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![CARES Act Provider Relief Fund
April 17, 2020
Page 2
CARES Act – Title VIII
§ $275M (available through FY 22)
§ To be transferred to HRSA for Ryan White HIV/AIDS Program ($90M); poison
control programs ($5M); and rural health initiatives ($180M)
§ $27B (available through FY24)
§ Secure vaccines, therapeutics, diagnostics, and necessary medical supplies;
develop medical surge capacity
§ Up to $16B for National Strategic Stockpile
§ $100B (available until expended)
§ “[T]o reimburse … providers for health care related expenses or lost revenues
that are attributable to coronavirus”
§ “[M]ay not be used to reimburse expenses or losses that have been
reimbursed from other sources or that other sources are obligated to
reimburse”
Public Health and Social Services Emergency Fund](https://image.slidesharecdn.com/pyaproviderrelieffundwebinar04-17-20-200505184123/75/Webinar-Provider-Relief-Fund-Payments-What-We-Know-What-We-Don-t-Know-What-To-Do-Now-3-2048.jpg)
![CARES Act Provider Relief Fund
April 17, 2020
Page 3
$100B Provider Relief Fund
1. Open to any entity that “provide[s] diagnoses, testing, or care for
individuals with possible or actual cases of COVID–19”
2. Must submit “an application that includes a statement justifying
the need of the provider for the payment”
3. HHS “shall, on a rolling basis, review applications and make
payments” from the fund
4. HHS shall make payments “in consideration of the most efficient
payment systems practicable to provide emergency payment”
5. Recipients must “submit reports and maintain documentation as
the Secretary determines are needed to ensure compliance with
conditions that are imposed by this paragraph….”
6. HHS must report to Congress every 60 days
568 Words (or $176M per word)](https://image.slidesharecdn.com/pyaproviderrelieffundwebinar04-17-20-200505184123/75/Webinar-Provider-Relief-Fund-Payments-What-We-Know-What-We-Don-t-Know-What-To-Do-Now-4-2048.jpg)
![CARES Act Provider Relief Fund
April 17, 2020
Page 11
Step 4 –Attestation
Checkbox # 1
§ I acknowledge receipt of [$amount] from the … Relief Fund, and accept the Terms
& Conditions.
§ If you received a payment from [the Relief Fund] and retain that payment for at
least 30 days without contacting HHS regarding remittance of those funds, you
are deemed to have accepted the following Terms & Conditions. This is not an
exhaustive list and you must comply with any other relevant statutes and
regulations, as applicable.
§ Your commitment to full compliance with all Terms and Conditions is material to
the Secretary’s decision to disburse these funds to you. Non-compliance with
any Term or Condition is grounds for the Secretary to recoup some or all of the
payment made from the Relief Fund.
§ In general, the requirements that apply to the recipient, also apply to
subrecipients and contractors under grants, unless an exception is specified.](https://image.slidesharecdn.com/pyaproviderrelieffundwebinar04-17-20-200505184123/75/Webinar-Provider-Relief-Fund-Payments-What-We-Know-What-We-Don-t-Know-What-To-Do-Now-12-2048.jpg)
![CARES Act Provider Relief Fund
April 17, 2020
Page 12
Step 4 –Attestation
Checkbox # 2
§ By receiving and accepting Relief Fund payment, you attest that in accordance
with the [CARES Act], you are eligible for this payment. You acknowledge that you
may be asked to submit to the review process established by [HHS], including its
contractor…to determine your eligibility for this payment.
§ Additionally, upon request by HHS, you will provide any and all information
related to the disposition or use of the funds received under Relief Fund for
auditing and/or reporting purposes.
§ I attest that I have the legal authority to act on behalf of the provider group that
has received payment under the Relief Fund.
