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Insights & Resources

  • April 24, 2020
  • Alerts

Government Outlines Plan for Additional Provider Relief Payments

In our Alert “Government Issues Provider Relief Payments,” we described the distribution of approximately $30 billion of the $100 billion appropriated for healthcare providers in the Coronavirus Aid, Relief, and Economic Security (CARES) Act. On April 22nd, the Department of Health and Human Services (HHS) outlined its plan for distribution of the remaining $70 billion. We anticipate additional guidance will follow, as the information currently available is very limited.

General Allocation
 
  • A total of $50 billion will be included in the “general” distribution (of which $30 billion was already distributed).
 
  • According to HHS, it will begin distribution of the remaining $20 billion to providers on April 24th to augment their allocation so that the whole $50 billion general distribution is allocated proportional to providers’ share of 2018 net patient revenue. Providers will be required to attest to receipt of the funds and adherence to terms and conditions specified by HHS. Prior to submitting an attestation, we recommend the terms and conditions be carefully reviewed.
 
  • Providers need to submit revenue data to HHS and payments will be distributed on a weekly basis as financial information is verified. Providers for whom HHS has sufficient cost report data will receive automatic advance payments, subject to verification by HHS.

Targeted Allocations
 
  • Covid-19 High Impact Areas
    $10 billion will be distributed to hospitals in areas that have been particularly impacted by the COVID-19 outbreak. HHS specifically referenced that hospitals serving COVID-19 patients in New York are expected to receive a large share of the funds. Hospitals were required to submit minimal data to HHS by midnight Pacific Standard Time on April 23rd. HHS indicated that hospitals have already been contacted directly regarding this requirement.
 
  • Uninsured
    HHS indicated that every health care provider who has provided treatment for uninsured COVID-19 patients on or after February 4th, 2020, can request claims reimbursement and will be reimbursed at Medicare rates, subject to available funding. HHS did not specify an amount allocated for this purpose.
    Providers can register for the program on April 27th, 2020, and begin submitting claims in early May 2020. For more information, visit coviduninsuredclaim.hrsa.gov.
 
  • Rural Providers
    $10 billion is allocated for rural health clinics and hospitals. Amounts will be distributed based on operating expenses in a manner that distributes payments proportionately to each facility and clinic.
 
  • Other Allocations
    • $400 million is allocated to Indian Health Service facilities.
    • An unspecified amount is allocated for other providers, including skilled nursing facilities, dentists, and providers that solely take Medicaid.

We continue to recommend that any funds received from HHS be segregated to ensure they can be properly accounted for.
 
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Should you have any questions regarding the above, please contact the Garfunkel Wild attorney with whom you regularly work, or contact us at info@garfunkelwild.com.