The Coronavirus Aid, Relief, and Economic Security (CARES) Act includes $100 billion of funding to ensure healthcare providers on the front lines of the pandemic continue to receive the support they need for COVID-19-related expenses and lost revenue.

Payments being dispersed immediately

Recognizing the importance of delivering funds to healthcare providers as quickly as possible, $30 billion is being distributed immediately – with payments arriving via direct deposit beginning April 10, 2020 – to eligible providers across the country. All providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for this initial distribution.

Each provider’s share of the initial $30 billion will be based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019. A provider can estimate their payment by dividing their 2019 Medicare FFS (excluding Medicare Advantage) payments they received by $484 billion, and multiplying that ratio by $30 billion.

Receipt of funds

HHS has partnered with UnitedHealth Group (UHG) to provide these payments to providers. The automatic payments will made using automated clearing house information and come to providers via Optum Bank with "HHSPAYMENT" as the payment description. Providers who normally receive a paper check for reimbursement from the Centers for Medicare & Medicaid Services (CMS) will receive a paper check in the mail for this payment as well, within the next few weeks.

Confirming receipt of funds

Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The portal for signing the attestation will be open the week of April 13, 2020. If a provider receives payment and does not wish to comply with these terms and conditions, the provider must contact the Department of Health and Human Services (HHS) within 30 days of receipt of payment and then remit the full payment to HHS as instructed.

Terms and conditions

Although it is important for providers to understand all terms and conditions, there are two specific conditions related to reporting and documentation maintenance requirements that providers need to start thinking about immediately, so they are prepared to submit the first required report in July 2020.

The two specific conditions are as follows:

1. Report
   Not later than 10 days after the end of each calendar quarter, any provider receiving more than $150,000 total in funds under the CARES Act, the Coronavirus Preparedness and Response Supplemental Appropriations Act, the Families First Coronavirus Response Act, or any other Act primarily making appropriations for the coronavirus response and related activities, shall submit a report to the Secretary of HHS and the Pandemic Response Accountability Committee. This report shall contain: the total amount of funds received from HHS under one of the foregoing enumerated Acts; the amount of funds received that were expended or obligated for reach project or activity; a detailed list of all projects or activities for which large covered funds were expended or obligated, including: the name and description of the project or activity, and the estimated number of jobs created or retained by the project or activity, where applicable; and detailed information on any level of sub-contracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees, to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 allowing aggregate reporting on awards below $50,000 or to individuals, as prescribed by the Director of the Office of Management and Budget.
2. Documentation
   Providers shall maintain appropriate records and cost documentation including, as applicable, documentation required by 45 CFR § 75.302 – Financial Management and 45 CFR § 75.361 through 75.365 – Record Retention and Access, and other information required by future program instructions to substantiate the reimbursement of costs under this award.

Priorities for the remaining $70 billion

The administration is working rapidly on targeted distributions that will focus on providers in areas particularly impacted by the COVID-19 outbreak, rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.

Baker Tilly can help

We understand there are a multitude of funding programs healthcare providers can access, and implications for compliance and tracking to determine. We can assist your organization as you have needs. Connect with our healthcare team to discuss how we can help.