Employer Payroll Tax Deferral UpdateApril 14, 2020
Accounting for PPP LoansApril 22, 2020
Updates on CARES Relief payments to healthcare providers – The CARES Act Provider Relief Fund Payment Attestation Portal (click here) is now open!
Providers who have been allocated a payment from the initial $30 billion general distribution must sign an attestation confirming receipt of the funds and agree to the terms and conditions within 30 days of payment. HHS has now modified some of the language to make its meaning more clear, stating that “every patient is a possible case of COVID-19” instead of the earlier language that seemed to imply that the provider had to be diagnosing and treating COVID -19 patients. Furthermore, HHS clarification states “If you ceased operation as a result of the COVID-19 pandemic, you are still eligible to receive funds so long as you provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19”
Key points to keep in mind when accepting the CARES payment as highlighted below:
- All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for this initial rapid distribution. The amount of the Relief payment is approximately 6% of Medicare payments paid to the provider in 2019.
- Payments to practices that are part of larger medical groups will be sent to the group’s central billing office. All relief payments are made to the billing organization according to its Taxpayer Identification Number (TIN).
- The quick dispersal of funds will provide relief to both providers in areas heavily impacted by the COVID-19 pandemic and those providers who are struggling to keep their doors open due to healthy patients delaying care and canceled elective services.
- Recipient must certify that the payment will only be used to prevent, prepare for, and respond to coronavirus, and use of funds are only for health care related expenses or lost revenues that are attributable to coronavirus.
- 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. In other words no “double dipping”.
- Recipient must submit reports as the HHS Secretary determines, are needed to ensure compliance with conditions that are imposed on the payment, and the reports will be in form, with such content, as specified by the Secretary in future program instructions directed to all Recipients.
- Any entity receiving more than $150,000 total in funds under the various Coronavirus funds (aggregate fund sources) will be required to submit reports quarterly. Providers must have good recordkeeping on the payments received and expenses and purpose of the expenditures. Example – Personal Protective Equipment (PPE), training, added locations, canceled procedures, etc.
- 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.
Full terms and conditions can be found at Terms and Conditions – PDF. Acceptance must occur within 30 days of receipt of payment. Not returning the payment within 30 days of receipt will be viewed as acceptance of the Terms and Conditions. It is also necessary to go on the HHS Attestation link if you decide to reject the CARES Relief payment. The portal will take you step by step for accepting or rejecting the payment.
Reach out to our Healthcare Services Team for more information: firstname.lastname@example.org