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Health and Human Services Provider Relief Funds

Tiffany Karlin

April 10, 2020

This post includes three valuable sections for your review:

Initial HHS $30 Billion Payment

Additional HHS Relief Funding to Healthcare Providers

HHS Payment Updates and Clarifications on Terms and Conditions

COVID-19 Claims Reimbursement to Healthcare Providers and Facilities for Testing and Treatment of the Uninsured

Initial HHS $30 Billion Payment

The CARES Act included a $100 billion provider relief fund to support healthcare-related expenses or lost revenue attributable to Coronavirus, and to ensure uninsured Americans can get the testing and treatment they need without receiving a surprise bill from a provider. Today, the Department of Health and Human Services (HHS) is beginning the delivery of the initial $30 billion in relief funding to providers. Visit the HHS site.

Who is eligible?

The relief funds will go to healthcare providers across the United States that enrolled in Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for this initial rapid distribution.

How will it be distributed?

All relief payments are made to the billing organization according to its Taxpayer Identification Number.

Payments to practices that are part of larger medical groups will be sent to the group’s central billing office.

HHS is partnering with UnitedHealth Group (UHG) to deliver the initial distribution to providers as quickly as possible.

Providers will be paid via Automated Clearing House account (the automatic payments will come with “HHSPAYMENT” as the payment description), information on file with UHG, UnitedHealthcare, or Optum Bank, or used for reimbursements from the Centers for Medicare & Medicaid Services (CMS). Providers who normally receive a paper check for reimbursement from CMS will receive a paper check in the mail for this payment as well, within the next few weeks.

How do we know our approximate amount?

Divide 2019 Medicare FFS (not including Medicare Advantage) payments received by $484,000,000,000 and multiply that ratio by $30,000,000,000.

As an example: A provider billed Medicare FFS $121 million in 2019:
To determine how much they would receive, use this equation: $121,000,000 / $484,000,000,000 x $30,000,000,000 = $7,500,000

Will we have to pay back?

These are payments, not loans, to healthcare providers, and will not need to be repaid.

Conditions

As a condition to receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.

Within 30 days of receiving the 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 will be open the week of April 13, 2020 and will be linked from hhs.gov/providerrelief

Can I take this money and still apply for Accelerated Payments?

Yes, this Accelerate Payment Program is a loan.

Future Funds

In the coming weeks, funds will be released for providers in areas particularly impacted by the COVID-19 outbreak, rural providers, low volume Medicare providers of services, providers who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.

Additional HHS Relief Funding to Healthcare Providers

The CARES Act included a $100 billion provider relief fund to support healthcare-related expenses or lost revenue attributable to Coronavirus, and to ensure uninsured Americans can get the testing and treatment they need without receiving a surprise bill from a provider. HHS site

As of this week Medicare fee for service providers received their proportionate share of the initial $30 billion in relief funding.  More details are above.

The Health and Human Services (HHS) will begin Friday April 24th to distribute an additional $20 billion in funding. This $20 billion will be based on a calculation percentage of provider’s total revenue, but will make some adjustment for Medicare revenue that was recognized in the prior payment. The calculation will be derived from the provider’s share of 2018 net patient revenue. Providers receiving this payment will automatically be sent an advance payment based off the revenue data they submitted in CMS cost reports. It is believed that providers who have a high level of Medicaid and/or Medicare Advantage will benefit from this additional payment.

Example of Calculation:

  1. Start with $2.5 trillion, which is what HHS calculated as the spend for all Medicare providers.
  2. Divide provider’s revenue by $2.5 trillion to get the percentage attributable to each building.
  3. Multiply the provider’s percentage by $50 billion (the full amount of payments to all providers) to determine the amount for each provider.
  4. For the payments going out this week, HHS is then deducting the amount distributed two weeks ago to determine the final payment.

Or: ([Facility’ s 2018 Net Patient Revenue ÷ $2.5 Trillion] × $50 billion) – Amount given in 1st payment = New distribution amount

Targeted groups receiving this money

Medicaid Only Providers: Those who solely take Medicaid.

Hospitals in High Impact Areas Affected by COVID-19:  $10 billion will be allocated for a targeted distribution to hospitals in areas that have been particularly impacted by the COVID-19 outbreak.

Uninsured: A portion of the $100 billion Provider Relief Fund will be used to reimburse healthcare providers, at Medicare rates, for COVID-related treatment of the uninsured. Every health care provider who has provided treatment for uninsured COVID-19 patients on or after February 4, 2020, can request claims reimbursement through the program and will be reimbursed at Medicare rates, subject to available funding.                   

