Note: Previous webinar resources (slide decks, replay videos, Q & A transcripts, etc.) are available here.
Virtual Town Hall w/Asbel Montes
Your Questions. Answered Live.
June 17, 2020
Questions and Answers Transcript
Has there been any further clarification about billing the HRSA Covid-19 Uninsured program for presumptive patients?
It was always under the assumption that presumptive and positive we're going to be paid. But unfortunately, that terms and conditions that you sign is for positive patients.
It has not been clarified right now. Currently, It is for positive only. There are additional avenues available for reimbursement for uninsured patients but that would be an effort at the state and local level.
Aside from HHS or PPP what other forms of relief should we be looking into?
There are 3 buckets of funding available: Payroll Protection Program, CARES Act Funding and FEMA. The CARES Act funding has a few avenues available: (1) distributions through Health & Human Services (HHS), as well as distributions through the Coronavirus Relief Fund (CRF). The CRF funds are distributed directly to state and local governments by the U.S. Treasury. These funds are available for loss revenue and increased expenses related to the Public Health Emergency. You will need to work with your state government and/or local jurisdictions to get access to these funds.
How long do we have to submit bills for uninsured COVID?
Until they run out of money and the public health emergency is over. We haven't been notified yet that they ran out of money... I would keep submitting your claims until they tell you there's no more money left available.
If we were denied for the second wave of HHS funding, can we still apply for the third wave?
I'm assuming when you mean denial that the formulary had you as a negative, so that's not really a denial. If that is what you are referencing, it just means that you did not qualify for a second level because the formula funding saw that you had already received a substantial amount of money based upon the formulary that was put together (i.e. 2% of that net operating revenue number based upon your tax filings or your balance sheet and that you uploaded your audited financials). Technically, yes, you would apply. From what I understand, it's going to be another application process.
Is there an update regarding HHS uninsured funding applying to only uninsured? I wonder about the time period for submitting those claims and receiving dedicated funds. Areas of the country are currently seeing spikes.
Right now, the uninsured funding is only available to those uninsured. When you read the terms and condition, you have to verify that they have no other insurance source. And, according also to Terms and Conditions you signed, it's only available to positive COVID patients. As of right now, there is no end date on that. Basically, as long as there's funds available, they are going to reimburse for the uninsured COVI-19 positive patients.
Is there any stimulus money for additional cost that we have incurred due to Covid-19? If so, how do we apply for them?
In the next allocation, you'll see the application process open up. We're not really sure yet what the formulary is. We do understand that it is going to be looking at increased expenses aound the PPE area. Also an update to your lost revenue numbers, because you only recorded March and April and we're now into June.
Since we provided March/April lost revenue re the CARES Act, does this mean we are prohibited from claiming lost revenue from other government reimbursement sources? If so, can we seek lost revenue for other months from the Feds?
You need to have a formalized documentation system that is keeping track of all funding received due to the Public Health Emergency. This could be funding received from the Paycheck Protection Program, FEMA, HHS and any funds received from state or local government related to the PHE. Once the PHE is rescinded, you will then need to compare your lost revenue and increased expenses throughout the PHE to the revenue you received from all sources. If you have received more revenue, you will need to reimburse the federal government. If you have receive less revenue from federal sources compared to your lost revenue and increased expenses, then you will not be required to refund the federal government. Documentation will be key! Document, document, document!
When are the first CARES Act quarterly reports due? Are there any published report specifications and requirements?
Currently, the only requirement is to submit your financial statements via the attached portal. If you have already done this through Tranche 2 funding, then nothing is due at this time. If you did not complete the application for Tranche 2 funding, you will need to follow the instructions as indicated.
When will be get notified if we will receive money under Tranche 2 of HHS?
You should have been notified already. If not, please call (866) 569-3522.
Will any part of the funding provided to state and local governments under the US Treasury Coronavirus Relief Fund (i.e. the $1.25 billion minimum to each state) eventually be allowed for revenue replacement?
Currently, the CARES Act direction is specific on what state and local governments can use these funds for.
