HHS relief update

HHS Certification Details – Tuesday, April 21, 2020 12:03PM

The HHS released the portal to certify payments from The Public Health and Social Service Emergency Fund. Payments must be certified within 30 days of deposit and the portal can be found here: https://covid19.linkhealth.com/#/step/1 
To refresh, payments are for facilities that received FFS Medicare payments in 2019 and its purpose is to support healthcare-related expenses or lost revenues that are attributable to COVID-19. More importantly, the payments are not loans and do not require repayment.

Generalized Terms and Conditions to certify are:

  1. The recipient of disbursement billed Medicare in 2019, is not currently terminated or excluded in participation in Medicare, and is providing or provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 after January 31, 2020. 
    NOTE: For the purpose of these Terms, the HHS says care does not have to be specific to COVID-19 and the HHS views every patient as a possible case of COVID-19. So if you were seeing patients in February 2020 and still participated in Medicare, you were caring for possible COVID-19 patients and are eligible for funds.
  2. Payments can only be used to prevent, prepare for, and respond to coronavirus. The payment is meant to reimburse the recipient for health care related expenses and lost revenues that are attributable to coronavirus. The recipient must certify that the payment will not be used to reimburse expenses or losses that are being reimbursed from other sources.
    NOTE: This would include EIDL/PPP loans. If you have a PPP loan approved and receive a payment from this Fund, the payment from the Fund cannot be used for payroll, rent/leases, utilities, or mortgage obligations. Think about loading up on medical/sanitation supplies to “respond” to coronavirus once you get back to nonemergency procedures.
  3. You must not collect from any out-of-network patient more than what their out-of-pocket expense would be if they had been an in-network to the recipient.

NOTE: There may be reporting requirements to which certified recipients may be subject. The Terms indicate these would be “records or cost documentation” on what the reimbursement was used for, but the HHS has not released an official guidance on reporting so there is no mandated reporting at the moment. However, it’s advised to keep diligent records as these standards are evolving.

Full list of Terms and Conditions can be found here: https://www.hhs.gov/sites/default/files/relief-fund-payment-terms-and-conditions.pdf