Rural Health Providers: $10 billion will be allocated for rural health clinics and hospitals, most of which operate on especially thin margins and are far less likely to be profitable than their urban counterparts.

Indian Health Service:  $400 million will be allocated for Indian Health Service facilities, distributed on the basis of operating expenses. Indian Country is also being impacted by COVID-19.

As with initial outlays of relief, those receiving these funds will also need to sign the Attestation: https://covid19.linkhealth.com/#/step/1  and follow the terms and conditions associated with the funds: https://www.hhs.gov/sites/default/files/relief-fund-payment-terms-and-conditions.pdf

HHS Payment Updates and Clarifications on Terms and Conditions

If you receive an automatic payment from funds appropriated in the Public Health and Social Services Emergency Fund for provider relief (“Relief Fund”), these are the “terms and conditions” associated with those funds as written by HHS (https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/index.html):

  • The Recipient certifies that it billed Medicare in 2019; provides or provided after January 31, 2020 diagnoses, testing, or care for individuals with possible or actual cases of COVID-19; is not currently terminated from participation in Medicare or precluded from receiving payment through Medicare Advantage or Part D; is not currently excluded from participation in Medicare, Medicaid, and other Federal health care programs; and does not currently have Medicare billing privileges revoked.
  • The Recipient certifies that the Payment will only be used to prevent, prepare for, and respond to coronavirus, and that the Payment shall reimburse the Recipient only for health care related expenses or lost revenues that are attributable to coronavirus.
  • The Recipient certifies that it will not use the Payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. 
  • The Recipient shall submit reports as the Secretary determines are needed to ensure compliance with conditions that are imposed on this Payment, and such reports shall be in such form, with such content, as specified by the Secretary in future program instructions directed to all Recipients.  The Recipient shall also submit general revenue data for calendar year 2018 to the Secretary when applying to receive a Payment, or within 30 days of having received a Payment. 
  • The Recipient consents to the Department of Health and Human Services publicly disclosing the Payment that Recipient may receive from the Relief Fund.  The Recipient acknowledges that such disclosure may allow some third parties to estimate the Recipient’s gross receipts or sales, program service revenue, or other equivalent information.
  • The Recipient certifies that all information it provides as part of its application for the Payment, as well as all information and reports relating to the Payment that it provides in the future at the request of the Secretary or Inspector General, are true, accurate and complete, to the best of its knowledge.  The Recipient acknowledges that any deliberate omission, misrepresentation, or falsification of any information contained in this Payment application or future reports may be punishable by criminal, civil, or administrative penalties, including but not limited to revocation of Medicare billing privileges, exclusion from federal health care programs, and/or the imposition of fines, civil damages, and/or imprisonment.
  • Not later than 10 days after the end of each calendar quarter, any Recipient that is an entity receiving more than $150,000 total in funds under the Coronavirus Aid, Relief, and Economics Security Act (P.L. 116-136), the Coronavirus Preparedness and Response Supplemental Appropriations Act (P.L. 116-123), the Families First Coronavirus Response Act (P.L. 116-127), or any other Act primarily making appropriations for the coronavirus response and related activities, shall submit to the Secretary and the Pandemic Response Accountability Committee a report.  This report shall contain: the total amount of funds received from HHS under one of the foregoing enumerated Acts; the amount of funds received that were expended or obligated for reach project or activity; a detailed list of all projects or activities for which large covered funds were expended or obligated, including: the name and description of the project or activity, and the estimated number of jobs created or retained by the project or activity, where applicable; and detailed information on any level of sub-contracts or sub-grants awarded by the covered recipient or its subcontractors or sub-grantees, to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 allowing aggregate reporting on awards below $50,000 or to individuals, as prescribed by the Director of the Office of Management and Budget.
  • The Recipient shall maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR § 75.302 – Financial management and 45 CFR § 75.361 through 75.365 – Record Retention and Access, and other information required by future program instructions to substantiate the reimbursement of costs under this award.  The Recipient shall promptly submit copies of such records and cost documentation upon the request of the Secretary, and Recipient agrees to fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with these Terms and Conditions. 
  • For all care for a presumptive or actual case of COVID-19, Recipient certifies that it 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.

To Accept Payments:

Attestation and Verification of Funds:

If you received the first and second payment (both need to be attested): https://covid19.linkhealth.com/#/step/1

If you received payments and want to apply for more: https://covid19.linkhealth.com/docusign/#/step/1

What you need to attest to the second payment:

The Provider Relief Fund Application Portal is collecting four pieces of information for use in allocating remaining General Distribution funds:

  1. A provider’s “Gross Receipts or Sales” or “Program Service Revenue” as submitted on its federal income tax return;
  2. The provider’s estimated revenue losses in March 2020 and  April 2020 due to COVID;
  3. A copy of the provider’s most recently filed federal income tax return;
  4. A listing of the TINs any of the provider’s subsidiary organizations that have received relief funds but that DO NOT file separate tax returns.

HHS is collecting the “gross receipt or sales” or “program service revenue” data to have an understanding of a provider’s usual operations.  We are collecting the revenue loss information to have an understanding of COVID impact.  We are collecting tax forms in order to verify the self-reported information. And we are collecting information about organizational structure and subsidiary TINs so that we do not overpay or underpay providers who file tax returns covering multiple legal entities (e.g. consolidated tax returns).

If I received the first payment but not the second, can I apply for more funds? 

YES. Any provider who has already received a payment from the Provider Relief Fund as of 5:00 pm EST Friday, April 24th can and should apply for additional funding via the Provider Relief Fund Application Portal: https://covid19.linkhealth.com/docusign/#/step/1

How long does it take for HHS to make a decision on additional funding?

For providers submitting tax and financial loss information, HHS intends to distribute additional funds within 10 business days of the submission.

For healthcare providers who have not yet received any distribution of funds, HHS is performing an ongoing assessment of how to distribute relief to these providers.  It is the Department’s intention to distribute relief funds as quickly as possible.

How will HHS notify me that my application has been processed?

You will receive an email when your application is completed. You will receive no notification from HHS as to the status of your application once submitted. You should expect additional funds, if you are to receive any, within 10 business days of completing your application.

What if I haven’t received any of the HHS Relief Money?

Providers who have NOT yet received any payment from the Provider Relief Fund should NOT use the General Distribution Portal.  However, providers who have NOT yet received any payments from the Provider Relief Fund may still receive funds in other distributions.

Providers who have not received ANY funding as of 5:00 pm EST Friday April 24th are NOT eligible to use the Provider Relief Fund Application Portal, HOWEVER these providers may still be eligible for payments from the Provider Relief Fund through other mechanisms, including the Targeted Distributions being made from the Fund.   More details to come on when additional monies will be released.

COVID-19 Claims Reimbursement to Healthcare Providers and Facilities for Testing and Treatment of the Uninsured

Click here to visit the Health Resources & Services Administration.

As a part of the CARES Act the US Department of Health and Human Service (HHS) will provide reimbursement to health providers for testing uninsured individuals for COVID-19 and treating those individuals with the COVID-19 diagnosis. This funding amounts to $1 billion to reimburse providers at approximately Medicare rates in an effort to protect the uninsured population.

Healthcare providers who have conducted COVID-19 testing or provided treatment for uninsured individuals with a COVID-19 diagnosis on or after February 4, 2020, can electronically request claims reimbursement through the program.

Steps will involve enrolling as a provider participant, checking patient eligibility, submitting patient information, submitting claims electronically, and receiving payment via direct deposit.

Reimbursement is subject to available funding.

Testing Terms and Conditions in accepting reimbursement

Treatment Terms and Conditions in accepting reimbursement

What’s covered:

  • Specimen collection, diagnostic and antibody testing.
  • Testing-related visits including in the following settings: office, urgent care or emergency room or telehealth.
  • Treatment: office visit (including telehealth), emergency room, inpatient, outpatient/observation, skilled nursing facility, long-term acute care (LTAC), acute inpatient rehab, home health, DME (e.g., oxygen, ventilator), emergency ambulance transportation, non-emergent patient transfers via ambulance, and FDA approved drugs as they become available for COVID-19 treatment and administered as part of an inpatient stay.
  • When an FDA-approved vaccine becomes available, it will also be covered.

Excluded Services:

  • Any treatment without a COVID-19 primary diagnosis, except for pregnancy when the COVID-19 code may be listed as secondary.
  • Hospice services.
  • Outpatient prescription drugs.

Getting Started:

Step 1: Register with Optum

Register with Optum

Sign-In at Optum (If you already have an account with them)

Step 2: Validate Taxpayer Identification Number (TIN)

Step 3: Set Up Optum Pay Automated Clearing House (ACH)

Step 4: Add Provider Roster

Step 5: Add and Attest to Patient Roster

Step 6: Submit Claims

Beginning Wednesday, May 6, 2020, submit claims electronically for professional and facility services (ANSI X12 837). All claims must be submitted electronically using an 837 EDI transaction set. Claims will be submitted outside the HRSA COVID-19 Uninsured Program Portal.

Billing Codes for Testing

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