§ For Electronic Funds Transfer/ACH Payments, HHS or its contractor may make
adjustments to the payment whenever a correction or change is required. For
example, if there is an error, you agree that HHS may correct the error
immediately and without notice. Such errors include, but are not limited to,
reversing an improper credit, and correction calculation and input errors. The
right to make adjustments are not subject to any limitations or time constraints,
except as required by law.](https://image.slidesharecdn.com/pyaproviderrelieffundwebinar04-17-20-200505184123/75/Webinar-Provider-Relief-Fund-Payments-What-We-Know-What-We-Don-t-Know-What-To-Do-Now-13-2048.jpg)
![CARES Act Provider Relief Fund
April 17, 2020
Page 13
Final Step - Accept/Reject Payment
Optum Pay - https://covid19.linkhealth.com/#/optum-pay-enrollment-agreement
“You hereby authorize us, acting directly or indirectly on behalf of [Payers] to credit
or debit the account(s) listed on your enrollment…, in connection with processing
transactions between you and any Payers.”](https://image.slidesharecdn.com/pyaproviderrelieffundwebinar04-17-20-200505184123/75/Webinar-Provider-Relief-Fund-Payments-What-We-Know-What-We-Don-t-Know-What-To-Do-Now-14-2048.jpg)
![CARES Act Provider Relief Fund
April 17, 2020
Page 21
What About the Other $70B?
§ On April 3, Secretary Azar stated “a portion of that funding [will be used]
to cover providers’ costs of delivering COVID-19 care for the uninsured” at
Medicare rates
§ Payments to be made through the National Disaster Medical System, but no
details have been provided
§ April 7 KFF analysis estimates these costs at $13.9 billion to $41.8 billion
§ Families First appropriated $1B for testing for uninsured also to be paid
through NDMS, but no details have been provided
§ To bill or not to bill?
§ HHS Relief Fund website
§ “The Administration is working rapidly on targeted distributions that will focus
on providers in areas particularly impacted by the COVID-19 outbreak, rural
providers, providers of services with lower shares of Medicare reimbursement
or who predominantly serve the Medicaid population, and providers
requesting reimbursement for the treatment of uninsured Americans.”](https://image.slidesharecdn.com/pyaproviderrelieffundwebinar04-17-20-200505184123/75/Webinar-Provider-Relief-Fund-Payments-What-We-Know-What-We-Don-t-Know-What-To-Do-Now-22-2048.jpg)
Uploaded byPYA, P.C.
Webinar: “Provider Relief Fund Payments – What We Know, What We Don’t Know, What To Do Now”
The document provides information on the $100 billion Provider Relief Fund established by the CARES Act to reimburse healthcare providers for expenses or lost revenues attributable to COVID-19. It summarizes that $30 billion has been distributed based on providers' 2019 Medicare billings, with no repayment obligation. It outlines the attestation process to accept funds within 30 days and confirms that providers must comply with terms including using funds only for COVID-19 care and not balance billing uninsured patients. The document advises on accounting, compliance, and tax implications of the relief funds.
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Webinar: “Provider Relief Fund Payments – What We Know, What We Don’t Know, What To Do Now”
- 1. April 17, 2020 CARESAct Provider Relief Fund What We Know, What We Don’t Know, What To Do Now Disclaimer: To the best of our knowledge, these answers were correct at the time of publication. Given the fluid situation, and with rapidly changing new guidance issued daily, be aware that these answers may no longer apply. Please visit our COVID-19 hub frequently for the latest information, as we are working diligently to put forth the most relevant helpful guidance as it becomes available. © PYA, P.C. All rights reserved.
- 2. CARES Act ProviderRelief Fund April 17, 2020 Page 1 Martie Ross Principal – Strategy & Integration [email protected] Lori Foley Principal – Compliance Advisory [email protected]
- 3. CARES Act ProviderRelief Fund April 17, 2020 Page 2 CARES Act – Title VIII § $275M (available through FY 22) § To be transferred to HRSA for Ryan White HIV/AIDS Program ($90M); poison control programs ($5M); and rural health initiatives ($180M) § $27B (available through FY24) § Secure vaccines, therapeutics, diagnostics, and necessary medical supplies; develop medical surge capacity § Up to $16B for National Strategic Stockpile § $100B (available until expended) § “[T]o reimburse … providers for health care related expenses or lost revenues that are attributable to coronavirus” § “[M]ay not be used to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse” Public Health and Social Services Emergency Fund
- 4. CARES Act ProviderRelief Fund April 17, 2020 Page 3 $100B Provider Relief Fund 1. Open to any entity that “provide[s] diagnoses, testing, or care for individuals with possible or actual cases of COVID–19” 2. Must submit “an application that includes a statement justifying the need of the provider for the payment” 3. HHS “shall, on a rolling basis, review applications and make payments” from the fund 4. HHS shall make payments “in consideration of the most efficient payment systems practicable to provide emergency payment” 5. Recipients must “submit reports and maintain documentation as the Secretary determines are needed to ensure compliance with conditions that are imposed by this paragraph….” 6. HHS must report to Congress every 60 days 568 Words (or $176M per word)
- 5. CARES Act ProviderRelief Fund April 17, 2020 Page 4 April 7 Coronavirus Task Force Briefing “And so this week we will be putting out another $30 billion which are grants. This is going to be based on Medicare revenue. There are no strings attached, so the healthcare providers that are receiving these dollars can essentially spend that in any way that they see fit. Also, this is going to be done in a very easy, simplified way for many of our healthcare providers. We actually do direct deposit with them and so those dollars will just go right into their bank accounts....”
