Wednesday, May 27, 2020

CARES Attestation Window Extended, Updated Guidance & Financial Resources

On Friday May 22, U.S. Department of Health and Human Services (HHS) extended the CARES Act Provider Relief Fund attestation window. This allows time to address additional questions and to offer providers time to collect necessary payment portal information. In the press statement, HHS announces that the attestation window and related acceptance of Terms and Conditions has been extended from 45 to 90 days from the date a provider received a payment to attest to and accept the Terms and Conditions or return the funds. Providers should have received emailed letters from HHS on Friday. Providers should have received emailed letters from HHS on Friday.

Members will need to identify the dates of each relief payment and identify their new attestation and Terms and Conditions acceptance date based on the extension. HHS updated the Fund FAQs twice this past week.

AHCA/NCAL has updated the COVID-Related Cost and Loss Calculator and prepared a guidance document on the CARES Act Provider Relief Fund (member login required for both resources). The guidance includes:

  • Updated AHCA/NCAL CARES Act Provider Relief Fund FAQs;
  • A merged version of Tranches 1 and 2 Terms and Conditions with easily identifiable changes as well as a redline version of the SNF Allocation Terms and Conditions showing differences relative to the Tranches 1 & 2 Terms and Conditions. SNF Allocation has its own Terms & Conditions. Each of the three versions of the T&C must be attested to using TINs and award dollar amounts; and
  • A table containing key FAQs and AHCA/NCAL interpretations of HHS guidance.

Questions about Award Amounts

If you have questions or concerns about Tranches 1, 2, 3 awards, contact the HHS Hotline at (866) 569-3522. HHS reported on Friday that the call center now has access to additional data and new HHS guidance to better answer questions. When calling have the following information ready:
  • TIN(s)
  • CCN(s)
  • Dollar Amount in question by tranche and by building
Also, if questions about Tranche 3, the SNF Allocation, also have the number of SNF certified beds (Medicare, Medicaid or both) as well as the amount you received and the amount you believe you should have received.

For Tranches 1 and 2, in its May 14 FAQ update, HHS provided an explanation of why a building might not have received a Tranche 2 allocation. The FAQ provides a formula and explanation of how a Tranche 1 award may have impacted eligibility for Tranche 2. See FAQs on page 7 of the updated FAQ document. HHS added Change in Ownership (CHOW) FAQs as well as TIN FAQs. The latter FAQs are called out in the AHCA/NCAL Guidance document in addition to inclusion in the HHS FAQs.

Next Steps – Additional CHOW, TIN, and Other Questions

AHCA/NCAL will continue to submit questions and examples of challenging fund scenarios to HHS including CHOW, TIN aggregation, disaggregation, and additional questions about financial terminology and use of tax filing data for validation. However, HHS has verbally indicated the Department’s goal is “maximum flexibility.” While we will continue work with them during the additional assentation window time, it is possible they will defer to reconciliation and reporting documentation to address all scenarios.

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