On June 10, the U.S. Department of Health & Human Services (HHS) announced the distribution of $15 billion from the Provider Relief Fund to Medicaid providers. The Provider Relief Fund was formed through $175 billion in appropriations in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Paycheck Protection Program and Health Care Enhancement Act. These payments reimburse eligible providers for healthcare-related expenses and lost revenues attributable to COVID-19.
In this distribution round, eligible providers include Medicaid and Children’s Health Insurance (CHIP) providers that participate in state Medicaid and CHIP programs and have not previously received a payment from the Provider Relief Fund General Allocation. This includes providers that do not participate in the Medicare program but provide care to Medicaid patients or residents. It is expected that as many as one million healthcare providers are eligible for this federal payment.
The Medicaid Targeted Distribution methodology will be based upon 2 percent of gross revenues from patient care for CY 2017, or 2018 or 2019, as selected by the provider applicant and with accompanying submitted tax documentation.
Eligible providers must report their annual patient/resident revenue, which will be used as a factor in determining their payment. The final amount each provider receives can only be determined after the data is submitted through the portal. This funding will supply relief to Medicaid providers experiencing lost revenues or increased expenses due to COVID-19.
Providers are eligible for a distribution if:
HHS has continuously updated its FAQs, providing further clarity by providing answers to questions about eligibility requirements.
The deadline to submit an application is July 20, 2020.
Suncrest Inc. owns and operates Sun Meadows Memory Care in Beaverton, Oregon. The facility was licensed and opened in 2015 and was approved to enter Oregon’s Medicaid provider enrollment. Sun Meadows has a licensed occupancy of 50. In 2019, the facility had an average daily occupancy of 46 residents, with 12 residents receiving services through Oregon’s Medicaid program. Sun Meadows had total gross revenues of $3million from patient care. Sun Meadows is currently operating, serving residents, and meets all of the payment eligibility requirements. When Suncrest Inc. submits a payment application for Sun Meadows, it will receive a Medicaid Targeted Distribution payment of $60,000.
Payment recipients will be required to certify compliance with the Terms and Conditions. The Terms and Conditions also provide that any provider retaining payment for at least 90 days without contacting HHS regarding remittance of those funds will be deemed to have accepted the Terms and Conditions.
Terms and Conditions include certifications that the recipient provides or provided after January 31, 2020, diagnoses, testing or care for individuals with possible or actual cases of COVID-19, and that the payment will be used only to prevent, prepare for and respond to COVID‑19, and will reimburse the recipient only for healthcare-related expenses or lost revenues attributable to COVID-19. HHS broadly views every patient/resident as a possible case of COVID-19. Providers should be aware that HHS may require them to submit financial documentation and records to HHS and that payments received may be publicly disclosed by HHS.
Many providers who do not participate in the Medicare program and who contract to provide services to Medicaid beneficiaries do not have National Provider Identifier (NPI) numbers. HHS contracts with United Health Group (UHG) to manage the CARES Act Provider Relief Fund Payment Attestation Portal and process and pay claims. The Provider Relief Fund Payment Attestation Portal includes a field for providers to submit an NPI number, but does not require an NPI number as a condition to complete and submit the application.
HHS has been asked to confirm whether NPIs are required. To date, HHS has not provided guidance on whether applications lacking NPI numbers will be accepted and processed for payment. For providers wanting to maximize odds of success in applying for these funds, immediate action is required to apply for an NPI number. The NPI application can take up to 14 days to process. Learn more about the NPI enrollment application process here.
More information on the CARES Act Provider Relief Fund can be found here. The CARES Act Provider Relief Fund Portal can be accessed here.
For more information, consult Lane Powell’s COVID-19 Resource Center or contact Joe Greenman.
Before proceeding, please note: If you are not a current client of Lane Powell PC, please do not include any information in this email that you or someone else considers to be confidential or secret in nature. Prior to the establishment of a lawyer-client relationship, unsolicited emails from non-clients containing confidential or secret information cannot be protected from disclosure.