The Department of Health and Human Services (HHS) has made several important announcements concerning the distribution of the $175 billion Provider Relief Fund:
| The application process for the Phase 1 General Distribution, available to providers who bill Medicare fee-for-service (FFS) for any amount, is being reopened starting the week of August 10th. The process will remain open through August 28th. The application process for the Phase 2 General Distribution, available to providers who bill Medicaid or CHIP but not Medicare, is beingextended through August 28th. HHS also plans to offer a simplified application form for this portal. HHS will publish reporting requirements for recipients of Provider Relief Fund money by August 17th. Reports will be due in 2021, and all funds must be expended and reporting completed by July 31, 2021. |
Below are some common questions concerning these updates.
Who is eligible to apply under the reopened Phase 1 distribution?
During April, providers who billed Medicare FFS for any amount during calendar year 2019 should have received a direct payment via ACH to the bank account where they receive Medicare payments. If you received such a payment but did not follow up by submitting further revenue information through CMS’s portal, you are eligible to resubmit during this period. HHS notes that this includes “many Medicaid, CHIP, and dental providers with low Medicare revenues,” who incorrectly believed they would instead be eligible for the Phase 2 Medicaid distribution.
Additionally, providers who experienced a change in ownership in 2020 may have failed to receive a payment. Since funds were distributed based on 2019 payment data, payments went to the original owners, who are obligated to return them to HHS. In such cases, the new owners of such providers may apply for Provider Relief Fund payments during this period.
How much money will the reopened Phase 1 distribution provide?
HHS is seeking to give each provider 2 percent of their annual revenues due to patient services. Since eligible providers will have received a direct deposit in April, they will now be eligible to receive the difference between the amount of that direct deposit and 2 percent of annual patient revenue. In this way, each provider will be “topped up” to receive 2 percent of annual patient revenue.
What if a provider did not bill Medicare FFS in 2019?
Current guidance states that such providers are not eligible for the Phase 1 general distribution. If they bill Medicaid, Medicaid managed care, the Children’s Health Insurance Program (CHIP), or provide dental services, they are eligible for Phase 2 of the general distribution. HHS plans to offer future relief funding to providers who do not fall into any of these eligibility categories, such as:
- Providers who bill only commercial or other payers;
- Providers who do not directly bill for Medicare or Medicaid services; and
- New providers in 2020.
When can providers apply?
For Phase 1 (Medicare FFS-billing providers), HHS plans to reopen the portal the week of August 10th. For Phase 2 (Medicaid/CHIP providers and dentists who do not bill Medicare), the portal is now open, and HHS plans to offer a simplified application form shortly.
Is there a deadline to use Provider Relief Fund money?
HHS has now established that funds must be spent by July 31, 2021, after which unused funds must be returned.
What are the reporting requirements for organizations receiving Provider Relief Funds?
Up to two reports will need to be filed by any provider who receives at least $10,000 of Provider Relief Fund money:
- All providers must file a report on their 2020 usage of funds. Reports may be submitted between October 1, 2020 and February 15, 2021. If all funds have been expended, no further reporting will be required.
- Providers who still retain unexpended funds after December 31, 2020 must submit a second and final report on their usage of funds during 2021 by July 31, 2021.
HHS will publish more detailed reporting requirements, including a template for submission, by August 17th.