Provider-Specific Allocations Available Online

The Department of Health and Human Services (HHS) has begun releasing information on provider-specific distributions on its website. Targeted “high-impact” distributions are available here and “general distribution” distributions are available here. Rural provider distributions are not yet available, but we expect the website to be updated with this information soon.

Hospitals should be prepared to address press inquiries about the distributions with information on your hospital’s comprehensive COVID-19 response activities, including efforts to create surge capacity to meet community need, as well as the financial impact of the pandemic response (both increased expenses and lost revenue). You can also direct press inquiries to GNYHA’s Brian Conway.

Targeted Distribution Update

Over the past two days, HHS has distributed the $12 billion for COVID-19 high-impact areas (defined as hospitals with 100 or more COVID-19 admissions as of April 10) and the $10 billion for rural providers. More information on the distributions is available in ML-68. GNYHA will keep you apprised of any additional details on the applicable distribution formulas.

“General Distribution” Update

HHS has extended the deadline for providers to attest to receipt of payments from the CARES Act Provider Relief Fund $50 billion “General Distribution” and accept the related Terms and Conditions. The deadline is extended from 30 days to 45 days from receipt of payment. For example, if a provider received its first payment out of the initial $30 billion distribution on April 10, the attestation for this payment is due May 25. Similarly, if the provider received its second payment from the $20 billion distribution on April 24, a separate attestation for this payment would be due June 8.

HHS has also posted a revised FAQ document that clarifies several issues raised by GNYHA members in recent weeks. Importantly, HHS states that “…it does not intend to recoup funds as long as a provider’s lost revenue and increased expenses exceed the amount of Provider Relief funding a provider has received.” We interpret this to mean that providers are not considered to be “overpaid” simply because their share of Medicare fee-for-service revenue (the formula for distributing the initial $30 billion) exceeded their share of net patient service revenue and therefore did not receive funds in the second round despite having filed a cost report. However, any provider receiving payments from the Provider Relief Fund must ensure that the amounts received do not exceed their lost revenues and COVID-related expenses not otherwise reimbursed; otherwise, they should reject the funds.

HHS also directs providers that believe they were underpaid to attest to receiving the payment and then request additional funds by entering the requested revenue information in the General Distribution Portal. In addition, all providers—even those that file cost reports and therefore received their distributions automatically—must verify their revenue information and enter data on estimated revenue losses in March and April in the General Distribution Portal.

The FAQs emphasize that HHS will conduct anti-fraud monitoring and the Office of the Inspector General will provide oversight of the use of the funds. In expectation of reporting requirements beginning with the calendar quarter ending June 30, all providers receiving relief funds must thoroughly document their COVID-19-related expenses and lost revenue, and whether those expenses or losses were reimbursed from other sources. HHS will provide additional guidance on the upcoming reporting requirements.

More information on the Provider Relief Fund, including information on both the general and targeted distributions, is available on the HHS website.