Blog

American Medical Association Helps Press HHS for Continued Provider Relief Fund Support

The U.S. Department of Health and Human Services has announced it is moving forward to provide some relief for medical professionals. HHS expects to distribute approximately $15 billion to eligible physicians and organizations that participate in state Medicaid and CHIP programs and have not received a payment from the Provider Relief Fund General Allocation.

Adds New and Updated FAQs

The U.S. Department of Health and Human Services has announced it is moving forward to provide some relief for medical professionals. HHS expects to distribute approximately $15 billion to eligible physicians and organizations that participate in state Medicaid and CHIP programs and have not received a payment from the Provider Relief Fund General Allocation.

Starting June 10, HHS plans to launch a portal that will allow eligible physicians and organizations to report their annual patient revenue data and other necessary information to receive a payment equal to at least 2 percent of reported gross revenues from patient care.

FSR will send out notification to members when the portal becomes available.

Read HHS Press Release


In addition, HHS has updated their FAQs. Modified or added FAQs can be read below.

Read Full FAQs

In order to accept a payment, must the provider have already incurred eligible expenses and losses higher than the Provider Relief Fund payment received? (Added 6/8/2020)

No. Providers do not need to be able to prove, at the time they accept a Provider Relief Fund payment that prior and/or future lost revenues and increased expenses attributable to COVID-19 (excluding those covered by other sources of reimbursement) meet or exceed their Provider Relief Fund payment. Instead, HHS expects that providers will only use Provider Relief Fund payments for permissible purposes and if, at the conclusion of the pandemic, providers have leftover Provider Relief Fund money that they cannot expend on permissible expenses or losses, then they will return this money to HHS. HHS will provide directions in the future about how to return unused funds. HHS reserves the right to audit Provider Relief Fund recipients in the future and collect any Relief Fund amounts that were used inappropriately.

The Terms and Conditions set forth a list of “statutory provisions” that “also apply” to the Provider Relief Fund payment. Do these requirements apply to any government funding received by the recipient, or only the Provider Relief Fund payment associated with those Terms and Conditions? (Added 6/8/2020)

The “statutory provisions” listed in the Terms and Conditions apply to the Provider Relief Fund payment associated with those Terms and Conditions. Those statutory provisions may also independently apply to other government funding that you receive.

Are Provider Relief funds accessible in whole or in part to bankruptcy creditors and other creditors in active litigation? (6/8/2020)

Payments from the Provider Relief Fund shall not be subject to the claims of the provider's creditors and providers are limited in their ability to transfer Provider Relief Fund payments to their creditors. A provider may utilize Provider Relief Fund payments to satisfy creditors' claims, but only to the extent that such claims constitute eligible health care related expenses and lost revenues attributable to coronavirus and are made to prevent, prepare for, and respond to coronavirus, as set forth under the Terms and Conditions.

The Terms and Conditions require recipients to attest that for all care for a presumptive or actual case of COVID-19 the recipient will not seek to collect from the patient out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network recipient. How should skilled nursing facilities comply with this requirement? (Added 6/8/2020)

For skilled nursing facility patients with insurance, an out-of-network skilled nursing provider delivering care to a presumptive or actual COVID-19 patient may not seek to collect from the patient out-of-pocket expenses, including deductibles, copayments, or balance billing, in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.

Can a healthcare provider that files its 2019 tax forms in July use financial information prepared for its 2019 tax filings for revenue submission even if it has not yet filed its 2019 tax forms? (Added 6/8/2020)

When a provider submits its revenue information in the Provider Relief Fund Payment Portal, it should use the most recent completed tax year's filings. If, when a provider submits its revenue information, it has its 2019 tax filings available, it may use those tax filings. Payments are determined based on the lesser of 2% of a provider's most recent complete tax year gross receipts or the sum of healthcare-related expenses or lost revenue attributable to COVID-19 for March and April 2020.

A parent organization has a subsidiary that received a Provider Relief Fund General Distribution payment, but one or more of its other subsidiaries did not. When the parent entity submits its revenue information, should it report the gross receipts or receipts (or program service revenue) for the parent entity, which includes multiple subsidiaries' data, or only the specific provider/subsidiary that received a payment? (Added 6/8/2020)

The parent organization should complete an application by listing the Billing TINs of the eligible subsidiaries that provide or provided after January 31, 2020, diagnoses, testing or care for individuals with possible or actual cases of COVID-19. In the application, the parent entity should enter the sum of all “gross sales or receipts” or “program service revenue” of all eligible subsidiary entities that provide or provided after January 31, 2020, diagnoses, testing or care for individuals with possible or actual cases of COVID-19 and enter the subsidiaries' Billing TINs in the applicable fields in the application form. Any revenues from subsidiaries that are not directly providing diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 may not be included.

