Wednesday, June 3, 2020

June 3 Attestation Deadline Applies Only to Medicare FFS Provider Relief Payment 

The U.S. Department of Health and Human Services clarified that the June 3 deadline for providers to submit revenue data:
  • Is only for providers who received a Tranche 1 allocation and would like to submit financial information to receive additional Tranche 1 funding. 
  • Providers would still be required to ensure that their General Distribution payment is the lesser of 2% of their provider net revenue or the sum of incurred losses for March and April.
Below is the relevant HHS webpage text:  

Providers must submit revenue information to the General Distribution Portal by June 3, 2020 to be considered for an additional payment from the Provider Relief Fund $20 billion General Distribution. Once providers submit their revenue information by June 3, 2020, if deemed qualified for additional payment, providers will then have 90 days from receipt of payment of the additional General Distribution funds to agree to the program Terms and Conditions.

AHCA/NCAL recognizes how challenging the lack of guidance is for members. The Association is working with HHS to secure additional information.

All other questions about the fund should be directed to HHS Hotline at (866) 569-3522. HHS reported on May 22 that the call center now has access to additional data and new HHS guidance to better answer questions.

Tranche by Tranche Questions

Tranche 1
: HHS as provided the formula and allocation process in its FAQs. The data source for the award amounts was 2019 Medicare Part A Fee-For-Service (FFS) net revenue.

Tranche 2: As above, HHS has provided the formula for Tranche 2 in its FAQs. Of note, HHS explains why a provider who received a Tranche 1 award may not have received a Tranche 2 award. The data source for Tranche 2 was 2018 Medicare Cost Report.

Tranche 3: (SNF-Only): All SNFs with Medicare-certified beds should have received an allocation on May 22. If the SNF did not receive an allocation this could be because:

  • it is a Medicaid-only or private pay only facility; or
  • errors in HHS’ data source (April 2020 CASPER Report).

If the SNF believes they should have received a Tranche 3 award or received the incorrect amount, they should contact the Hotline (above) and have the following information ready:

  • Tax Identification Number(s) (TIN)
  • CMS Certification Number(s) (CCN)
  • Dollar amount in question by building

Also, for Tranche 3, the SNF Allocation, have the number of SNF certified beds (Medicare, Medicaid or both), the amount they received and the amount they believe they should have received.

At this point, the above information is all HHS has shared. AHCA/NCAL continues to request clarification on Change in Ownership, TINs and reporting window information.

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