Wednesday, June 3, 2020

HHS Releases Guidance on Important CARES Fund Questions

Late yesterday, June 2, HHS released updated FAQs with long awaited guidance on Tax Identification Numbers (TIN) and has explained use of Gross Receipts. In addition to the TIN s FAQs, HHS also added or updated other FAQ topic areas. That information is listed below the TIN information. To find updated, Gross Receipts language, AHCA/NCAL recommends downloading a copy of the FAQs as a PDF and conducting a key word search.

  • In the case of a parent organization with multiple billing TINs that may have each received payment, may the parent organization attest to the Terms and Conditions and keep the payments?
  • In the case of a merger of a provider entity (billing TIN) into another entity (billing TIN), or the consolidation of two or more entities (each with a billing TIN), resulting in the creation of a new entity (single billing TIN) between January 1, 2018 through January 31, 2020, how should the entities apply?
  • A parent entity submitting an application for a General Distribution payment from the $20 billion payment tranche has more than 20 subsidiaries with Billing TINs. How should it complete the application in the Provider Relief Fund Payment Portal?
  • A parent entity files a tax return (“Filing TIN”) but does not bill Medicare. The parent entity has one or more subsidiaries that bill Medicare (“Billing TIN”) but do not file tax returns (disregarded or consolidated entities). Accordingly, the parent entity did not receive a payment under the $30 billion General Distribution and entering the parent’s Filing TIN does not allow the Provider Payment Portal application to proceed. How should this be addressed with respect to the application?
  • Can a parent organization transfer Provider Relief Fund payments to its subsidiaries?

Other New FAQ Information

HHS also has added or modified language on the SNF Allocation, High Impact Allocation. Other themes in updates are:

Eligible Uses of Fund Dollars

The Terms and Conditions state that Provider Relief Fund payments will only be used to prevent, prepare for, and respond to coronavirus and shall reimburse the Recipient only for healthcare-related expenses or lost revenues that are attributable to coronavirus. What expenses or lost revenues are considered eligible for reimbursement? (6/2)

Resubmission of Information
  • I submitted my revenue information in the Provider Payment Portal. Why am I being asked to resubmit my information?
  • What action should I take in order to resubmit my revenue information?
  • Will the amount of the potential payment be affected if my submission has been identified for resubmission?
  • Do all providers who submitted revenue information in the Provider Payment Portal have to resubmit their information?
  • If I changed my mind after I rejected a Provider Relief Fund Targeted Distribution payment through the Attestation Portal and returned the payment, can I receive a new payment?
Executive Compensation
  • What is the definition of Executive Level II pay level, as referenced in the Terms and Conditions? 
Change in Ownership
  • How should an organization currently undergoing a change in ownership to purchase a practice report revenue in its application?

AHCA/NCAL recognizes an array of unanswered questions remain including additional detail on CHOW and the 10 Day Reporting window included in the Terms and conditions. HHS appears to be following through on its promise to address questions and, as soon as additional information is available we will share it.

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