How were the initial COVID-19 High Impact Area funds allocated? (Modified 6/8/2020)

HHS allocated High Impact Area funding based on a fixed amount per COVID-19 inpatient admission with an additional distribution based off each hospital's portion of Medicare Disproportionate Share Hospital (DSH) payments and Medicare Uncompensated Care Payments (UCP).

Should providers continue to update their High Impact data? (Modified 6/8/2020)

Providers should update their capacity and COVID-19 census data to ensure that HHS can make timely payments in the event that the provider becomes a High Impact Area provider. Providers can continue to update their information through the same method they used previously.

How many payments did HHS make under the initial COVID-19 High Impact Area Distribution? (Modified 6/8/2020)

HHS made payments to nearly 400 hospitals and health systems that provided inpatient care for 100 or more COVID-19 patients through April 10, 2020. Some payments were made to hospitals and health systems that operate more than one hospital.

What was the rationale behind requiring at least 100 COVID-19 admissions to be eligible for the initial High Impact payment? (Modified 6/8/2020)

HHS used COVID-19 admissions as a proxy for the extent to which each facility experienced lost revenue and increased expenses associated with directly treating a substantial number of COVID-19 inpatient admissions. The hospitals that received the initial round of COVID-19 High Impact Area distributions encountered over 70% of the national COVID-19 inpatient admissions reported by April 10, 2020.

What types of entities are eligible to receive new COVID-19 High Impact Area payments? (Added 6/8/2020)

HHS is making COVID-19 High Impact Area payments to hospitals that have a high number of COVID-19 positive inpatient admissions. Payments are made at the billing TIN level. Hospital systems with more than one facility under a common Tax Identifier Number (TIN) must report the number of a COVID-19 positive-inpatient admissions occurring within each facility. Reporting this information is accomplished by using the comma separated values (CSV) document available on the TeleTracking portal.

What data do I submit to be considered for the High Impact Area funding? And where? (Added 6/8/2020)

To be considered for a COVID-19 High Impact Area payment, applicants must use the TeleTracking platform to upload the number of their hospital's COVID-19 positive-inpatient admissions between January 1, 2020 and June 10, 2020.

What is the COVID-19 admission threshold for payment under this High Impact Area Distribution, and why was this value chosen? (Added 6/8/2020)

HHS' allocation methodology will be determined after fully analyzing the collective data submitted by hospitals.

How is this High Impact Area Distribution different from the Initial Distribution of High Impact Funding? (Added 6/8/2020)

HHS intends to distribute the second round of High Impact Area funding to address the comprehensive impact of the cost of providing care to COVID-19 positive inpatients. Funding from the prior round will be taken into account in making payments under this round.

When is the deadline for my application? (Added 6/8/2020)

HHS is collecting COVID-19 positive-inpatient hospital admissions for the period January 1, 2020, through June 10, 2020, via TeleTracking. The portal will be open for submission from June 8, 2020 through June 15, 2020 at 9:00 PM Eastern Time.

If I submitted an application for the first round of High Impact Area funding, can I submit through this announcement as well? (Added 6/8/2020)

Yes. Please go into TeleTracking and update your hospital's data to reflect all COVID-19 positive inpatient admissions from January 1, 2020 through June 10, 2020. Funding from the prior round will be taken into account in making payments under this round.

In my last submission, I misunderstood the directions and submitted the total of all COVID-19 positive admissions throughout the system instead of by facility. Will that effect my new submission? (Added 6/8/2020)

Please go into TeleTracking and correct your submission and update your hospital's data to reflect all COVID-19 positive inpatient admissions from January 1, 2020 through June 10, 2020.

My facility (four walls) does not have an ICU but there is one at another campus across the street, can I count that? (Added 6/8/2020)

No.

My billing TIN includes multiple campuses that are only a few blocks apart. Can we count the total cases of COVID-19 positive inpatient admissions across all of the campuses under a single submission? (Added 6/8/2020)

COVID-19 positive inpatient admissions that occur at multiple campuses that share the same TIN for billing purposes should not be rolled-up into one count. You should enter the total COVID-19 positive inpatient admissions for each campus separately using the CSV file option on TeleTracking.

Should I count cases through June 10, 2020 (i.e. including that date) or up until that date (i.e. not including the end date)? (Added 6/8/2020)

You should count COVID-19 positive inpatient admissions from January 1, 2020, through the end of the day June 10, 2020.

Does an emergency department (ED) admission count as a COVID-19 positive inpatient admission? (Added 6/8/2020)

No. ED admissions should not be included in your count.

Can I count patients that had a pending positive test that came back positive after June 10, 2020? (Added 6/8/2020)

No. Only count COVID-19 positive inpatient admissions through June 10, 2020.

What constituted a “certified” skilled nursing facility for purposes of the Targeted Distribution? (Added 6/8/2020)

A “certified” skilled nursing facility must be certified under Medicare and/or Medicaid to be eligible for this Targeted Distribution. All standalone and/or hospital-based skilled nursing facilities with at least six beds were eligible for this Targeted Distribution.

Contributors

    Contributors