Update to HHS CARES Act Provider Relief Funds

Healthcare Providers Should Proceed with Caution When Applying for Additional COVID Relief to Ensure Accurate Requests

The Department of Health and Human Services has started distributing the remaining $20 billion of the $50 billion general distribution to Medicare providers.

If you’ve already received a payment from the Provider Relief Fund, you’re now eligible to apply for additional funds by submitting data about your annual revenues and estimated COVID-related losses. You can do so through the Provider Relief Fund Application Portal. Those who are eligible can receive disbursements through both the “General” and “Targeted” distributions.

For more information, take a look at our HHS Cares Act Provider Relief Fund blog. There, you’ll find a link to FAQs about the general distribution portal.

The FAQ provides information about eligibility, what information to submit through the portal, how to calculate lost revenue, etc. PLEASE NOTE: Our team’s initial analysis identified inconsistencies and raised concerns about the accuracy and consistency of the information HHS is requesting.

For example, the FAQ suggests that nonprofits use Part I, Line 9, “Program Services Revenue” of Form 990 to determine gross receipts. However, it’s likely that’s not an accurate estimate of your gross receipts. A healthcare provider also has different options for calculating lost revenue. However, “net revenue” would be impacted by such things as cost report impacts during the COVID-19 period and the accuracy of allowances associated with accounts receivable.

The process for accessing additional HHS funding seems fairly rigid in that there isn’t an appeal or dispute process. The FAQ also states that providers will not be penalized for taking several days to collect the necessary information. Applications will be processed in batches every Wednesday. Funds will not be disbursed on a first-come-first-served basis, so applicants will be given equal consideration regardless of when they apply. Also, HHS’s turn around is relatively quick. According to the FAQ, if you have attested and submitted the required information, you should receive a payment or other response within 10 business days.

Accordingly, we’re advising providers to not rush through this process. Hurrying to apply without first fully understanding or determining the accuracy of the information you submit may limit your abilities to maximize the funding that your facility may be eligible to receive.

We’re encouraging healthcare providers to consult with their cost report preparers or accounting firms before submitting information through the portal.

This communication is intended to provide general information on legislative COVID-19 relief measures as of the date of this communication and may reference information from reputable sources. Although our firm has made every reasonable effort to ensure that the information provided is accurate, we make no warranties, expressed or implied, on the information provided. As legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that may modify some of the provisions in this communication. Some of those modifications may be significant. As such, be aware that this is not a comprehensive analysis of the subject matter covered and is not intended to provide specific recommendations to you or your business with respect to the matters addressed.