Today, April 10, 2020, the Department of Health and Human Services (HHS) began the delivery of $30 billion in relief funding to support healthcare-related expenses or lost revenue attributable to the COVID-19 pandemic. This program is different from the CMS Accelerated and Advance Payment Program (APP).
The $30 billion in funding is part of the $100 billion for healthcare providers included in the Coronavirus Aid, Relief, and Economic Security (CARES) Act.1 The $30 billion will go to hospitals and providers across the United States that are enrolled in Medicare programs. The $30 billion will be in the form of payments, not loans, to healthcare providers that will not need to be repaid.2
Some key provisions of this $30 billion in payments:
Facilities and providers are allotted a portion of the $30 billion based on their share of 2019 Medicare fee-for-service (FFS) reimbursements. Providers can estimate their payment by dividing their 2019 Medicare FFS (not including Medicare Advantage) payments they received by $484 billion and multiply that ratio by $30 billion.
As an example, the following calculation would be done with a hospital who billed Medicare FFS $121 million in 2019:
($121 million/$484 billion) x $30 billion = $7.5 million
HHS is partnering with the UnitedHealth Group (UHG) to deliver the initial $30 billion in funding. Providers will be paid via Automated Clearing House account information on file with UHG, UnitedHealthcare, or Optum Bank. The automatic payments will come to providers with “HHSPAYMENT” as the description. UHG will donate all fees for the administration of the CARES Act provider relief fund. The funds will also be used for reimbursements from the Centers of Medicare & Medicaid Services (CMG), as providers who normally receive a paper check for reimbursement will receive a paper check in the mail for this payment as well within the next few weeks.3 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 can be found through the link: hhs.gov/providerrelief.4
HHS’ payment of this initial portion of funds is conditional to the healthcare provider’s acceptance of the Terms and Conditions PDF which can be found here. If a healthcare provider receives payment and does not wish to comply with these terms and conditions, the provider should contact HHS within 30 days of receipt and then remit the full payment to HHS as instructed.
Solo practitioners, and large health organizations/systems should be prepared for payments to be received through their Taxpayer Identification Numbers (TINs) used to bill Medicare. Large organizations and health systems will receive relief payments for each of their billing TINs that bill Medicare.
Employed physicians practice should not expect to receive individual payments directly. The employer organization will receive the relief payment as the billing operation.5
Physicians in a group practice should not expect to receive individual payments directly as the group practice will receive the relief fund payment as the billing organization.6
The remaining $70 billion will be targeted distributions focused on providers in areas particularly impacted by the COVID-19 pandemic, rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.
1 https://www.hhs.gov/about/news/2020/04/10/hhs-to-begin-immediate-delivery-of-initial-30-billion-of-cares-act-provider-relief-funding.html
2 https://www.hhs.gov/about/news/2020/04/10/hhs-to-begin-immediate-delivery-of-initial-30-billion-of-cares-act-provider-relief-funding.html
3 https://www.hhs.gov/about/news/2020/04/10/hhs-to-begin-immediate-delivery-of-initial-30-billion-of-cares-act-provider-relief-funding.html
4 https://www.hhs.gov/about/news/2020/04/10/hhs-to-begin-immediate-delivery-of-initial-30-billion-of-cares-act-provider-relief-funding.html
5 https://www.hhs.gov/provider-relief/index.html
6 https://www.hhs.gov/provider-relief/index.html
Readers should not act upon information presented without individual professional consultation.
Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.