Search
 
 

Practices

 

Search

FILTERS

  • Please search to find attorneys
Close Btn

Alerts

April 2020

HHS to Distribute $30 Billion in Immediate Relief as Part of the $100 Billion Public Health and Social Services Emergency Fund

Last updated April 10, 2020

On April 10, 2020, the U.S. Department of Health & Human Services (HHS) will begin delivering an initial $30 billion in immediate relief funds as part of the distribution of the $100 billion Public Health and Social Services Emergency Fund that was earmarked by the CARES Act (discussed in a previous CSG alert).  These funds will go to providers and suppliers that are enrolled in Medicare.  The amount provided will be based on the share of the provider or supplier’s 2019 Medicare fee-for-service (FFS) reimbursements.  Importantly, these will be payments and not loans; therefore, they will not need to be repaid.

Eligibility

Providers and suppliers that received Medicare fee-for-service reimbursement in 2019 will receive payment in accordance with their tax identification number (TIN). HHS provided the following examples:

  • Large Organizations and Health Systems: Large Organizations will receive relief payments for each of their billing TINs that bill Medicare. Each organization should look to the part of their organization that bills Medicare to identify details on Medicare payments for 2019 or to identify the accounts where they should expect relief payments.

  • Employed Physicians: Employed physicians should not expect to receive an individual payment directly. The employer organization will receive the relief payment as the billing organization.

  • Physicians in a Group Practice: Individual physicians and providers in a group practice are unlikely to receive individual payments directly, as the group practice will receive the relief fund payment as the billing organization. Providers should look to the part of their organization that bills Medicare to identify details on Medicare payments for 2019 or to identify the accounts where they should expect relief payments.

  • Solo Practitioners: Solo practitioners who bill Medicare will receive a payment under the TIN used to bill Medicare

Amount and Distribution

Recipients can estimate their payment by dividing their 2019 Medicare FFS (excluding Medicare Advantage) payments they received by $484 billion (the total FFS payments made in 2019) and multiplying that ratio by $30 billion. 

HHS is partnering with UnitedHealth Group (UHG) to deliver the initial funds.  Providers will be paid via Automated Clearing House account information on file with UHG, UnitedHealthcare, or Optum Bank, or used for reimbursements from Centers for Medicare & Medicaid Services (CMS).  Payments will be made electronically via Optum Bank with "HHSPAYMENT" as the payment description.  Providers who normally receive a paper check from CMS will also receive this payment in the form of a paper check within the next few weeks.    

Requirements

Within 30 days of receiving the payment, recipients must sign an attestation confirming receipt of the fund and agreeing to the terms and conditions of the payment.  Starting the week of April 13, 2020, recipients can access the portal to sign the attestation, which will be linked on HHS's website.  If a recipient does not wish to comply with the terms and conditions, the recipient must contact HHS within 30 days of receiving the payments and remit the full payment to HHS per the Agency's instructions.   

The terms and conditions include requirements that recipients only use the payment to "prevent, prepare for, and respond to coronavirus" and require the provider to certify that the payment will not be used to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse.  It also requires recipients to maintain records and cost documentation to substantiate the reimbursement of costs.  The full terms and conditions can be found here.  

Remaining Funds

With respect to the remaining $70 billion of the $100 billion fund, HHS indicated it is working to effectuate targeted distributions to providers in areas particularly impacted by the COVID-19 outbreak, rural providers, providers of services with lower shares of Medicare reimbursement or who predominately serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.  

For additional information pertaining to the coronavirus outbreak, please visit CSG's COVID-19 Resource Center.


This publication contains general information on recent legal developments and is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. Attorney Advertising. Prior results do not guarantee a similar outcome.

×

Visit CSG's COVID-19 Resource Center.