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IMPORTANT COVID-19 HOSPITAL FUNDING UPDATE

 

 

 

 

 

1. Important Deadline:

June 15 is the deadline to submit January 1 through June 10 COVID-19 inpatient admissions for the next round of High Impact Funding.

2.  HHS released updated FAQs including:

  • Reporting COVID-19 admissions.
  • Reporting expenses and lost revenues.
  • Clarifications for parent organizations with subsidiaries.

3. HHS allocated $25 billion toward:

  • $15 billion for Medicaid & CHIP providers.
  • $10 billion for Safety Net Hospital Funding.

 

Toyon is pleased to provide this update on the CARES Act Public Health and Social Services Emergency Fund (PHSSEF).   For more information, or to contact any of our team members, please feel free to visit Toyon’s website.

1. Important Deadline: Monday June 15
HHS contacted all hospitals requesting COVID-19 positive-inpatient admissions for January 1 through the end of the day June 10.  These cases will be used for the second round COVID-19 High Impact funding.  Funding from the first round of High Impact Payments will be taken into account in the second round.  Hospitals have until June 15 (9 PM EDT) to submit admission detail.  Toyon recommends hospitals evaluate HHS’s FAQs and contact TeleTracking for assistance 
(877-570-6903).
 
2. Observations from Updated FAQs
The CARES Act Provider Relief Fund FAQs were last updated Tuesday June 9.   Listed below are notable updates by category:
 
 
Reporting COVID-19 Admissions:
  • Patients with a pending positive test that came back positive after June 10 are not allowed in COVID-19 admissions data due June 15.
  • Do not include emergency department patients in COVID-19 admissions data.
  • Admissions occurring at multiple campuses, under the same TIN, should be reported separately and not rolled up into one count.
  • If the prior submission of COVID-19 positive admissions was submitted in error (i.e., all COVID-19 positive admissions submitted by system instead of by facility), HHS requests providers to use TeleTracking to correct and update the data to reflect all COVID-19 positive inpatient admissions from January 1 through June 10.
CARES Provider Relief Funding
  • HHS expects providers will only use Provider Relief Fund payments for permissible purposes. If, at the conclusion of the pandemic, providers have leftover Provider Relief Fund money that cannot be expended on permissible expenses or losses, then providers will return this money to HHS. 
COVID-19 Expenses and Lost Revenues
  • HHS will be providing further guidance about the type of documentation to provide per the terms and conditions (e.g., documentation due with quarterly reports July 10).  
  • HHS clarifies the term “healthcare related expenses attributable to coronavirus” is a broad term for determining eligibility of expenses and lost revenues eligible for reimbursement 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.
  • Providers may have incurred eligible health care related expenses attributable to coronavirus prior to the date on which they received their payment.  HHS expects that it would be highly unusual for providers to have incurred eligible expenses prior to January 1.
  • The term “lost revenues that are attributable to coronavirus” means any revenue lost to providers due to the coronavirus. 
  • HHS encourages the use of funds to cover lost revenue so providers can respond to the coronavirus public health emergency to cover employee or contractor payroll, employee health insurance, rent or mortgage payments, equipment lease payments and electronic health record licensing fees.
Parent Organizations and Subsidiaries
  • Parent organizations with multiple billing TINs that each received payments, may attest and keep the payments as long as providers associated with the parent organization were providing diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 on or after January 31 and can otherwise attest to the Terms and Conditions.  The parent organization can allocate funds at its discretion to its subsidiaries. If the parent organization would like to control and allocate Provider Relief Fund payments to its subsidiaries, the parent organization must attest to accepting its subsidiaries’ payments and agreeing to the Terms and Conditions.
  • Providers with TINs covering all business lines can report lost revenues under the same TIN that are actively caring for patients with COVID-19 or actively working to prevent the spread of COVID-19.
  • Parent entities, submitting revenue information on behalf their subsidiaries may encounter an issue if they have multiple Medicare/Medicaid provider numbers (there is only one space in the HHS Portals to populate these numbers). HHS states these providers should submit a statement on the first page of the uploaded tax return file stating (i) the parent entity’s Filing TIN and that it does not bill Medicare and (ii) a schedule of the billing subsidiaries, their Billing TINs, their Medicare/Medicaid ID numbers, and gross sales or receipts.
On Tuesday, June 9, HHS announced the following funding allocations:
  • $15 billion Medicaid and CHIP funding to eligible providers that participate in state programs and have not received a payment from the Provider Relief Fund General Distribution. Approximately one million health care providers may be eligible for this funding.
  • $10 billion safety net funding to approximately 760 hospitals. HHS states the safety net distribution will occur this week. Recipients will receive a minimum payment of $5 million and a maximum payment of $50 million. In order to qualify for this funding, hospitals must have:
    • A Medicare Disproportionate Payment Percentage (DPP) of 20.2 percent or greater,
    • average Uncompensated Care per bed of $25,000 or more, and
    • profitability of 3 percent or less, as reported to CMS in its most recently filed Cost Report.