The guidance clarifies what costs are permissible under the CRF, noting that necessary expenditures incurred due to the public health emergency:
- Must be used for actions taken to respond directly to the COVID-19 public health emergency
- May include expenditures incurred to address medical or public health needs, as well as to respond to second-order effects of the emergency, such as providing economic support to those suffering from employment or business interruptions
- Can’t be used to fill shortfalls in government revenue to cover expenditures that wouldn’t otherwise qualify under the statute
Only certain costs not accounted for in the government’s budget most recently approved as of March 27, 2020 are permitted. Costs will, however, meet the above requirement if the cost:
- Can’t lawfully be funded using a line item, allotment, or allocation with that budget
- Is for a substantially different use from any expected use of funds in such a line item, allotment, or allocation
A cost isn’t considered to have been accounted for in a budget merely because it could be paid from a budgetary stabilization fund, rainy day fund, or similar reserve account.
Will the Medicare sequestration roll back be permanent or will the 2% be back?
The Medicare sequestration roll back is temporary only and expires on 12/30/2020. It remains to be seen if Congress will make this permanent or not.
Will the Round Two Cares Act Application Portal open up again? We didn't have enough time to complete the application and want additional funding.
Round Two closed on 6/3/2020. HHS will be doing a Round 3 funding soon.
Any updates on auditing or reporting - can we just claim a revenue loss based on call volume or do we also have to show what the money was spent on?
Based upon the FAQ posted on 6/13/2020 via https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/index.html. See the following:
Recipients of Provider Relief Fund payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee. HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with this provision. For all providers who attest to receiving a Provider Relief Fund payment and agree to the Terms and Conditions (or retain such a payment for more than 90 days), HHS is posting the names of payment recipients and their payment amounts on its public website Tracking Accountability in Government Grants System (TAGGS). HHS is also working with the Department of Treasury to reflect the aggregate total of each recipient's attested to Provider Relief Fund payments on USAspending.gov. Posting these data meets the reporting requirements of the CARES Act. See Appendix A of OMB Memo M-20-21 - PDF [Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19)].
However, the Terms and Conditions for all Provider Relief Fund payments also require recipients to submit any reports requested by the Secretary that are necessary to allow HHS to ensure compliance with payment Terms and Conditions. HHS will be requiring recipients to submit future reports relating to the recipient's use of its PRF money. HHS will notify recipients of the content and due date(s) of such reports in the coming weeks.
We have never had to submit Cost Data for Novitas, but understand it is a requirement due to the HHS funding. What format do we submit it in and where?
Please see answer above.
Traunch 3 includes all providers, including hospitals?
They're indicating it is a general allocation. And if it's a general allocation, then it would include everybody. Do not hold me to that. Remember, this is what they were thinking. They could make it a little bit more specific because the hospitals have been receiving a ton of money. And many of you have been probably talking to some of your hospital colleagues and some of them are actually sending money back because they've got way too much that they can't justify, especially in areas that may not have been hotspots that right now, if it is a general allocation, it would include all suppliers and providers of health care.
Could you please talk about the application due July 20th for the upcoming $15B HHS allocation for agencies participating in Medicaid and CHIP?
If you received funding in Round 1 or Round 2, you will not be eligible for the Medicaid and CHIP funding.
Are there any tax implications for the CARES ACT funds?
I'm going to tell you to get with your tax advisor on that. That is not my area of specialty. And there are depending upon how you have set yourself up. But I would definitely get with your tax advisor on that.
We teach EMT classes. Do these lost revenues count?
Anything related to the provision of healthcare that's related to the corona virus and pandemic would qualify. If you teach EMT classes and that was a source of revenue and because of the pandemic, you've seen a loss of EMT. And so you've seen a loss of revenue related to that. That would be a justifiable revenue loss.
If a patient becomes retroactive with Medicaid and we already received payment from the Uninsured Program - how do we go about contacting HRSA for refunds?
If at the time you validated and checked for insurance, and the patient had not insurance for a COVID-19 positive patient, then you do not need to file Medicaid if they received retroactive coverage. You just need to be able to prove under audit that when you filed you verified eligibility.