We posted yesterday that HHS Medicare relief payments were going out to practices who received Medicare FFS reimbursements during 2019.  This does not apply to the vast majority of you.  But for those to whom it does, we have an important update.   Acceptance of the funds is going to require that you certify several things are true.  One of those things is that your practice “currently provides diagnoses, testing, or care for individuals with possible or actual cases of COVID-19.”  We believe, in most cases, that is not valid and, therefore, you won’t be able to make that certification.  This information is subject to change once we have more details, but our current recommendation follows:

1.  Upon receipt of stimulus funds from HHS, segregate and hold the funds.

2.  Wait for additional guidance from HHS with regard to the certification that must be made regarding qualification for the retention of the stimulus money.  Guidance should be forthcoming later this week or next week.

3.  Within the 30-day period, and upon issuance of more clear guidance, if you meet the qualification requirement, then complete and submit the certification.  HHS has stated that they will be setting up a portal within the next week to permit physicians to make the required certification.

4.  If you can safely make the certification then the funds will not be treated as a loan, but will be instead a grant to accomplish the purposes of the $30 billion stimulus focused on healthcare providers.

5.  If you are unable to make the certification because you fail to satisfy more clearly stated qualification standards, then the money should be promptly returned to HHS.