HHS Provider Relief Funds: It’s August what do I need to know?

August 20, 2020

Overview: Most providers received funds in April via EFT.  2nd round distribution began after providers attested, agreed to the Terms & Conditions, provided tax returns, and lost revenue data.   FYI if you did not apply for 2nd round money you may still apply until August 28th.  Yes, the deadline moved a few times.

  • General Information   

o   Who is eligible to receive payments from the Provider Relief Fund?  Providers who have billed Medicare or Medicaid fee-for-service in 2019 and provided diagnoses, testing, or care for individuals after Jan 312020.  (Documentation states individuals with possible or actual cases of COVID-19 and HHS clarified that they view all individuals as possible.)

o   Is it a grant or a loan?  If you meet the Terms & Conditions, there will be no repayment.

o   Is it considered taxable revenue? This has not been determined yet.

o   Funds may be used for:

  • Increased healthcare-related expenses attributable to coronavirus:
  • Supplies used to provide health care services
  • Equipment used to provide health care services
  • Workforce training
  • Acquiring additional resources, including facilities, equipment, supplies, health care practices, staffing, and technology to expand or preserve care delivery.
  • Lost revenue attributable to coronavirus. Calculated with any reasonable method.
  • HHS encourages the use of funds to cover lost revenue so that providers can maintain health care delivery. Funds can cover costs that would have otherwise been paid by the lost revenue to prevent, prepare, or respond to the coronavirus.

o   Employee or contractor payroll

o   Employee health insurance

o   Rent or mortgage payments

o   Equipment lease payments

o   Electronic health record licensing fees

  • Expenses cannot be reimbursed from other sources.  (Example: You may not list the same payroll dates on a PPP forgiveness application and HHS reports.)
  • Funds may not be used for Executive Level Salary (those over $197,300).
  • If the extra expenses to respond to COVID and the lost revenue do not exceed the HHS payment you may have to send extra funds back.
  • How Distribution Worked 

o   Phase 1: To distribute funds quickly, HHS distributed Phase 1 funds proportional to Medicare payments received.

o   Applying for further funds: You needed to login to the HHS link, verify receipt of payment, submit tax documents, and apply for further funds.  There have been many dues dates for this, and the current deadline is August 28th.

o   Phase 2:  Payments are determined based on the lesser of 2% of a provider’s 2018 gross receipts or the sum of incurred losses for March and April. If Phase 1 payment was at least 2% you may not receive additional funds.

o   The deadline has been extended for Phase 2 to Aug 28th.

  • Reporting & Auditing

o   HHS funds have always been subject to reporting & auditing.  As outlined in the Terms & Conditions providers attested that they would follow all reporting instructions.

o   On August 14th HHS released General and Targeted Distribution Post-Payment Notice of Reporting Requirement with the following information.  https://www.hhs.gov/sites/default/files/provider-post-payment-notice-of-reporting-requirements.pdf

  • Who: Any provider or entity that received more than $10,000.
  • What: Outlines the timing of future reporting requirements.
  • Provider Responsibility: Maintain appropriate records and cost documentation.  Be accurate and truthful.  Submit the necessary reports. Maintain records for three years.
  • Reporting Instructions: Detailed instructions regarding these reports will be released soon. Those who deliberately misrepresent or falsify information in reports will have consequences.
  • When:
  • The reporting system will open on October 1, 2020.
  • 1st report is due Feb 15, 2021. Include expenditures through December 31, 2020.
  • If all funds have been spent in 2020 you may submit a single final report between Oct 1st and Feb 15th.
  • If funds are spent in 2021 you must submit a second and final report before July 31, 2021.
  • I have more questions… What if I got less than $10,000? How do I document? What reports do I need to submit?  There is no answer yet.  They have promised more information soon.

Sources:  

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