              0.003             <.0001            -0.110             0.007                 <.0001
 % Non-Hispanic Other Race             0.016              0.007             0.0135            -0.111             0.013                 <.0001
 % Hispanic/Latino                    -0.277              0.004             <.0001            -0.167             0.007                 <.0001
 % Poverty Rate                        0.084              0.006             <.0001             0.042             0.015                  0.006
 Distance                              0.117              0.007             <.0001            -0.421             0.009                 <.0001
 Adjusted R-Squared                                                         0.3285                                                     0.2021



                      Exhibit 19: Linear regression model results for Tribal Hospitals allotments
                      Note: Census tract characteristics and PRF per person were log transformed in all regression models.

                                          Tribal Hospitals Allotments
                               Linear Regression Model of Targeted PRF per Person
                                                Nonrural                                                 Rural
                                            (n = 55528 tracts)                                     (n = 14814 tracts)
                             Estimate           Std. Error        p-value            Estimate          Std. Error            p-value
 Intercept                           -0.123               0.010             <.0001           -0.392              0.035                 <.0001
 COVID-19 Deaths Jan-Jun             -0.003               0.001             <.0001            0.026              0.003                 <.0001
 COVID-19 Deaths Jun-Dec              0.030               0.002             <.0001            0.019              0.005                 <.0001
 % Non-Hispanic AI/AN                 0.262               0.002             <.0001            0.578              0.006                 <.0001
 % Non-Hispanic Asian/PI             -0.008               0.001             <.0001           -0.031              0.008                 0.0002
 % Non-Hispanic Black                -0.008               0.001             <.0001           -0.021              0.004                 <.0001
 % Non-Hispanic Other Race            0.019               0.002             <.0001            0.103              0.008                 <.0001
 % Hispanic/Latino                    0.009               0.001             <.0001           -0.008              0.004                 0.0704
 % Poverty Rate                      -0.005               0.001             0.0003            0.047              0.009                 <.0001
 Distance                            -0.005               0.002             0.0016            0.009              0.005                 0.0625
 Adjusted R-Squared                                                         0.2101                                                     0.4209




Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of
Populations Served                                                                                                33
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                     Stepwise Regression Analysis for All Targeted PRF Allotments

                     To better understand the relationship between proportion of Hispanic/Latino
                     residents in a census tract and PRF and proportion of Non-Hispanic Black residents
                     and PRF, we performed stepwise regression analysis on all Targeted PRF allotments.
                     For both nonrural and rural census tracts, we started with a model including variables
                     for race, ethnicity, and poverty, and then added controls to the model in steps to
                     observe how estimates in the model changed.

                     In Exhibit 20, you can see that there is a positive correlation between the proportion
                     of Non-Hispanic Black residents and PRF per person in nonrural census tracts when
                     only race/ethnicity and poverty variables are included in the model. However, the
                     estimate associated with proportion of Non-Hispanic Black residents decreases
                     dramatically when the COVID-19 death rate variables are introduced to the model.
                     This indicates that although higher proportions of Non-Hispanic Black residents are
                     associated with higher PRF per person in nonrural census tracts, this relationship can
                     be partially explained by the positive association between COVID-19 death rates and
                     PRF per person in All Targeted PRF Allotments combined.

                     In both Exhibits 20 and 21 (both nonrural and rural census tracts), you can see that
                     the estimate associated with proportion of Hispanic/Latino residents does not change
                     meaningfully when the COVID-19 death rate variables are introduced to the model.
                     This indicates that the difference in PRF per person between high-Hispanic/Latino and
                     low-Hispanic/Latino communities cannot be explained by low COVID-19 impact in
                     areas with greater concentrations of Hispanic/Latino residents.

                     Exhibit 20: Stepwise regression model results for all Targeted PRF allotments
                     in nonrural census tracts
                     Note: Census tract characteristics and PRF per person were log transformed in all regression models.

                                        All Targeted PRF Allotments
                             Stepwise Regression Model of Targeted PRF per Person
                                                             Nonrural Tracts (n = 55528 tracts)
                             Step 1 (No COVID-19                Step 2 (Include COVID-19    Step 3 (Include COVID-19
                             Deaths and Distance)               Deaths; No Distance)        Deaths and Distance)
                             Estimate    Std.         p-value     Estimate     Std.        p-value     Estimate     Std.        p-value
                                         Error                                 Error                                Error
 Intercept                       4.817       0.020      <.0001        3.333        0.036     <.0001        3.488        0.040     <.0001
 % Non-Hispanic AI/AN           -0.158       0.012      <.0001        0.043        0.010     <.0001        0.043        0.010     <.0001
 % Non-Hispanic Asian/PI         0.027       0.005      <.0001       -0.067        0.004     <.0001       -0.074        0.004     <.0001
 % Non-Hispanic Black            0.171       0.004      <.0001        0.047        0.003     <.0001        0.045        0.003     <.0001
 % Non-Hispanic Other Race      -0.307       0.008      <.0001       -0.161        0.006     <.0001       -0.163        0.006     <.0001
 % Hispanic/Latino              -0.070       0.004      <.0001       -0.067        0.003     <.0001       -0.070        0.004     <.0001
 % Poverty Rate                 -0.135       0.007      <.0001       -0.046        0.006     <.0001       -0.057        0.006     <.0001
 COVID-19 Deaths Jan-Jun                                              0.555        0.003     <.0001        0.550        0.003     <.0001
 COVID-19 Deaths Jun-Dec                                             -0.061        0.008     <.0001       -0.061        0.008     <.0001
 Distance                                                                                                 -0.053        0.006     <.0001
 Adjusted R-Squared                                       0.064                               0.427                                0.427



Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of
Populations Served                                                                                                34
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                      Exhibit 21: Stepwise regression model results for all Targeted PRF
                      allotments in rural census tracts
                      Note: Census tract characteristics and PRF per person were log transformed in all regression models.

                                        All Targeted PRF Allotments
                             Stepwise Regression Model of Targeted PRF per Person
                                                                 Rural Tracts (n = 14814 tracts)
                            Step 1 (No COVID-19                    Step 2 (Include COVID-19      Step 3 (Include COVID-19
                            Deaths and Distance)                   Deaths; No Distance)         Deaths and Distance)
                            Estimate    Std.         p-value       Estimate   Std.        p-value      Estimate    Std.        p-value
                                        Error                                 Error                                Error
 Intercept                      5.330       0.033      <.0001         5.125       0.043      <.0001        5.928       0.046     <.0001
 % Non-Hispanic AI/AN           0.112       0.009      <.0001         0.111       0.009      <.0001        0.140       0.008     <.0001
 % Non-Hispanic Asian/PI       -0.080       0.011      <.0001        -0.069       0.012      <.0001       -0.133       0.011     <.0001
 % Non-Hispanic Black           0.012       0.005      0.0214         0.003       0.006      0.5816       -0.012       0.005     0.0226
 % Non-Hispanic Other          -0.099       0.011      <.0001        -0.088       0.011      <.0001       -0.111       0.010     <.0001
 Race
 % Hispanic/Latino             -0.104       0.006      <.0001        -0.106       0.006      <.0001       -0.125       0.005     <.0001
 % Poverty Rate                 0.049       0.012      <.0001         0.046       0.012      0.0002        0.010       0.012     0.3751
 COVID-19 Deaths Jan-Jun                                              0.008       0.004      0.0744        0.009       0.004     0.0345
 COVID-19 Deaths Jun-Dec                                              0.047       0.007      <.0001        0.028       0.006     <.0001
 Distance                                                                                                 -0.252       0.007     <.0001
 Adjusted R-Squared                                      0.042                                0.048                               0.133




Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of
Populations Served                                                                                                35
OEI-05-20-00580
ACKNOWLEDGMENTS AND CONTACT

        Acknowledgments
                     Samantha Handel-Meyer and Hilary Slover served as the team leaders for this study,
                     and Thaddeus Chatto served as the lead analyst. Others in the Office of Evaluation
                     and Inspections Regional Offices who conducted the study include Rebecca Gorges
                     and Brianna Weldon. Office of Evaluation and Inspections headquarters staff who
                     provided support include Althea Hosein, Robert Gibbons, Michael Novello, and Sarah
                     Swisher.

                     We would also like to acknowledge the contributions of other Office of Inspector
                     General staff, including Elina Breton, Bianca Hernandez, Justin Koppa, and Jason Lee.

                     This report was prepared under the direction of Laura Kordish, Regional Inspector
                     General for Evaluation and Inspections in the Chicago Regional Office, Adam
                     Freeman, Deputy Regional Inspector General, and Hilary Slover, Assistant Regional
                     Inspector General.


        Contact
                     To obtain additional information concerning this report, contact the Office of Public
                     Affairs at Public.Affairs@oig.hhs.gov. OIG reports and other information can be found
                     on the OIG website at oig.hhs.gov.

