Additional $20 Billion from HHS for Medicare Providers: Are you Eligible for Round 2?

Background

The CARES Act appropriated $100 billion to the Department of Health and Human Services (HHS) to distribute to healthcare providers during the COVID-19 pandemic (read our guidance here).  In April, HHS allocated an initial $30 billion of this funding to providers who received Medicare fee-for-service reimbursements in 2019 based on each provider’s share reported. These payments, or grants, were automatically dispersed to providers without an application process.

On April 24^th, HHS announced that an additional $20 billion in funding would be distributed to eligible providers who have been impacted by COVID-19 (either by a decrease in revenue or an increase in expenditures).

Eligibility

Eligibility for the new funding is broken into two groups:

• Group 1: Healthcare providers that submit cost report data to the Centers for Medicare and Medicaid Services (CMS), such as hospitals, home health agencies, skilled nursing facilities, etc. A number of these healthcare providers will automatically receive funds based on gross revenue reported on their 2018 cost report. Providers who do not automatically receive payment are required to submit revenue information on the Provider Relief Fund Portal.
• Group 2: All other healthcare providers who received payments from the initial $30 billion distribution as of 5 p.m. on April 24^th and accepted the payment by visiting the attestation portal and agreeing to the Terms and Conditions. This includes providers with a lower population of Medicare patients who may not have received a significant payment in the first allocation. While those that received the initial funding are all automatically eligible, they will all be required to apply for the additional funding.

Like the original grant, you must be a participating Medicare provider and you must have provided care to a potential COVID-19 patient after January 31^st, 2020.  HHS defines all patients as potential COVID-19 patients.

Additionally, the provider must have filed a 2017, 2018, or 2019 Federal income tax return to apply.

How to Apply

Eligible providers can apply on the Provider Relief Fund Portal.

The HHS has provided the following information to assists users in applying for additional funding:

• An interactive user guide guiding you through the process step by step.
• A frequently asked questions (FAQ) document with addressing who can apply and the information required to apply.

Healthcare providers will need the following information to complete the application process:

• Taxpayer identification number of the taxpayer who received funds from the initial distribution of $30 billion,
• Amount of the payments previously received from HHS,
• Last six digits of the account where funds were deposited or the check number,
• Medicare or Medicaid ID,
• Estimate of lost revenue for March 2020 and April 2020, and
• Copy of most recently filed Federal tax return in PDF format for uploading (you will need to provide gross revenue – Aprio can assist in providing this required reporting information).

Applications are processed every Wednesday at 12 p.m. EST.  Funds are not disbursed on a first-come, first-served basis, however, Aprio recommends applying as soon as possible due to the uncertainty of when the allocated $20 billion of funds may be exhausted.

When HHS distributed the initial $30 billion in grants, they disclosed the formula used to calculate the payments, which allowed providers to estimate how much they would receive. For this second round of funding, HHS has not disclosed a methodology, but have noted the intent to “optimize the beneficial impact of the funds.” At this time, there is no way to calculate or estimate how much an individual provider will receive upon application for funding.

The HHS suggests that providers can expect to receive funds within 10 business days of submitting their applications.

Terms of Repayment, Terms and Conditions, Reporting Requirements

The terms of repayment, Terms and Conditions, and reporting requirements are the same as the original $30 billion of funding.  Aprio analyzed these terms and requirements at the time of their announcement; you can find a summarization of key points published on Aprio’s COVID-19 dedicated website.

If you believe you are eligible for the newly allocated funding, contact Aprio for additional guidance.