IMPORTANT CARES Act Provider Relief Fund Update

Published in Government Relations on April 27, 2020

HHS has begun distributing the remaining $20 billion of the $50 billion general distribution to Medicare providers to augment providers’ allocations so that the whole $50 billion general distribution is allocated proportional to providers' share of 2018 net patient revenue. Medicare providers for whom HHS did not have adequate cost report data on file will need to submit their revenue information to the General Distribution Portal to be able to receive additional general distribution funds and agree to the Terms and Conditions for this additional distribution.

Here is a link to the PORTAL: https://covid19.linkhealth.com/docusign/#/step/1

Providers who received their additional money automatically will still need to submit their revenue information so that it can be verified via the portal. Click here for FAQs on the General Distribution Portal.

Here is a portion of the FAQ:

HHS will distribute additional moneys via “Targeted Distributions” aimed at providers who are disproportionally impacted by COVID or who have not received payments in the General Distribution.
Providers will only get a General Distribution payment if they billed Medicare in 2019 and provide or provided after January 31, 2020 diagnoses, testing, or care for individuals with possible or actual cases of COVID-19.
The Provider Relief Fund Application Portal has been deployed in order to collect information from providers who have already received General Distribution payments prior to April 24th 2020 at 5 pm EST.
The Provider Relief Fund Application Portal is collecting four pieces of information for use in allocating remaining General Distribution funds:

1) a provider’s “Gross Receipts or Sales” or “Program Service Revenue” as submitted on its federal income tax return;

2) the provider’s estimated revenue losses in March 2020 and April 2020 due to COVID;

3) a copy of the provider’s most recently filed federal income tax return;

4) a listing of the TINs any of the provider’s subsidiary organizations that have received relief funds but that DO NOT file separate tax returns.

This information may also be used in allocating other Provider Relief Fund distributions.
We are collecting the “gross receipt or sales” or “program service revenue” data to have an understanding of a provider’s usual operations. We are collecting the revenue loss information to have an understanding of COVID impact. We are collecting tax forms in order to verify the self-reported information. And we are collecting information about organizational structure and subsidiary TINs so that we do not overpay or underpay providers who file tax returns covering multiple legal entities (e.g. consolidated tax returns).

Providers meeting the following criteria are required to submit a separate portal application:

(a) Provider has received Provider Relief Fund payments as of 5:00 EST Friday April 24th AND

(b) Provider has filed a federal income tax return for 2017, 2018, or 2019.

As such, each entity that files a federal income tax return is required to file an application even if it is part of a provider group. However, a group of corporations that files one consolidated return will have only the tax return filer apply.
Each provider submitting an application is required to list the TINs of each subsidiary that (a) has received Provider Relief Fund payments as of 5:00 EST Friday April 24th AND (b) has not filed federal income tax returns for 2017, 2018, or 2019.
Do not list any subsidiary’s TIN that has filed a federal income tax return, because such subsidiary is required to submit a separate application.
The CARES Act Provider Relief Fund Payment Attestation Portal is now open. Providers who have been allocated a payment must sign an attestation confirming receipt of the funds and agree to the terms and conditions within 30 days of payment.
President Trump is providing support to healthcare providers fighting the COVID-19 pandemic. On March 27, 2020, the President signed the bipartisan CARES Act that provides $100 billion in relief funds to hospitals and other healthcare providers on the front lines of the coronavirus response. This funding will be used to support healthcare-related expenses or lost revenue attributable to COVID-19 and to ensure uninsured Americans can get testing and treatment for COVID-19.
In allocating the funds, the Administration is working to address both the economic harm across the entire healthcare system due to the stoppage of elective procedures, and addressing the economic impact on providers incurring additional expenses caring for COVID-19 patients, and to do so as quickly and transparently as possible.

$50 Billion General Allocation Summary

$50 billion of the Provider Relief Fund is allocated for general distribution to Medicare facilities and providers impacted by COVID-19, based on eligible providers' 2018 net patient revenue. The initial $30 billion was distributed between April 10 and April 17, and the remaining $20 billion is being distributed beginning Friday, April 24.

To expedite providers getting money as quickly as possible, $30 billion was distributed immediately, proportionate to providers' share of Medicare fee-for-service reimbursements in 2019. On Friday, April 10, $26 billion was delivered to bank accounts. The remaining $4 billion of the expedited $30 billion distribution was sent on April 17.
This simple formula used the data on-hand to get the money out the door as quickly as possible. The Administration was transparent and upfront additional funds would be going out quickly to help providers with a relatively small share of their revenue coming from Medicare fee-for-service, such as children's hospitals.
HHS will begin distribution of the remaining $20 billion of the general distribution to these providers on April 24 to augment their allocation so that the whole $50 billion general distribution is allocated proportional to providers' share of 2018 net patient revenue.
On April 24, a portion of providers will automatically be sent an advance payment based off the revenue data they submit in CMS cost reports. Providers without adequate cost report data on file will need to submit their revenue information to the General Distribution Portal for additional general distribution funds.
- Providers who receive their money automatically will still need to submit their revenue information so that it can be verified via the General Distribution Portal.
Payments will go out weekly, on a rolling basis, as information is validated, with the first wave being delivered at the end of this week (April 24, 2020).
Providers who receive funds from the general distribution have to sign an attestation confirming receipt of funds and agree to the terms and conditions of payment and confirm the CMS cost report. Click here to sign the attestation and accept the Terms and Conditions.
The Terms and Conditions also include other measures to help prevent fraud and misuse of the funds. All recipients will be required to submit documents sufficient to ensure that these funds were used for healthcare-related expenses or lost revenue attributable to coronavirus. There will be significant anti-fraud and auditing work done by HHS, including the work of the Office of the Inspector General.
President Trump is committed to ending surprise bills for patients. As part of this commitment, as a condition to receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a presumptive or actual 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.