Has your medical practice or facility received one or more stimulus payments from the Provider Relief Fund? Many recipient healthcare providers are unsure of how to use or apply these payments, which are part of a $100 billion provision of the CARES Act intended to shore up healthcare providers on the front lines of the coronavirus response. In recent days, there have been many changes to the payment calculation and required provider information from HHS. Some details still remain ambiguous at the time of this writing.
RKL’s healthcare advisors are here to answer questions about the attestations, applications, payment calculations, and to help providers start tracking and prepare for reporting. Read on to learn more about the program requirements and what actions providers can start taking now.
Payment distribution and calculation
$50 billion of the Provider Relief Fund is allocated for Medicare facilities and providers as general distribution. The initial $30 billion was distributed on April 10, 2020 and April 17, 2020. These payments were calculated based on the provider’s share of total Medicare fee-for service 2019 reimbursements. The remaining $20 billion distribution began on April 24, 2020. These distributions were allocated proportionally to providers’ share of 2018 net revenue based on submitted cost report data. Providers without adequate cost report data on file AND providers who received their money automatically need to submit their revenue information on the HHS General Distribution Portal.
These payments are not loans; however, there are terms and conditions that recipient providers must agree to, including how to use the funds and routine reporting to the U.S. Department of Health and Human Services (HHS).
Terms and Conditions attestation and financial data submission
As a condition to receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.
Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. This attestation must be completed via the HHS CARES Act Provider Relief Fund Payment Attestation Portal.
Medicare providers who received a payment from the Provider Relief Fund on or before April 24, 2020 are now eligible to apply for additional funds by submitting data about their annual revenues and estimated coronavirus-related revenue losses to HHS. After attesting to the terms and conditions as described above, here’s what needs to be reported through the General Distribution Portal:
- The provider’s Gross Receipts or Sales or Program Service Revenue as submitted on the federal income tax return; and
- The provider’s estimated revenue losses in March 2020 and April 2020 due to COVID-19; and
- A copy of the provider’s most recently filed federal income tax return; and
- A listing of the taxpayer identification numbers any of the provider’s subsidiary organizations that have received relief funds but do not file separate tax returns.
Applications will be processed in batches every Wednesday at noon EST and HHS intends to distribute funds within 10 business days of submission.
Providers who have not received a payment should not use the portal and may still be eligible for payments through other mechanisms, including the remaining Targeted Allocations distributions from the Provider Relief Fund intended for uninsured treatment, areas of high coronavirus impact, rural providers, Indian Health Services, etc.
Payment use and required reporting
When agreeing to the terms and conditions, the healthcare provider certifies that the funds will only be used to prevent, prepare for and respond to coronavirus, or to reimburse the provider only for healthcare-related expenses or lost revenues attributable to coronavirus. Relief payments must not be used for reimbursement of expenses or losses that would otherwise be reimbursed from another source.
To document compliance, recipients of payments totaling more than $150,000 are required to prepare and submit routine reports to the HHS Secretary and the Pandemic Response Accountability Committee. Please note, the $150,000 total represents all funding received from any coronavirus relief packages, not just the Provider Relief Fund. The content of the report is outlined in the next section of this post. The exact format has yet to be clarified from HHS, but they will be due no more than 10 days after the end of each calendar quarter.
This reporting requirement makes tracking all the more essential. If not already, providers should immediately start tracking expenses and lost revenue attributed to coronavirus. Even providers not actively treating COVID-19 patients have felt an impact. Whether it is the cost of PPE, staff for a new screening area or holding off on admissions, providers have likely had a financial burden related to the pandemic.
What to track
The quarterly reports for HHS and the Pandemic Response Accountability Committee must contain the following data points:
- Total amount of funding received from HHS under one or more of the federal coronavirus response and relief package
- Breakdown of relief funds spent or obligated by project or activity
- Detailed list of all projects or activities for which relief funds were spent or obligated, including name, description and estimated number of jobs created or retained (if applicable)
- Detailed information on any subcontracts or subgrants awarded by the relief recipient or its subcontractors or subgrantees
- Confirmation that lost revenue or expenses tracked would not have been reimbursed from other sources
Action items for recipients
Providers who have received funds should confirm receipt of the payment and read and attest to the terms and conditions through the CARES Act Provider Relief Fund Payment Attestation Portal. Then, recipients should attest to each payment and apply for additional funds through the General Distribution Portal.
Recipients should also start keeping records now to document how Provider Relief Fund payments are spent. Providers should also consider establishing a separate bank account and setting up a general ledger mechanism to track payments. RKL’s Senior Living Services Consulting Group is preparing a model to assist healthcare providers with Provider Relief payment tracking and allocation of funds stemming from coronavirus-related revenue losses and expenses. Contact your RKL advisor for assistance and support with this tracking and reporting requirement.