The $2 trillion Coronavirus Aid, Relief, and Economic Security (CARES) Act includes more than $100 billion in aid in a Provider Relief Fund for healthcare organizations. In recent weeks, the Department of Health and Human Services (HHS) has issued guidelines on how the Fund dollars will be distributed. Yesterday, there was a new announcement regarding the Fund as well as updated information on the program.
Provider Relief Fund Allocations
$50 Billion General Allocation
- $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.
- On April 10, 2020, HHS announced an expedited general allocation of $30 billion distributed to eligible providers based on their 2019 Medicare fee-for-service reimbursements. According to HSS, $26 billion was distributed on April 10, and $4 billion was distributed on April 17 directly to provider bank accounts.
- On April 22, 2020, HHS increased the general allocation by $20 billion. The new $20 billion allocation is based on the provider’s share of 2018 net patient revenue.
- On April 24, 2020, a portion of providers will automatically receive payments based on revenue data submitted in their cost reports to the Centers for Medicare and Medicaid Services (CMS). Those providers without adequate cost report data will be required to submit revenue information to https://www.hhs.gov/providerrelief in order to receive general allocation funds.
- Payments will be distributed automatically on a weekly, rolling basis to providers, with the first wave being delivered on April 24, 2020.
A few considerations
- Providers who receive funds from the ‘general allocation’ are required to sign an attestation confirming the receipt of and agreeing to the Terms and Conditions of payment that include measures to help prevent fraud and misuse of the funds.
- Recipient providers will be required to submit documentation that supports the use of the funds for healthcare-related expenses and/or lost revenue attributable to COVID-19.
- Providers should monitor compliance with the Terms and Conditions and be prepared to comply with the reporting requirements and respond to audit requests.
- Non-compliance with the Terms and Conditions is grounds for the Secretary of HHS to recoup some or all the payment from the general allocation funds. Both HHS and the Office of Inspector General will be auditing and monitoring the program for fraud, waste, and abuse.
$10 Billion COVID-19 High Impact Areas Allocation
- $10 billion will be allocated to hospitals in areas that have been particularly impacted by the COVID-19 outbreak (i.e., New York, Michigan). This allocation will take into consideration the number of admissions and challenges faced by facilities in ‘hot zones’ for COVID-19 infection.
- Hospitals in these areas have already been contacted directly to provide the following 4 pieces of information via an authentication portal:
- Tax Identification Number
- National Provider Identifier
- Total number of Intensive Care Unit beds as of April 10, 2020
- Total number of admissions with a positive diagnosis for COVID-19 from January 1, 2020 to April 10, 2020.
The portal to submit this information is live and has been provided to facilities that meet the requirements.
Treatment of the Uninsured Allocation
- Providers that treated uninsured COVID-19 patients on or after February 4, 2020, can request reimbursement at Medicare rates.
- HHS did not specify the total amount of funds available through this allocation.
- Providers can register for the program on April 27, 2020 and begin submitting claims on May 6, 2020.
- Providers who submit claims for patients confirmed as uninsured will be required to follow these steps:
- Enroll as a provider participant;
- Check patient eligibility and benefits;
- Submit patient information;
- Submit claims; and
- Receive payment via direct deposit.
- More information is available on hrsa.gov
$10 Billion Rural Providers Allocation
- $10 billion is allocated to rural health clinics and hospitals.
- This money will be distributed as early as next week based on operating expenses, using a methodology that distributes payments proportionately to each facility and clinic
- More details on allocation will be available the week of April 27, 2020.
$400 Million Indian Health Service Allocation
- $400 million will be distributed to for Indian Health Service facilities distributed based on operating expenses.
As we stated in our initial perspective on the CARES Act, hospitals should consider all applicable funding sources. At the same time, hospitals must also understand all rules and requirements of the funding programs being considered. While the Provider Relief Fund will allow for the distribution of much needed monies, hospitals need to ensure that they fully review, understand, and are able to comply with all Terms and Conditions required to qualify for the funds from the various allocations.