- 6. CARES Act ProviderRelief Fund April 17, 2020 Page 5
- 7. CARES Act ProviderRelief Fund April 17, 2020 Page 6 Provider Relief Fund Payments § $30B distributed to all facilities and providers that billed Medicare in 2019 § Payments based on 6.2% of TIN’s 2019 Medicare payments § Distributed by UnitedHealth Group through direct deposit § Not a loan; not payment for services; no repayment obligation We haven’t received our payment yet - The amount we received was less than we expected - CARES Provider Relief Hotline - (866) 569-3522 Managed by UnitedHealth Group
- 8. CARES Act ProviderRelief Fund April 17, 2020 Page 7 Attestation § Within 30 days of receiving the payment, recipient must sign attestation confirming receipt of funds and agreeing to terms and conditions of payment § Alternatively, recipient may reject funds and remit full payment to HHS as instructed § Complete thru on-line portal which opened April 16 https://covid19.linkhealth.com/
- 9. CARES Act ProviderRelief Fund April 17, 2020 Page 8 Step 1 - Eligibility
- 10. CARES Act ProviderRelief Fund April 17, 2020 Page 9 Step 2 – Billing TINs
- 11. CARES Act ProviderRelief Fund April 17, 2020 Page 10 Step 3 – Verify Payment Information
- 12. CARES Act ProviderRelief Fund April 17, 2020 Page 11 Step 4 –Attestation Checkbox # 1 § I acknowledge receipt of [$amount] from the … Relief Fund, and accept the Terms & Conditions. § If you received a payment from [the Relief Fund] and retain that payment for at least 30 days without contacting HHS regarding remittance of those funds, you are deemed to have accepted the following Terms & Conditions. This is not an exhaustive list and you must comply with any other relevant statutes and regulations, as applicable. § Your commitment to full compliance with all Terms and Conditions is material to the Secretary’s decision to disburse these funds to you. Non-compliance with any Term or Condition is grounds for the Secretary to recoup some or all of the payment made from the Relief Fund. § In general, the requirements that apply to the recipient, also apply to subrecipients and contractors under grants, unless an exception is specified.
- 13. CARES Act ProviderRelief Fund April 17, 2020 Page 12 Step 4 –Attestation Checkbox # 2 § By receiving and accepting Relief Fund payment, you attest that in accordance with the [CARES Act], you are eligible for this payment. You acknowledge that you may be asked to submit to the review process established by [HHS], including its contractor…to determine your eligibility for this payment. § Additionally, upon request by HHS, you will provide any and all information related to the disposition or use of the funds received under Relief Fund for auditing and/or reporting purposes. § I attest that I have the legal authority to act on behalf of the provider group that has received payment under the Relief Fund. § For Electronic Funds Transfer/ACH Payments, HHS or its contractor may make adjustments to the payment whenever a correction or change is required. For example, if there is an error, you agree that HHS may correct the error immediately and without notice. Such errors include, but are not limited to, reversing an improper credit, and correction calculation and input errors. The right to make adjustments are not subject to any limitations or time constraints, except as required by law.
- 14. CARES Act ProviderRelief Fund April 17, 2020 Page 13 Final Step - Accept/Reject Payment Optum Pay - https://covid19.linkhealth.com/#/optum-pay-enrollment-agreement “You hereby authorize us, acting directly or indirectly on behalf of [Payers] to credit or debit the account(s) listed on your enrollment…, in connection with processing transactions between you and any Payers.”
