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Home arrow Public News arrow CARES Act and Relief Fund Terms and Conditions: Does a DC Qualify for Funding?
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CARES Act and Relief Fund Terms and Conditions: Does a DC Qualify for Funding?
By FCA Asst. General Counsel Kim Driggers   
Wednesday, 15 April 2020

See this HHS document for Relief Fund Payment Terms and Conditions.

The applicable and questionable terms are this, along with the highlighted sections to suggest that DCs CAN seek CARES fund relief:   

  • The Payment means the funds received from the Public Health and Social Services Emergency Fund (“Relief Fund”). The Recipient means the healthcare provider, whether an individual or an entity, receiving the Payment.
  • The Recipient certifies that it billed Medicare in 2019; provides or provided after January 31, 2020 diagnoses, testing, or care for individuals with possible or actual cases of COVID-19; is not currently terminated from participation in Medicare; is not currently excluded from participation in Medicare, Medicaid, and other Federal health care programs; and does not currently have Medicare billing privileges revoked.
  • The Recipient certifies that the Payment will only be used to prevent, prepare for, and respond to coronavirus, and shall reimburse the Recipient only for health care related expenses or lost revenues that are attributable to coronavirus.
  • The Recipient certifies that it will not use the Payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. 

HHS appears to be defining these terms very broadly to keep these offices going.  See this pertinent bullet point below from https://www.hhs.gov/provider-relief/index.html.


Who is eligible for initial $30 billion?
 
All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for this initial rapid distribution.  Payments to practices that are part of larger medical groups will be sent to the group's central billing office.  All relief payments are made to the billing organization according to its Taxpayer Identification Number (TIN).

As a condition to receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.

This quick dispersal of funds will provide relief to both providers in areas heavily impacted by the COVID-19 pandemic and those providers who are struggling to keep their doors open due to healthy patients delaying care and cancelled elective services.  If you ceased operation as a result of the COVID-19 pandemic, you are still eligible to receive funds so long as you provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19.

Based upon the above, many of our DCs will fit into the criteria for eligibility of CARES fund payments.