Estate and Succession Planning
Dean Mead’s Estate and Succession Planning Department is one of the largest and most respected groups of estate planning attorneys in Florida. We are frequently…
On Friday, April 10, healthcare providers began receiving relief payments provided for in the CARES Act from the Department of Health & Human Services (HHS). Payments are made according to the Tax Identification Numbers (TIN) under which Medicare is billed (i.e., payment is not being made to individual providers unless they are solo practitioners). Payment will primarily come via Automated Clearing House (ACH) payments; however, providers who normally receive reimbursement by check will receive paper checks by mail. The initial amount of funds being distributed to providers is $30 Billion, with another $70 Billion to be distributed later. The payments are based on the provider’s share of total Medicare FFS reimbursements in 2019.
These funds are payments, not loans. They do not need to be repaid provided that the healthcare provider attests to the following via a web portal to be opened on Monday, April 13, 2020:
- The provider must certify that it billed Medicare in 2019; currently provides diagnoses, testing or care for individuals with possible or actual cases of COVID-19; is not currently terminated from participation in Medicare; is not currently excluded from participation in Medicare Medicaid, and other federal health care programs; and does not currently have Medicare billing privileges revoked.
- The provider certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus, and shall reimburse the provider only for health care related expenses or lost revenues attributable to coronavirus.
- The provider certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse.
- The provider agrees to submit certain reports as required by HHS, and to maintain appropriate records and cost documentation.
- The provider certifies that for all care for a possible or actual case of COVID-19, it will not seek to collect from the patient out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.
The Relief Fund Payment Terms and Conditions are available here. These attestations must be made via the web portal within 30 days following receipt of the relief payments.
More guidance as to eligibility and the terms and conditions for keeping these payments is expected to be issued in the coming weeks. In the meantime, access the link to the guidance currently available through the Department of Health and Human Services here.
We will continue to update you as we learn more on this important relief available to our healthcare provider clients.