Toyon has updated our Provider Relief Fund estimates to include hospitals eligible for safety net funding. This information will soon be available on our website. In the meantime if you have any questions on these estimates, please contact Fred Fisher at 888.514.9312, fred.fisher@toyonassociates.com.  
 
Toyon is committed to apprising providers with important reimbursement updates and will keep you updated with the latest on UC DSH and COVID-19 funding and documentation. Please feel free to visit Toyon’s COVID-19 Resources for updates on hospital funding estimates, and recommendations on documenting cost and revenue losses associated with this public health emergency. Toyon’s website provides information on how to contact Toyon’s team members.  
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IMPORTANT COVID-19 FUNDING UPDATE | MAY 22, 2020

 

 
  • This Sunday, May 24, is the deadline for attesting to CARES provider relief payments received on April 10.
 

Toyon’s COVID-19 Funding Resources (updated for interactive national modeling of funding)
Toyon University’s COVID-19 Funding and Documentation Presentation

 
  • Wednesday, June 3, is the deadline to submit COVID-19 expenses for
    additional provider relief funding. Providers may be eligible for payments
    from the remaining
    funds through targeted distributions.
     
  • Toyon estimates $27.6
    billion in unallocated
    funding.
 

Toyon is pleased to provide this update on developing details from the CARES Act Public Health and Social Services Emergency Fund (PHSSEF). For more information, or to contact any of our team members, please feel free to check Toyon’s website.

Important Deadlines: May 24 and June 3
This Sunday, May 24 is the deadline for providers receiving CARES PHSSEF payments on April 10 to attest the terms and conditions (T&C)

Providers that do not attest to the T&C and retain the funds past 45 days will retain payments and be included in HHS’s public release of providers and payments. In HHS’s updated FAQs, the agency states:

“Generally, HHS does not intend to recoup funds as long as a provider’s lost revenue and increased expenses exceed the amount of Provider Relief funding a provider has received.”

Providers must also submit revenue detail by June 3 to receive additional funding from the PHSSEF Distribution.
Please visit Toyon University’s COVID-19 Funding and Documentation Presentation for a discussion on submitting expenses and revenue loss. In HHS’s updated FAQs, HHS indicates this information may be used for other funds, such as the High Impact Fund. HHS states:

“Providers should update their capacity and COVID-19 census data to ensure that HHS can make timely payments in the event that the provider becomes a high-impact provider. Providers can continue to update their information through the same method they used previously.”

Also, providers are required to accept HHS’s T&C and submit revenue information to be considered for additional relief payments.

Toyon’s estimation of unallocated funds (to eligible hospitals) from the CARES Act PHSSEF is below. It is noted some of this funding will be used as part of provider relief funding for skilled nursing facilities (SNF) and HRSA’s Uninsured Program.

$50,000 Payments to RHCs for COVID-19 testing | expenses
Also included in HHS’s provider relief funding update is a distribution of $225 million to RHCs for COVID-19 testing. Payments are based on the number of certified clinic sites. HHS also released RHC T&Cs here. 

Provider relief for Skilled Nursing Facilities
As part of the CARES provider relief funding, HHS is distributing $50,000 to each SNF plus a variable distribution between $2000 per bed for smaller SNFs (5 and 25
beds) and $1,8000 per bed for larger SNFs (more than 200 beds). HHS also released SNF T&Cs here.


Thank you

Toyon is committed to apprising providers with important reimbursement updates and will keep you updated with the latest on UC DSH and COVID-19 funding and documentation.  Please feel free to visit Toyon’s COVID-19 Resources for updates on hospital funding estimates, recommendations on documenting cost and revenue losses associated with this public health emergency. Toyon’s website provides information on how to contact Toyon’s team members.   

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COVID-19 FUNDING UPDATE

Toyon’s COVID-19 Resources

Visit Toyon’s COVID-19 Resources for updates on hospital funding estimates, recommendations on documenting cost and revenue losses associated with this public health emergency. Toyon recently updated an interactive model estimating hospital payments from the $50 billion General Fund here.

CMS RELEASED

WIDESPREAD WAIVERS

AND FLEXIBILITIES

FOR COVID-19 RELIEF

 

CMS New Waivers and Flexibilities

On April 30, CMS released extensive regulatory waivers and flexibilities. CMS also published detailed regulatory insight on these waivers and flexibilities by provider type (including acute care hospitals and teaching hospitals) here. CMS also posted an interim final rule related to COVID-19 revised policies here.

