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Volume 20.20

The U.S. Department of Health & Human Services has released additional information regarding, among other things, the appropriate use of Provider Relief Funds.  According to HHS:

“The term “health care related expenses attributable to coronavirus” is a broad term that may cover a range of items and services purchased to prevent, prepare for, and respond to coronavirus, including:

  • Supplies used to provide healthcare services for possible or actual COVID-19 patients,
  • Equipment used to provide healthcare services for possible or actual COVID-19 patients,
  • Workforce training,
  • Developing and staffing emergency operation centers,
  • Reporting COVID-19 test results to federal, state, or local governments,
  • Building or constructing temporary structures to expand capacity for COVID-19 patient care or to provide healthcare services to non-COVID-19 patients in a separate area from where COVID-19 patients are being treated, and
  • Acquiring additional resources, including facilities, equipment, supplies, healthcare practices, staffing, and technology to expand or preserve care delivery.”

Furthermore, “the term “lost revenues that are attributable to coronavirus” means any revenue that you as a healthcare provider lost due to coronavirus.  This may include revenue losses associated with fewer outpatient visits, canceled elective procedures or services, or increased uncompensated care.  Providers can use Provider Relief Fund payments to cover any cost that the lost revenue otherwise would have covered, so long as that cost prevents, prepares for, or responds to coronavirus.  Thus, these costs do not need to be specific to providing care for possible or actual coronavirus patients, but the lost revenue that the Provider Relief Fund payment covers must have been lost due to coronavirus.”  The fact that revenues have declined does not, by itself, reflect that the revenue decline was COVID-19 PHE related.  Other facts and circumstances need to be identified and documented.

The additional guidance is included with other previously provided information here.

The additional guidance validates information that we have been providing.  HHS also clarified, as expected. that to the extent a provider can identify lost revenue as a valid use of Provider Relief Funds, the associated monies are available for general use by the provider in meeting other financial obligations (the use of Provider Relief Funds was validated through lost revenue).  Of course, Provider Relief Funds cannot be used for expenses covered through debt forgiveness associated with receipt of a PPP loan.

Eligibility for General Distribution Payments – Many providers do not bill Medicare for any services provided.  Clarification provides that “to be eligible for a General Distribution payment, providers must have billed Medicare on a fee-for- service basis (Parts A or B) in Calendar Year 2019.”

We encourage all providers to read the guidance very carefully and ensure that financial records incorporate, but separately identify, those expenses deemed to validate COVID-19 PHE expenses.