April 24, 2020
As previously detailed in our April 16, 2020
email
, the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) provides $100 billion in relief funds (the “Fund”) to hospitals and other healthcare providers on the front lines of the COVID-19 response. The Department of Health and Human Services (“HHS”) announced additional information about how the general and targeted allocations from the Fund will be made and how to participate. On April 23, 2020,
HHS extended the deadline for hospitals to apply for an allocation of the Fund
.
What does the general allocation from the Fund entail?
$50 billion of the Fund is allocated for general distribution to Medicare facilities and providers based on the 2018 net patient revenue of the eligible providers. HHS has already distributed the initial $30 billion from the Fund to eligible healthcare providers via direct deposit, proportionate to the providers’ share of Medicare fee-for-service reimbursements in 2019. The remaining $20 billion will begin to be distributed on April 24, 2020 with a portion being automatically sent to providers as advance payment based off of the revenue data the providers submitted in their Centers for Medicare & Medicaid Services (“CMS”) costs reports. If a provider does not have adequate cost report data on file, the providers will need to submit their revenue information to a portal opening this week. Payments will go out weekly, on a rolling basis. As a reminder, healthcare providers must accept certain terms as a condition to keep funds received from the Fund.
What must be done after payment is received from the general allocation?
Within 30 days of receiving this payment, providers must sign an attestation confirming receipt of the funds and agreeing to the
terms and conditions
of payment. The portal for signing the attestation is now live and can be accessed
here
. If a provider receives payment and does not wish to comply with the terms and conditions, the provider must contact HHS within 30 days of receipt of the payment and remit the full payment to HHS, as instructed. Not returning payment within 30 days of receipt will be viewed as acceptance of the terms and conditions.
How will payments for the remaining specific allocations be prioritized?
Targeted allocations of the Fund will be distributed as follows: (1) $10 billion for targeted distribution to hospitals in areas that have been particularly impacted by the COVID-19 pandemic; (2) $10 billion for rural health clinics and hospitals; (3) a portion of the Fund to reimburse healthcare providers, at Medicare rates, for COVID-19-related treatment for uninsured patients; (4) $400 million will be allocated for the Indian Health Service facilities; and (5) additional allocations for other providers including skilled nursing facilities, dentists and providers that solely take Medicaid.
What must be done for a hospital to receive targeted allocations for COVID-19 high impact areas?
Hospitals should apply for a portion of the allocated $10 billion by providing the requested information via a portal
before 3:00 p.m. ET, Saturday, April 25, 2020
. This portal is live and hospitals have been contacted with instructions and a link to register on the portal. Hospitals must submit the following information: (1) tax identification number; (2) national provider identifier; (3) total number of ICU beds as of April 10, 2020; and (4) total number of admissions with positive diagnosis for COVID-19 from January 1, 2020 to April 10, 2020. Supplying this information does not guarantee receipt of funds from this targeted allocation.
How will the targeted allocations for rural providers be distributed?
$10 billion will be allocated to rural hospital and health clinics as early as next week on the basis of operating expenses, using a methodology that distributes payments proportionately to each facility.
How can a provider participate in the targeted allocation for treatment of uninsured patients?
Every provider who has provided treatment to uninsured COVID-19 patients on or after February 4, 2020 can request claims reimbursement, at Medicare rates, subject to available funding. In order to receive reimbursement for treatment of uninsured patients, providers can register beginning on April 27, 2020, and begin submitting claims beginning on May 6, 2020. Reimbursements will begin in mid-May 2020. For additional information about this program, please visit
here
.
More information about the Fund is available
here
. The entirety of the CARES Act is available
here
.