                     Office of Inspector General
                     U.S. Department of Health and Human Services
                     330 Independence Avenue, SW
                     Washington, DC 20201




Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of
Populations Served                                                                                                36
OEI-05-20-00580
ENDNOTES

1 Commonwealth Fund, Achieving Racial and Ethnic Equity in U.S. Health Care.     Accessed at Achieving Racial and Ethnic Equity
in U.S. Health Care: Scorecard | Commonwealth Fund on May 15, 2023.
2 CDC, COVID-19 in Racial and Ethnic Minority Groups.    Accessed at COVID-19 racial and ethnic health disparities : 1.
Introduction (cdc.gov) on November 6, 2020.
3 CNN, Black communities account for disproportionate number of COVID-19 deaths in the US, study finds.
                                                                                                     Accessed at Black
communities account for disproportionate number of Covid-19 deaths in the US, study finds | CNN on November 6, 2020.
4 Washington Post, The coronavirus is infecting and killing black Americans at an alarmingly high rate.
                                                                                                 Accessed at
https://www.washingtonpost.com/nation/2020/04/07/coronavirus-is-infecting-killing-black-americans-an-alarmingly-high-
rate-post-analysis-shows/ on November 6, 2020.
5 Brookings, Racial economic inequality amid the COVID-19 crisis.
                                                               Accessed at https://www.brookings.edu/research/racial-
economic-inequality-amid-the-covid-19-crisis/ on November 6, 2020.
6
  Pew Research Center, For U.S. Latinos, COVID-19 Has Taken a Personal and Financial Toll. Accessed at For U.S. Latinos,
COVID-19 Has Taken a Personal and Financial Toll | Pew Research Center on August 27 2021.
7 COVID-19 has had a disproportionate impact among high-poverty populations: National Center for Biotechnology

Information, Coronavirus infections and deaths by poverty status: The effects of social distancing. Accessed at
https://pubmed.ncbi.nlm.nih.gov/33362321/ on August 27, 2021.
8 HHS Office of Minority Health, Minority Health Social Vulnerability Index Overview.   Accessed at Minority Health Social
Vulnerability Index Overview (hhs.gov) on October 26, 2022.
9 CDC, CDC SVI 2018 Documentation.      Accessed at SVI2018Documentation_01192022_1.pdf (cdc.gov) on October 27, 2022.
10 Executive Order 13995, Ensuring an Equitable Pandemic Response and Recovery, Code of Federal Regulations, Vol. 86, No. 15

(enacted January 26, 2021).
11 HHS, HHS Equity Action Plan.   Accessed at HHS Equity Action Plan on May 16, 2021.
12 Coronavirus Aid, Relief, and Economic Security (CARES) Act, Div. B, tit. VIII, P.L. 116-136 (enacted March 27, 2020).

13 Ibid.


14 HRSA, Provider Relief Fund: General Information.   Accessed at CARES Act Provider Relief Fund: General Information |
HHS.gov on August 19, 2021.
15 HRSA, Provider Relief Fund Past Payments Targeted Distributions.  Accessed at Past Targeted Distributions | Official web site
of the U.S. Health Resources & Services Administration (hrsa.gov) on September 8, 2021.
16 HHS, Office of Minority Health, About COVID-19 Health Equity Task Force.     Accessed at Health Equity Task Force - The Office
of Minority Health (hhs.gov) on October 1, 2021.
17 HHS, Strategic Plan FY 2018 – 2022, Strategic Objective 2.4: Prepare for and respond to public health emergencies.
                                                                                                                   Accessed
at Strategic Goal 2: Protect the Health of Americans Where They Live, Learn, Work, and Play | HHS.gov on December 3, 2021.
18 CDC, Health Equity Considerations & Racial & Ethnic Minority Groups.     Accessed at Health Equity Considerations and Racial
and Ethnic Minority Groups | CDC on January 25, 2022.
19 HHS, HHS Equity Action Plan.   Accessed at HHS Equity Action Plan on May 16, 2021.

20 HHS, HHS Protect FAQ. Accessed at hhs-protect-faqs.pdf on October 25, 2021.

21 Ibid.




Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of
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22 U.S. Census Bureau, Why We Ask Each Question About / Race, Accessed at Race | American Community Survey | U.S. Census

Bureau on June 11 2023.
23 U.S. Census Bureau, Questionnaire Archive. Accessed at https://www.census.gov/programs-

surveys/acs/methodology/questionnaire-archive.2019.html at on October 7, 2021.
24 HRSA, Defining Rural Population. Accessed at Defining Rural Population | HRSA on April 8, 2022.

25 USA Facts, About USAFacts.   Accessed at https://usafacts.org/about-usafacts/ on October 21, 2021.
26 USA Facts, Detailed Methodology and Sources: COVID-19 Data.        Accessed at https://usafacts.org/articles/detailed-
methodology-covid-19-data/ on November 12, 2020.
27 HHS, COVID-19 Guidance for Hospital Reporting and FAQs For Hospitals, Hospitals Laboratory, and Acute Care Facility Data

Reporting. Accessed at covid-19-faqs-hospitals-hospital-laboratory-acute-care-facility-data-reporting.pdf< (hhs.gov) on
October 25, 2021.
28 Journal of American Medical Association, Allocation of COVID-19 Relief Funding to Disproportionately Black Counties.