HHS has released updated guidance related to HHS General Fund FAQs as well as Terms and Conditions for CARES Funding. Listed below under “Initial Key Language from COVID-19 Regulatory Updates” is Toyon’s composition of initial key language from these important updates for hospitals. Toyon will continue to provide updates and insight on these changes in the coming weeks.

$50 Billion General Fund Allocations

  • The Provider Relief Fund Application Portal has been deployed in order to collect information from providers in receipt of General Distribution payments prior to April 24, 2020 at 5 p.m. EST.
  • HHS will be processing applications in batches every Wednesday at 12:00 noon EST. For providers submitting tax and financial loss information, HHS intends to distribute additional funds within 10 business days of the submission.
  • HHS would like the General Distribution to “replace a percentage of a provider’s annual gross receipts, sales, or program service revenue.
  • The initial $30 billion tranche was expedited to providers by April 17. Medicare revenue from federal fiscal year 2019 was used as the basis for these initial payments.
  • The second $20 billion tranche is being provided to providers as of April 24. This allocation uses net patient revenue from 2018 so the “whole $50 billion general distribution is allocated proportional to providers’ share of net patient revenue.

COVID-19 Uninsured Program Portal

The COVID-19 Uninsured Program Portal, which allows for reimbursement for uninsured patients receiving COVID-19 is open. FAQs related to this Program are available here.

Please contact Robert Howey at robert.howey@toyonassociates.com or 888.514.9312 with any questions.

Respectfully,

Toyon Associates, Inc.

www.toyonassociates.com 


Initial Key Language from COVID-19 Regulatory Updates for Providers

Listed below is Toyon’s composition of initial key language from these important updates for hospitals. Toyon will continue to provide updates and insight on these changes in the coming weeks.

I.  CMS New Waivers and Flexibilities

Teaching Hospitals

  • CMS will not reduce Medicare payments for teaching hospitals that shift their residents to other hospitals to meet COVID-related needs, or penalize hospitals without teaching programs that accept these residents
  • Teaching hospitals can increase the number of temporary beds without facing reduced payments for indirect medical education
  • To help teaching hospitals quickly expand their workforce, medical residents will have more flexibility to provide services under the direction of the teaching physician. In addition to being able to directly supervise a resident with their physical presence during key portions of a procedure, teaching physicians can now also provide supervision virtually using audio/video communication technology.

Expansion Sites, Home Health and Telehealth

  • Hospitals may bill for services furnished remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is at home when the home is serving as a temporary provider-based department of the hospital.
  • CMS is allowing payment for certain partial hospitalization services – that is, individual psychotherapy, patient education, and group psychotherapy – that are delivered in temporary expansion locations, including patients’ homes.
  • CMS is allowing healthcare systems and hospitals to provide services in locations beyond their existing walls to help address the urgent need to expand care capacity and to develop sites dedicated to COVID-19 treatment.  For example, a healthcare system can use a hotel to take care of patients needing less intensive care while using its inpatient beds for COVID-19 patients. 
  • As mandated by the CARES Act, CMS is paying for Medicare telehealth services provided by rural health clinics and federally qualified health clinics.
  • CMS is also increasing payments for these telephone visits to match payments for similar office and outpatient visits. This would increase payments for these services from a range of about $14-$41 to about $46-$110. The payments are retroactive to March 1, 2020.
  • Hospitals may bill as the originating site for telehealth services furnished by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is located at home. 
  • CMS will now pay for more than 80 additional services when furnished via telehealth. These include emergency department visits, initial nursing facility and discharge visits, and home visits, which must be provided by a clinician that is allowed to provide telehealth.

Other Notable Waivers and Flexibilities

  • Hospital Outpatient Departments: CMS will allow certain provider-based hospital outpatient departments that relocate off-campus to obtain a temporary exception and continue to be paid under the OPPS.  Importantly, hospitals may also relocate outpatient departments to more than one off-campus location, or partially relocate off-campus while still furnishing care at the original site.  These flexibilities allow payment for outpatient hospital services — such as wound care, drug administration, and behavioral health services — that are delivered in temporary expansion locations, including parking lot tents, converted hotels, or patients’ homes (when they’re temporarily designated as part of a hospital).
  • CMS Audits: The agency will continue to engage in oversight activities but will suspend requesting additional information from providers, healthcare facilities, Medicare Advantage and Part D prescription drug plans, and States.
  • Accountable Care Organizations (ACO): CMS is also forgoing the annual application cycle for 2021 and giving ACOs whose participation is set to end this year the option to extend for another year. ACOs that are required to increase their financial risk over the course of their current agreement period in the program will have the option to maintain their current risk level for next year, instead of being advanced automatically to the next risk level.
  • Ambulatory Surgery Centers (ASCs): ASCs can contract with local healthcare systems to provide hospital services, or they can enroll and bill as hospitals during the emergency declaration as long as they are not inconsistent with their State’s Emergency Preparedness or Pandemic Plan.
  • Hospital Benefits: CMS is issuing a blanket waiver to allow hospitals to provide benefits and support to their medical staffs, such as multiple daily meals, laundry service for personal clothing, or child-care services while the physicians and other staff are at the hospital providing patient care.
  • Rehab Hospitals: CMS is excepting certain requirements to enable freestanding inpatient rehabilitation facilities to accept patients from acute-care hospitals experiencing a surge, even if the patients do not require rehabilitation care.
  • Respiratory Care: Medicare will now cover respiratory-related devices and equipment for any medical reason determined by clinicians so that patients can get the care they need; previously, Medicare covered them under certain circumstances.

