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As previously reported, the Coronavirus Aid, Relief, and Economic Security (CARES) Act provides for a $100 billion Provider Relief Fund (PRF). As part of the first wave of distribution under the PRF, on April 10, 2020, the Department of Health & Human Services (DHHS) distributed $30 billion from the PRF as immediate relief funding to support providers and facilities in their response to COVID-19. These funds were deposited directly into recipients’ accounts (labeled as HHSPAYMENT) or sent via check, in accordance with how the provider or facility typically receives its Medicare payments. No application or request for the funds by the recipients were required. Note, PRF payments are made to the billing organization according to its Taxpayer Identification Number (TIN), as opposed to individual providers within each organization.

Who is Eligible to receive PRF Funds?

All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible, provided that they:

  • are not currently terminated from participation in Medicare;

  • are not currently excluded from participation in Medicare, Medicaid, and other Federal health care programs;

  • do not currently have Medicare billing privileges revoked; and

  • provided testing or care to individuals with possible or actual cases of COVID-19. Note, DHHS has taken the stance that every patient is potentially a COVID-19 case.

How did DHHS determine the allocation amounts?

The amount of each provider’s PRF grant for the initial $30 billion distribution round was calculated based on the amount of FFS payments that the recipient received in 2019, in comparison to the total amount of FFS payments to all providers in 2019. Note, Medicare Advantage payments, Medicaid, and other revenue sources were not factored into the calculations for the initial $30 billion distribution.

Future distributions of the remaining $70 billion will, at least partially, be targeted to providers in areas particularly impacted by the COVID-19 outbreak, rural providers, providers of services with lower shares of Medicare FFS reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.

How can the funds be used?

Per the PRF Terms and Conditions, the funds may only be used to prevent, prepare for, and respond to coronavirus or to reimburse the recipient for healthcare related expenses or lost revenues that are attributable to coronavirus. Note, PRF funds cannot be used to reimburse expenses or losses that have been reimbursed from other sources or for which other sources are required to make reimbursement (i.e., no double-dipping).

Do the funds need to be paid back at a future date?

No, the PRF funds are not loans, they are grants. Recipients of the funds will not be required to pay back the funds, provided they agree to and abide by the Terms and Conditions, which are a precondition for keeping the funds. If a recipient is unwilling to accept the Terms and Conditions, then it must contact DHHS within 30 days of receipt of the funds and remit full payment to DHHS per their instructions.

Are there any strings attached?

Yes, a few:

1. Prohibition on balance billing: Recipients that accept PRF funds must agree not to collect out of pocket payments from COVID-19 patients that are in excess of what the patient would have otherwise been required to pay had they been an in-network patient.

2. Executive pay restriction: PRF funds may not be used to pay the salary of any individual at a rate in excess of $197,300 per year.

3. Reporting obligations: Recipients that receive more than $150,000 total in funds from any one program, or combination of programs under the CARES Act, e.g. Provider Relief Fund, Payroll Protection Program, Economic Injury Disaster Loan, must maintain certain records and submit quarterly reports to DHHS, which account for the use of the funds. Additional guidance regarding these records keeping and reporting requirements is expected from DHHS in the coming days.

4. Additional restrictions on use of funds: Recipients cannot use PRF funds for costs related to gun control advocacy, lobbying efforts, abortion programs, embryo research, legalization of controlled substances, pornography, ACORN programs, or needle exchanges.

Where can I access and sign the required attestation?

Recipients must complete the required online attestation within 30 days of their receipt of PRF funds, regardless of whether they plan to accept or reject the funds. If a recipient fails to comply with the attestation requirement set forth above, acceptance and retention of grant funds will, after 30 days, automatically constitute acceptance by the recipient of the associated Terms and Conditions. At the time of signing the attestation, the group will need their TIN, the Banking Information for the account where Medicare deposits are received, the primary address where services are rendered, and the billing address.

What if I did not receive my payment?

Eligible providers that did not receive a PRF payment should contact DHHS at Note, Medicare providers that did not receive payments in the initial round will likely receive their allocations in the second round of the PRF funds distribution. For providers who continue to have problems, DHHS plans to establish a web-portal to support those providers.

For more information on the PRF, please visit the web page.

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abeo Management Corporation (abeo) serves as a leading source of revenue cycle management and practice management with a specialization in anesthesia. The company leverages its people, processes, and software to serve independent practices, surgery centers, hospitals and healthcare systems with a scope of services that include billing, coding, transcription, practice management, and business consulting.

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