FEDERAL AND STATE FINANCIAL RELIEF ASSISTANCE
[May 21] HHS Updates CARES Act Provider Relief Fund FAQs The U.S. Department of Health and Human Services (HHS) issued updated guidance for Medicare providers receiving payments from the CARES Act Provider Relief Fund. The updated frequently asked questions (FAQs) document addresses common questions on attestation and rejecting payments (beginning on page two) with the notation “added 5/20/2020.” The FAQs also provide guidance on revenue reporting through the portal, entering taxpayer identification numbers into the General Distribution Portal, estimating lost revenue, and the definition of a rural facility.
[May 20] Deadline to Accept HHS Provider Relief Funds is June 3 On May 20, the U.S. Department of Health and Human Services (HHS) reminded eligible healthcare providers that they have until June 3 to attest to receipt of payments from the Provider Relief Fund, accept the terms and conditions, and submit their revenue information to potentially qualify for an additional payment from the $50 billion general distribution. All providers who automatically received an additional General Distribution payment prior to 5:00 pm, Friday, April 24, must provide HHS with an accounting of their annual revenues by submitting tax forms or financial statements. Providers who do not submit revenue information by June 3 will no longer be eligible to receive additional funding. Read More
[May 19] Medicare Reimbursement for COVID-19 Diagnostic Tests On May 19, the Centers for Medicare & Medicaid Services (CMS) updated its guidance on payment for COVID-19 diagnostic tests to include details for additional CPT codes created by the American Medical Association as well as specific reimbursement rates from Medicare Administrative Contractors (MACs). For COVID-19 tests that do not use high throughput technology, MACs developed payment amounts for claims that will be used until CMS establishes national payment rates. There is no cost-sharing for Medicare patients. Read More
[May 15] SBA Releases Application for PPP Loan Forgiveness On May 15, the Small Business Administration (SBA) released an application and instructions for Paycheck Protection Program (PPP) loan forgiveness. The borrower is expected to complete the application and submit it to their lender, who will ultimately be responsible for assessing forgiveness. The process can be completed electronically. The SBA plans to issue regulations and guidance to further assist borrowers as they complete their applications and to provide lenders with direction on their responsibilities.
[May 7] HHS Extends Provider Relief Fund Payment Deadline to 45 Days for Attestation, Acceptance of Terms and Conditions The U.S Department of Health and Human Services (HHS) has extended the deadline for healthcare providers to attest to receipt of payments from the Provider Relief Fund and accept the Terms and Conditions. Instead of 30 days, providers will now have 45 days from the date of payment receipt to attest and accept the Terms and Conditions or return the funds. Under the new deadline extension, providers who have not returned payments within 45 days of receipt of funds will be deemed to accept the program’s Terms and Conditions. Additional information on the deadline’s extension is available HERE.
[May6] SBA Extends Deadline to Return PPP Loans to May 14 The U.S. Small Business Administration (SBA) has extended the safe-harbor period for returning Paycheck Protection Program (PPP) funds by one week to May 14. The previous deadline for returning funds (May 7) was initially provided for entities that received PPP funds [removed comma] but then determined that they were unable to certify in good faith that their PPP loan was necessary. For additional guidance from the SBA, please see question 45 (bottom of page 15) on the FAQ document.
[April 30] Federal Reserve Announces New Details on Main Street Lending Program The Federal Reserve released updated information and an FAQ regarding its Main Street Lending Program. This loan program was created through the CARES Act to help small and medium-sized businesses, like physician practices, via the provision of credit to companies that were in sound financial condition prior to the COVID-19 pandemic. The new Main Street loans can range from $500,000 to $25 million but are full-recourse loans and are not forgivable. The program has not yet been operationalized. The Academy will provide additional details on the program as they become available.
[April 30] NOW OPEN: HRSA COVID-19 Uninsured Program Portal Clinicians who have conducted COVID-19 testing or provided treatment for uninsured individuals with a COVID-19 diagnosis on or after February 4, 2020, are now eligible for reimbursement through the U.S. Department of Health and Human Services (HHS) Health Resources and Services Administration (HRSA) COVID-19 Uninsured Program. Funding is subject to availability. The portal to register to participate in the program is now open. Once registered, providers can begin to submit claims electronically on May 6. To receive funding, providers must attest that no other payer will reimburse them for COVID-19 testing or treatment, accept the defined program reimbursement as payment in full, and abstain from balance billing. The agency has prepared a FAQ document outlining eligibility for the program, reimbursement rates, and terms and conditions for participation.
