Billing, Federal Affairs, Private Practice, Telehealth

HHS Deposits Money Into Some Providers’ Bank Accounts

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April 10, 2020 APTA Federal Affairs Update

A $30 billion emergency relief package began rolling out on April 10, making direct deposits into provider and facility accounts based on 2019 Medicare billing.

Many health care providers — including PTs — caring for patients with possible or verified COVID-19 received a welcome surprise when they checked their bank accounts on April 10: an infusion of cash released as part of the most recent CARES Act pandemic relief package. The direct deposits are part of a $100 billion program that provides cash based on a provider's 2019 Medicare billing, under certain conditions.

Think you qualify and haven't received any money yet? Hang on, the Department of Health and Human Services says the payments will be released over the coming days.

What Just Happened
The $30 billion being released by HHS is part of a $100 billion Public Health Service Emergency Fund for health care providers. The funds are being made available to Medicare-enrolled individual providers and facilities that billed Medicare fee-for-service last year. The new funds are in addition to a recent $51 billion expansion to the Accelerated and Advanced Payment Program. But unlike that program, the money now being distributed doesn't have to be repaid.

How It Works
The money is being distributed proportionally, based on a provider's billing record for 2019. HHS decided on who gets what by determining the percentage that each provider's billing represents in terms of total Medicare payments made last year.

An HHS resource explains it this way:

"For example, if total Medicare fee-for-service payments in 2019 were $100, and one physician received $2 in payments from Medicare fee-for-service in 2019, then that physician accounted for 2% of total Medicare fee-for-service payments in 2019. According to this formula, that physician would receive 2% of this $30 billion."

Who Qualifies
There are terms and conditions related to who can receive the money — some of which are sure to prompt additional questions that can't be answered at this time.

A guidance document from HHS states that to qualify for the relief, the provider must currently provide "care for individuals with possible or actual cases of COVID-19," and must not currently be terminated from participation in Medicare or have billing privileges revoked. APTA has asked for additional guidance from HHS explaining if providers and facilities must be front line providers caring for patients with possible or verified COVID-19 infections, or if the funds can go to any health care provider continuing to deliver services during the public health emergency.

How the Money Can be Used
According to the terms and conditions, payments can be used only to "prevent, prepare for, and respond to coronavirus," with the payments themselves intended for "only health care related expenses or lost revenues that are attributable to coronavirus."

There are additional restrictions on use, including using the money for reimbursement of losses "that other sources are obligated to reimburse," as well as prohibitions on using the money to "advocate or promote gun control," lobbying, funding of abortions, and a host of other social and political issues.

If You Don't Qualify
HHS says that the intent behind the $30 billion program was to provide immediate relief and that "CMS has indicated that future rounds of funding from the $100 billion fund will have a more formal application process." Those future funding efforts could devote at least a part of the relief to "providers that do not typically bill Medicare."

More Details and Clarifications
Like many of the government actions taken in response to the pandemic, not every detail has been fully worked out, and there are bound to be questions that APTA and even the federal agency can't answer. APTA regulatory affairs staff is working to obtain as many details as possible about the program.

In the meantime, there are resources for more (if not full) detail. Here are a few:

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