- 15. CARES Act ProviderRelief Fund April 17, 2020 Page 14 Terms & Conditions § Certify that recipient provides “diagnoses, testing, or care for individuals with possible for actual cases of COVID-19” § HHS: “Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19.” § Certify that funds “will only be used to prevent, prepare for, and respond to coronavirus, and shall reimburse the Recipient only for health care related expenses or lost revenues that are attributable to coronavirus.” Page 1 of 10 https://www.hhs.gov/sites/default/files/relief-fund-payment-terms-and- conditions-04132020.pdf
- 16. CARES Act ProviderRelief Fund April 17, 2020 Page 15 More Terms & Conditions § Recipient will not use funds “to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse” § Recipient will not balance bill any out-of-network patient for COVID-19- related treatment § T&Cs do not address diagnosis and treatment for uninsured § Recipient will not use funds for any purpose for which CARES Act funds cannot be used § To pay individual salary in excess of $197,300 § To fund lobbying, abortion, embryonic research, needle exchange, ACORN, capture or procurement of wild chimpanzees, human trafficking § To do business with any entity that requires employees to sign confidentiality agreement prohibiting reporting of fraud, waste, or abuse to federal officials § To do business with a corporation that has unpaid Federal tax liability or has been convicted of a felony Federal criminal violation in preceding 24 months
- 17. CARES Act ProviderRelief Fund April 17, 2020 Page 16 Still More Terms & Conditions § Submit reports as HHS determines necessary to monitor T&C compliance § If receive ˃ $150,000 in federal funds for coronavirus response and related activities, submit quarterly reports to Pandemic Response Accountability Committee (PRAC) with detailed accounting of expenditures § Maintain records and cost documentation, including documentation required by 45 CFR §§ 75.302, 361-365 and by any future program instructions § Fully cooperate in all audits the Secretary, OIG, or PRAC conducts to ensure compliance with these Terms and Conditions.
- 18. CARES Act ProviderRelief Fund April 17, 2020 Page 17 Tax Implications § Currently no guidance that states the funds are excluded from gross income § Contrast with PPP that expressly states that forgiven amounts are not considered as taxable revenue § Conservative approach = assume the payments will be considered in gross income and recognized as taxable § Tax exempt entity – no taxable event § For profit entity – taxable event but unlikely to generate revenue in excess of expenses incurred § Stay tuned for additional guidance/rule making
- 19. CARES Act ProviderRelief Fund April 17, 2020 Page 18 Revenue Recognition § Funds are not loans, do not have to be repaid subject to terms and conditions § Funds should be recognized as revenue when received if the provider § believes it can meet the list of program criteria; § agrees to be bound by the terms and conditions; and § attests to such within 30 days of receipt of payment § Funds should be recorded as deferred revenue § If the provider is unsure of whether it can meet the program criteria § Until such time that the provider determines fulfillment of the criteria is likely to occur (and the probability of having to pay back the funds is unlikely).
- 20. CARES Act ProviderRelief Fund April 17, 2020 Page 19 Recording Revenue and Expenses § Create a separate general ledger account to record the Relief Fund payments. § Separate bank account? § Report Relief Fund revenues as a line item in operating revenues on the financial. § Use footnote disclosures to adequately explain the portion of revenue related to Relief Fund payments. § Consult your external auditors to discuss additional accounting for these payments.
- 21. CARES Act ProviderRelief Fund April 17, 2020 Page 20 Compliance Considerations § Establish a process to fully vet the requirements – known, implied, potential – of each funding mechanism to ensure the entity can comply with the requirements. § Designate informed individuals to monitor regularly for additional guidance, rules and regulations. § Update internal guidance, educate teams, modify policies and procedures accordingly. § Create a process to efficiently track sources and uses of funds to ensure compliance with spending requirements and attestations. § Prepare in advance for an audit.
- 22. CARES Act ProviderRelief Fund April 17, 2020 Page 21 What About the Other $70B? § On April 3, Secretary Azar stated “a portion of that funding [will be used] to cover providers’ costs of delivering COVID-19 care for the uninsured” at Medicare rates § Payments to be made through the National Disaster Medical System, but no details have been provided § April 7 KFF analysis estimates these costs at $13.9 billion to $41.8 billion § Families First appropriated $1B for testing for uninsured also to be paid through NDMS, but no details have been provided § To bill or not to bill? § HHS Relief Fund website § “The Administration is working rapidly on targeted distributions that will focus on providers in areas particularly impacted by the COVID-19 outbreak, rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.”
- 23. CARES Act ProviderRelief Fund April 17, 2020 Page 22 PYA Resources § Prior webinar recordings, slides, transcripts, follow-up Q&As § PYA thought leadership § Links to important resources www.pyapc.com/covid-19-hub/ Thank you, and stay well!