[April 27] An updated CMS fact sheet outlining the programmatic changes is available HERE
[April 26] CMS Reevaluates Accelerated Payment Program and Suspends Advance Payment Program PRESS RELEASE
On April 26, CMS announced that, effective immediately, it is suspending its Advance Payment Program for Part B suppliers and reevaluating the amounts that will be paid under its Accelerated Payment Program. CMS had expanded these temporary loan programs to provide frontline providers with immediate financial support needed to combat the beginning stages of the COVID-19 pandemic. CMS reports that, since March 28, 2020, approximately $40 billion in advance payments has been sent to physicians, nonphysician providers, and other suppliers. As noted in the Academy’s recent email updates, additional grant funding will continue to be available to Medicare providers and suppliers primarily via the U.S. Health and Human Services Provider Relief Fund.
[April 25] PORTAL IS OPEN: HHS Releases Additional $20 Billion in CARES Act Provider Relief Funding
On April 22, the U.S. Department of Health and Human Services (HHS) announced that it is adding an additional $20 billion to the CARES Act Provider Relief Fund. All facilities and providers with a Medicare Provider Number are eligible for these funds. As of Friday, April 24th, HHS has already distributed $30 billion of the $100 billion fund to providers, in proportion to their Medicare Fee for Service payments in 2019. These distributions were sent directly to providers by automatic deposit or by paper check. Providers were not required to engage in any activity or application in order to get these funds, though providers are required to sign an attestation if they wish to keep the funds.
As part of the distribution of the remaining $70 billion in funds, HHS is asking providers who have already received payments from the initial distribution of $30 billion to supply information from IRS tax filings and to supply estimates of lost revenues in March and April of 2020, if they wish to be eligible to receive additional funds. HHS will be distributing an additional $20 billion to these providers.
This morning, HHS opened the portal for providers to attest to their net 2018 revenue for purposes of determining the new allocation of funds. All providers who accept these funds must accept terms and conditions, such as abstaining from balance billing for care delivered to patients with presumptive or actual cases of COVID-19. Additional terms and conditions include submitting documentation to ensure funds received were used for healthcare expenses or to cover lost revenue from the COVID-19 Public Health Emergency.
- THE LINK TO THE PORTAL IS HERE.
- AN INSTRUCTIVE USER GUIDE ON THE NEW PORTAL AND FUNDING IS AVAILABLE HERE: USER GUIDE
[April 24] SBA to Resume Accepting PPP Applications on Monday, April 27
The Small Business Administration will resume accepting Paycheck Protection Program (PPP) loan applications on Monday, April 27 at 10:30 am (ET) from approved lenders on behalf of any eligible borrower. The program authorized under the CARES Act was quickly depleted of funds after only two weeks of operation. Following enactment of the Paycheck Protection Program and Health Care Enhancement Act, an additional $321 billion in funding for PPP loans was appropriated. Of the $321 billion in funding, $60 billion is set aside for small, midsize, and community lenders (including minority lenders).
As noted in previous communications, for those who are seeking but have not received PPP funds, we urge you to apply immediately with your community lender. Read the SBA press release.
[April 24] Fourth Coronavirus Relief Package Signed into Law
Today, April 24, the President signed into law, the “‘Paycheck Protection Program and Health Care Enhancement Act." The Act provides $484 billion in new funding to support the federal government’s response to the COVID-19 pandemic. Highlights of this fourth COVID-19 relief package, which directly impact practicing otolaryngologist-head and neck surgeons, include an additional:
- $321 billion in funding for the Paycheck Protection Program, with a special focus on community banks and credit unions
- $75 billion in funding for hospitals and Medicare providers to support COVID-19 related expenses and lost revenue
- $60 billion in funding for Economic Injury Disaster Loans
- $25 billion for state-led COVID-19 testing plans, research and development, with funding support for federal agencies such as the CDC and the NIH
We expect certain portions of this additional funding to become immediately available. The AAO-HNS will continue to provide updates as they develop.
CARES ACT RELATED FINANCIAL RELIEF INFORMATION
- HHS CARES Act Provider Relief Fund [April 10]
- Paycheck Protection Program Application Form – According to the SBA, lenders may begin processing loan applications as soon as April 3, 2020
- U.S. Treasury Overview of Paycheck Protection Program
- U.S. Treasury PPP LOANS Frequently Asked Questions (FAQs) [UPDATED April 24]
- U.S. Treasury Interim Final Rule on Requirements for Promissory Notes, Authorizations, Affiliation, and Eligibility [UPDATED April 24]
- U.S. Treatury Interim Final Rule on Additional Criterion for Seasonal Employers [April 28]
- U.S. Treasury Interim Rule on Final Disbursements [UPDATED April 28]
- Important Overview Highlights for the Paycheck Protection Program
- CARES Act and Special Message from James C. Denneny III, MD, AAO-HNS EVP/CEO [March 27]
- CARES Act: Paycheck Protection Program (PPP) Loans Q&A [March 28]
- Small Business Administration: Coronavirus (COVID-19): Small Business Guidance & Loan Resources
- Small Business Administration: Lender Search Tool - Use this tool to find a nearby lender eligible to issue a loan under the Paycheck Protection Program.