II. HHS General Fund FAQs

Revenue Loss

  • Before you initiate your application via the Provider Relief Fund Application Portal, please collect the following data…3. An estimate the organization’s lost revenue for March 2020 and April 2020. 
    • Lost revenue can be estimated by comparing year-over-year revenue, or by comparing budgeted revenue to actual revenue. 
    • For April 2020, an estimate of the total monthly loss based on data from the first few weeks in April or by extrapolation from March data is acceptable
  • How to Estimate – You may use a reasonable method of estimating the revenue during March and April compared to the same period had COVID-19 not appeared. For example, if you have a budget prepared without taking into account the impact of COVID-19, the estimated lost revenue could be the difference between your budgeted revenue and actual revenue. It would also be reasonable to compare the revenues to the same period last year.
  • We realize that a final revenue number may not be available until a certain time after the end of April. As the program seeks to provide liquidity support to the healthcare system in a timely manner we are using estimated revenues.
  • We are collecting the “gross receipt or sales” or “program service revenue” data to have an understanding of a provider’s usual operations. We are collecting the revenue loss information to have an understanding of COVID impact. We are collecting tax forms in order to verify the self-reported information. And we are collecting information about organizational structure and subsidiary TINs so that we do not overpay or underpay providers who file tax returns covering multiple legal entities (e.g. consolidated tax returns)…This information may also be used in allocating other Provider Relief Fund distributions.

Cash Flow/Payment Confirmation

  • We will be processing applications in batches every Wednesday at 12:00 noon EST. Funds will NOT be disbursed on a first-come-first-served basis, which is to say, an applicant will be given equal consideration regardless of when they apply.
  • For providers submitting tax and financial loss information, HHS intends to distribute additional funds within 10 business days of the submission.
  • If a provider meets certain terms and conditions, the payments received do not need to be repaid at a later date.
  • Retention and use of funds are subject to certain terms and conditions. If these terms and conditions are met, payments do not need to be repaid at a later date.
  • You will receive an email when your application is completed.
  • You will receive no notification from HHS as to the status of your application once submitted.
  • We do not anticipate that you will receive any inquiries from HHS. If additional information is requested, HHS will use the email used to access the Provider Portal.
  • There is no appeals or dispute process.

III.   Terms and Conditions

  • The Recipient certifies that the Payment will only be used to prevent, prepare for, and respond to coronavirus, and that the Payment shall reimburse the Recipient only for health care related expenses or lost revenues that are attributable to coronavirus.
    • FFCRA T&C language…if the Recipient subsequently receives reimbursement for any items or services for which the Recipient requested Payment from the FFCRA Relief Fund, the Recipient will return to HHS that portion of the Payment which duplicates payment or reimbursement from another source. The Recipient will not include costs for which Payment was received in cost reports or otherwise seek uncompensated care reimbursement through federal or state programs for items or services for which Payment was received.
  • 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.
  • Not later than 10 days after the end of each calendar quarter, any Recipient that is anentity receiving more than $150,000 total in funds…shall submit…a report. This report shall contain: the total amount of funds received from HHS under the foregoing enumerated Acts; the amount of funds received that were expended or obligated for each project or activity; a detailed list of all projects or activities for which the funds were expended or obligated, including: the name and description of the project or activity, and the estimated number of jobs created or retained by the project or activity, where applicable; and detailed information on any level of subcontracts or subgrants awarded by the Recipient or its subcontractors or subgrantees.
  • The Recipient shall maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR § 75.302 – Financial management and 45 CFR § 75.361 through 75.365 – Record Retention and Access, and other information required by future program instructions to substantiate the reimbursement of costs under this award. The Recipient shall promptly submit copies of such records and cost documentation upon the request of the Secretary, and Recipient agrees to fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with these Terms and Conditions.
  • The Secretary has concluded that the COVID-19 public health emergency has caused many healthcare providers to have capacity constraints. As a result, patients that would ordinarily be able to choose to receive all care from in-network healthcare providers may no longer be able to receive such care in-network. Accordingly, for all care for a presumptive or actual case of COVID-19, Recipient certifies that it will not seek to collect from the patient out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network Recipient.
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