Accessed at Allocation of COVID-19 Relief Funding to Disproportionately Black Counties | Health Disparities | JAMA | JAMA
Network on August 25, 2021.
29 Journal of Health Politics, Policy and Law, Duke University Press, Unsanitized and Unfair: How COVID-19 Bailout Funds Refuel

Inequity in the US Health Care System. Accessed at Unsanitized and Unfair: How COVID-19 Bailout Funds Refuel Inequity in the
US Health Care System | Journal of Health Politics, Policy and Law | Duke University Press (dukeupress.edu) on November 29,
2021.
30 KFF, Changes in Health Coverage by Race and Ethnicity since the ACA, 2010-2018.
                                                                                 Accessed at https://www.kff.org/racial-
equity-and-health-policy/issue-brief/changes-in-health-coverage-by-race-and-ethnicity-since-the-aca-2010-2018/ on March
5, 2020.
31 CARES Act, Div. B, tit. VIII, P.L. 116-136 (enacted March 27, 2020).

32 Paycheck Protection Program and Health Care Enhancement Act, Div. B, tit. I, P.L. 116–139 (enacted April 24, 2020).

33 Coronavirus Response and Relief Supplemental Appropriations Act, 2021, Div. M, tit. III, P.L. 116-260 (enacted December 27,

2020).
34 CARES Act, Div. B, tit. VIII, P.L. 116-136 (enacted March 27, 2020).

35 Ibid.

36 HRSA, COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine

Administration for the Uninsured. Accessed at COVID-19 Claims Reimbursement to Health Care Providers and Facilities for
Testing, Treatment, and Vaccine Administration for the Uninsured | Official web site of the U.S. Health Resources & Services
Administration (hrsa.gov) on January 27, 2022.
37 HRSA, COVID-19 Coverage Assistance Fund.   Accessed at COVID-19 Coverage Assistance Fund | Official web site of the U.S.
Health Resources & Services Administration (hrsa.gov) on January 27, 2022.
38 HRSA, Provider Relief Fund Past Payments General Distributions. Accessed at Past General Distributions | Official web site of
the U.S. Health Resources & Services Administration (hrsa.gov) on September 8, 2021.
39 Ibid.

40 HRSA, Provider Relief Funds Future Payments.Accessed at Future Payments | Official web site of the U.S. Health Resources
& Services Administration (hrsa.gov) on September 15, 2021.
41 HRSA, Provider Relief Fund Past Payments General Distributions. Accessed at Past General Distributions | Official web site of
the U.S. Health Resources & Services Administration (hrsa.gov) on September 8, 2021.
42 Ibid.


43 Ibid.




Targeted Provider Relief Funds Allocated to Hospitals Had Some Differences with Respect to the Ethnicity and Race of
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OEI-05-20-00580
44 HRSA, Provider Relief Fund 3: Payment Calculation Methodology.         Accessed at Provider Relief Fund Phase 3: Payment
Calculation Methodology (hrsa.gov) on February 7, 2022.
45 HRSA, Provider Relief Funds Future Payments. Accessed at Future Payments | Official web site of the U.S. Health Resources
& Services Administration (hrsa.gov) on October 25, 2022.
46 In March 2020, hospitals reported substantial challenges with mitigation strategies, and needs for assistance related to

personal protective equipment (PPE), testing, staffing, supplies and durable equipment; maintaining or expanding facility
capacity; and financial concerns. OEI-06-20-00300.
47 HHS Press Release, HHS to Begin Immediate Delivery of Initial $30 Billion of CARES Act Provider Relief Funding.   Accessed at
2020-12-31 08:51 | Archive of HHS.gov (pagefreezer.com) on January 14, 2022.
48 CARES Act, Div. B, tit. VIII, P.L. 116-136 (enacted March 27, 2020).

49 HRSA, Provider Relief Fund General Information. Accessed at Provider Relief Fund General Information | Official web site of
the U.S. Health Resources & Services Administration (hrsa.gov) on September 17, 2021.
50 HRSA, Provider Relief Fund Past Payments Targeted Distributions.  Accessed at Past Targeted Distributions | Official web site
of the U.S. Health Resources & Services Administration (hrsa.gov) on September 8, 2021.
51 Ibid.


52 Ibid.

53 Ibid.


54 Ibid.

55 Ibid.


56 Ibid.

57 HRSA, Current and Future Payments.     Accessed at Current and Future Payments | HRSA on December 19, 2022.
58 Ibid.

59 OIG, HHS’s and HRSA’s Controls Related to Selected Provider Relief Fund Program Requirements Could Be Improved. Accessed

at HHS's and HRSA's Controls Related to Selected Provider Relief Fund Program Requirements Could Be Improved A-09-21-
06001 09-26-2022 on December 7, 2022.
60 USDA Economic Research Service, The COVID-19 Pandemic and Rural America.            Accessed at USDA ERS - The COVID-19
Pandemic and Rural America on August 17, 2021.




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