[April 16] Update on Paycheck Protection Program and Financial Relief Resources: Special Message from James C. Denneny III, MD, AAO-HNS Executive Vice President and CEO
One of the cornerstone pieces of legislation designed to help small business owners was the CARES Act, which contained the Paycheck Protection Program (PPP) that allocated $349 billion to offset small business owner’s costs of maintaining employees. The initial funding for the PPP has been expended and the Small Business Administration (SBA) has stopped accepting applications. My colleagues in the banking industry are recommending that you apply for a PPP loan through your community bank. They indicate that the applications will be processed by the banks and then submitted to the SBA when additional funding is provided by Congress. Your Academy continues to lobby for further economic support of our distressed practices and expects that there will be additional support available in the future.
[April 16] Did You Get a PPP Loan? Tips for Managing the Funds
In the SBA PPP report, as of April 13, 1,035,086 loans had been distributed in the amount of $247,543,393. Of total funds distributed 11.27 percent were directed to "Health Care and Social Assistance." If you received a PPP loan since the program opened on April 3, there are some valuable tips to consider in tracking the management of those funds, or any COVID-19 relief monies you receive, such as setting up a separate bank account dedicated specifically to the accounting of those funds. There are numerous sources of guidance to make future forensic accounting more fluid. While we don't recommend or endorse any one source, this information provided by Inc., offers a few quick steps to ensure success in managing these funds.
HHS Announces $30 Billion of CARES Act Relief Funding to Providers
On April 10, the Department of Health and Human Services (HHS), announced it will begin delivery of an initial $30 billion in relief funding to healthcare providers. The funding is part of the $100 billion passed in the coronavirus aid, relief, and economic security, or CARES, Act. Rapid distribution of the funds will go to hospitals and providers across the United States who received Medicare fee-for-service (FFS) reimbursements in 2019. This initial $30 billion is being directed to hospitals and physician practices in direct proportion to their share of Medicare fee-for-service spending. The total amount of Medicare FFS spending in 2019 was $484 billion. Hypothetically, if a Medicare provider with a Taxpayer ID Number (TIN) accounted for 1% of total Medicare FFS spending in 2019, the TIN would receive 1% of the $30 billion. These are payments, not loans, to healthcare providers, and will not need to be repaid. Providers do not have to apply. In order to receive these funds, providers must agree to accept Medicare rates for patients who are uninsured and not to seek to collect a “surprise” balance bill from a COVID-19 patient. HHS is partnering with UnitedHealth Group (UHG) to deliver the initial $30 billion of relief as soon as possible. Providers will be paid through Automated Clearing House information already on file with CMS or UHG. Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The portal for calculating one’s applicable payment and signing the attestation will be open the week of April 13, 2020, and will be linked HERE. Be sure to read the Terms and Conditions linked on this site prior to signing up. Additional details regarding the CARES relief funding can be found HERE.
House of Medicine Letter on CARES Act Emergency Funding
Today, April 7, 2020, the AAO-HNS joined scores of groups across the House of Medicine in sending a letter to U.S. Secretary of Health and Human Services (HHS) Alex Azar regarding immediate financial relief for physician practices. The coalition urged HHS to provide one month of revenue to each physician (MD or DO) enrolled in Medicare or Medicaid to account for financial losses and non-reimbursable expenses resulting from the COVID-19 crisis. This funding was included in the CARES Act, which authorized $100 billion in direct financial support for healthcare providers.
ADDITIONAL FINANCIAL RELIEF RESOURCES:
- U.S. Department of Labor, Families First Coronavirus Response Act: Questions and Answers
- Treasury, IRS and Labor Announce Plan to Implement Coronavirus-related Paid Leave for Workers and Tax Credits
- U.S. Chamber of Commerce COVID-19 Emergency Loans: Small Business Guide and Checklist
- U.S. Chamber of Commerce National Small Business Town Hall
- National Governors Association
- National Conference of State Legislators: State Fiscal Responses to Coronavirus (COVID-19)
- American Bankers Association List of Induvial Bank Responses to COVID-19