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Health and Human Services (HHS) released an update addressing the proper use of funds available through the CARES Act provider Relief Fund. There were numerous additions made after May 25, 2020 to Frequently Asked Questions and they are highlighted in the document posted on the COVID-19 page of the MSN website.
One of the most relevant updates follows:
The Terms and Conditions state that Provider Relief Fund payments will only be used to prevent, prepare for, and respond to coronavirus and shall reimburse the Recipient only for healthcare-related expenses or lost revenues that are attributable to coronavirus. What expenses or lost revenues are considered eligible for reimbursement? (Added 6/2/2020)
The term “health care related expenses attributable to coronavirus” is a broad term that may cover a range of items and services purchased to prevent, prepare for, and respond to coronavirus, including:
- supplies used to provide healthcare services for possible or actual COVID-19 patients;
- equipment used to provide healthcare services for possible or actual COVID-19 patients;
- workforce training;
- developing and staffing emergency operation centers;
- reporting COVID-19 test results to federal, state, or local governments;
- building or constructing temporary structures to expand capacity for COVID-19 patient care or to provide healthcare services to non-COVID-19 patients in a separate area from where COVID-19 patients are being treated; and
- acquiring additional resources, including facilities, equipment, supplies, healthcare practices, staffing, and technology to expand or preserve care delivery.
Providers may have incurred eligible health care related expenses attributable to coronavirus prior to the date on which they received their payment. Providers can use their Provider Relief Fund payment for such expenses incurred on any date, so long as those expenses were attributable to coronavirus and were used to prevent, prepare for, and respond to coronavirus. HHS expects that it would be highly unusual for providers to have incurred eligible expenses prior to January 1, 2020.
The term “lost revenues that are attributable to coronavirus” means any revenue that you as a healthcare provider lost due to coronavirus. This may include revenue losses associated with fewer outpatient visits, canceled elective procedures or services, or increased uncompensated care. Providers can use Provider Relief Fund payments to cover any cost that the lost revenue otherwise would have covered, so long as that cost prevents, prepares for, or responds to coronavirus. Thus, these costs do not need to be specific to providing care for possible or actual coronavirus patients, but the lost revenue that the Provider Relief Fund payment covers must have been lost due to coronavirus. HHS encourages the use of funds to cover lost revenue so that providers can respond to the coronavirus public health emergency by maintaining healthcare delivery capacity, such as using Provider Relief Fund payments to cover:
- Employee or contractor payroll
- Employee health insurance
- Rent or mortgage payments
- Equipment lease payments
- Electronic health record licensing fees
All providers receiving Provider Relief Fund payments will be required to comply with the reporting requirements described in the Terms and Conditions and specified in future directions issued by the Secretary. HHS will provide guidance in the future about the type of documentation we expect recipients to submit. Additional guidance will be posted at here.
We encourage all MSN clients to review the complete FAQ document here.
On Sunday, April 26, 2020 the Centers for Medicare and Medicaid Services (CMS) state they have updated the Accelerated & Advance Payments Program Fact Sheet.
- The Advance Payment program applies to providers and Accelerated Payments are designated for hospitals
- Beginning on April 26, 2020 CMS will not be accepting any new applications for the Advance Payment Program; and
- CMS will be reevaluating all pending and new applications for Accelerated Payments in light of historical direct payments made available through HHS’s Provider Relief Fund.
Those applying for Provider Relief Funds should have the following information gathered for the application:
- “Gross Receipts or Sales” or “Program Service Revenue” as submitted on its federal income tax return;
- Estimated revenue losses in March 2020 and April 2020 due to COVID;
- A copy of the provider’s most recently filed federal income tax return;
- Listing of the TINs any of the provider’s subsidiary organizations that have received relief funds but that DO NOT file separate tax returns
All groups receiving a Provider Relief Payment must submit an attestation accepting the terms and conditions for receipt of these funds. There is an electronic portal available for this purpose.
A separate targeted Provider Relief Fund has been established for specific groups HHS classifies as hard-hit by COVID-19 or particularly vulnerable to revenue losses due to the virus. These funds may be eligible to providers who did not receive an earlier distribution from the General Distribution of Funds. Targeted provider groups include:
- High impact COVID-19 hospitals – $10 billion
- Rural health clinics/rural hospitals – $10 billion
- Indian Health Service facilities – $400 million
- COVID-related care to the uninsured – amount unspecified
$100 billion remains unobligated, with HHS still to announce how or when they intend to release the funds
Frequently asked questions regarding funds available to providers from the Health Resources Service Administration (HRSA) are addressed in a document available from Health and Human Services (HHS).
How to bill and collect for COVID-19 from the uninsured (HRSA funds):
Suggested RSNA guidelines for the documentation and dictation of radiology reports related to COVID-19 diagnoses are available at the following links:
A description of cost-sharing initiatives announced by insurance carriers is available at:
IRS announces 50% employee tax credit due to COVID-19:
The False Claims Act can apply to groups for failure to properly document appropriate use of Coronavirus Aid, Relief and Economic Security (CARES) Act funds as required by the Terms and Conditions.
MSN Client Advisories:
The Radiological Society of North America (RSNA) COVID-19 Task Force has issued a guidance document for the safe resumption of imaging services: