April 15, 2020

As part of our commitment to continuous education, PYA wants to help you and your organization

by offering timely and informative webinars related to COVID-19.

April 14, 2020

The PYA link below provides much more detail but some highlights are below.

https://www.pyapc.com/insights/covid-19-relief-funds-strings-attached/

Relief Fund payments are not loans–they do not have to be repaid or forgiven. However, this money comes with strings attached. Within 30 days of receipt, a provider must sign an attestation confirming receipt of the funds and agreeing to specific terms and conditions. The portal for signing the attestation will open the week of April 13 and will be linked from the CARES Act Provider Relief Fund website.

Terms and Conditions-

(1)        Certify that the provider currently provides diagnoses, testing, or care for individuals with possible or actual cases of COVID-19.

PYA interprets this condition to refer to the capability to provide healthcare services, since CMS made payments to providers of all specialties, as opposed to present engagement with potential COVID-19 patients. We expect clarification to be forthcoming. 

(2)        Certify that the provider is not currently terminated from participation in Medicare; is not currently excluded from participation in Medicare, Medicaid, and other federal healthcare programs; and does not currently have Medicare billing privileges revoked.

(3)        Agree to use the funds for healthcare-related expenses or lost revenues attributable to coronavirus.

(4)        Agree not to use the funds to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse.

PYA interprets this provision as preventing a provider from listing the same expense, or allowed portion thereof, as a covered expenditure under another COVID-19 relief program. For example, the portion of salary expenses listed under the Payroll Protection Program for purposes of loan forgiveness could not also be claimed as an expenditure of Relief Fund payments. Again, we expect clarification soon.

(5)        Agree not to balance bill any out-of-network patient for COVID-19-related treatment.

Keep in mind special provisions have been made regarding reimbursement for COVID-19 testing and treatment for uninsured individuals.

(6)        Agree to maintain and to submit upon request appropriate records and cost documentation including, as applicable, documentation required by 45 CFR § 75.302 and 45 CFR § 75.361 through 75.365, as well as other information required by future program instructions.

Also, a provider must agree to submit any HHS-required reports needed to ensure the provider’s compliance with conditions imposed on Relief Fund payments.

Specifically, any provider receiving more than $150,000 total in funds appropriated by any law relating to coronavirus response and related activities, must submit a quarterly report to HHS and the Pandemic Response Accountability Committee (and independent oversight committee created under the CARES Act), including the following information:

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 [each] 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 subcontracts 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. 

April 10, 2020 

Yesterday the FCC released information about a new funding opportunity of $200 Million in grants that will be made available to Physicians to support telehealth efforts.  Details can be found here:

https://docs.fcc.gov/public/attachments/DA-20-394A1.pdf