logo
logo
logo
MENU
Categories
Hospitals and Health Systems - Audits and ReimbursementHospitals and Health Systems - Consent and TreatmentHospitals and Health Systems - Corporate and GovernanceHospitals and Health Systems - Corporate ComplianceHospitals and Health Systems - Fraud and AbuseHospitals and Health Systems - Government InvestigationsHospitals and Health Systems - Health RecordsHospitals and Health Systems - HIPAA and HITECHHospitals and Health Systems - Managed CareHospitals and Health Systems - Medical Staff IssuesHospitals and Health Systems - Medical Training ProgramsHospitals and Health Systems - MedicareHospitals and Health Systems - Mergers, Affiliations and Joint VenturesHospitals and Health Systems - Peer ReviewHospitals and Health Systems - Professional Services AgreementsMedical SocietiesPharmaceutical Industry - Agreements with PhysiciansPharmaceutical Industry - Clinical ResearchPharmaceutical Industry - Regulatory CompliancePhysicians and Providers - Audits and ReimbursementPhysicians and Providers - CertificationsPhysicians and Providers - CredentialingPhysicians and Providers - Disciplinary ActionsPhysicians and Providers - Employment AgreementsPhysicians and Providers - Fraud and AbusePhysicians and Providers - Government InvestigationsPhysicians and Providers - HIPAA and PrivacyPhysicians and Providers - ImpairmentPhysicians and Providers - LicensingPhysicians and Providers - LitigationPhysicians and Providers - MedicarePhysicians and Providers - Peer ReviewPhysicians and Providers - Practice AcquisitionsPhysicians and Providers - Practice IssuesPhysicians and Providers - Regulatory CompliancePhysicians and Providers - SupervisionPhysicians and Providers - TrainingUncategorized

$30 Billion Is Being Infused Into the Health Care System: Who Is Receiving Money and What You Should Know If You Keep It

Beginning April 10, the U.S. Department of Health and Human Services (“HHS”), assisted by UnitedHealth Group, began distributing the $30 billion to health care providers and health care systems. These payments are not loans and will not need to be repaid. This differs from the CMS Accelerated and Advance Payment Program, where the payments are loans to providers and must be repaid.

We previously wrote about the $100 billion in relief funds to hospitals and health care providers included in the CARES Act passed on March 27. (See “Senate Approves $100 Billion to Hospitals in COVID-19 Relief Package” and “CARES Act Provides Financial Relief for Health Care Providers.”) On April 10, the HHS released guidance pertaining to an immediate infusion of $30 billion into the health care system. The intent of these quick disbursements is to provide relief both to providers in areas heavily impacted by the COVID-19 pandemic and to providers who are struggling to keep their doors open because healthy patients are delaying care and canceling elective services.

Who is eligible for this initial rapid distribution?

  • All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019.

How are the payments being distributed?

  • All relief payments are made to the billing organization according to its Taxpayer Identification Number (TIN). Thus, employed physicians and physicians who are part of a group will not receive the payment directly; the payment will be received like a routine payment for medical services.
  • Payments to practices that are part of larger medical groups will be sent to the group’s central billing office.
  • The direct deposit will come via Optum Bank with “HHSPAYMENT” as the payment description.
  • Providers that normally receive a paper check for reimbursement from CMS will receive a paper check in the mail.

How much can you expect to receive?

  • Health care providers can anticipate receiving an amount that is proportional to their billing of the total FFS payments in 2019, which was approximately $484 billion.
  • HHS provides the following formula: A provider can estimate their payment by dividing the 2019 Medicare FFS payments they received (not including Medicare Advantage) by $484,000,000,000, and multiply that ratio by $30,000,000,000. Providers can obtain their 2019 Medicare FFS billings from their organization’s revenue management system.

What’s the catch?

  • Not returning the money within 30 days will be considered an acceptance of the Terms and Conditions, even if an attestation was not provided.

What do you need to do?

  • The Terms and Conditions impose very strict recordkeeping requirements and depending on the amount received, there might be an affirmative duty to submit reports quarterly.
  • Additionally, the money cannot be used to cover expenses that have already been reimbursed through other sources or that other sources are obligated to reimburse.

If you need help navigating the steps in this process, or get stuck along the way, we are here to assist you. If you have any questions concerning this post, please contact Sandra Jarva Weiss, Chair of our Health Care & Life Sciences Practice Group, at sjarvaweiss@norris-law.com.

The information contained in this post may not reflect the most current developments, as the subject matter is extremely fluid and constantly changing. Please continue to monitor this site for ongoing developments. Readers are also cautioned against taking any action based on information contained herein without first seeking advice from professional legal counsel.

Share
Related Posts
OSHA Issues COVID-19 Safety Rule: Emergency Temporary Standard (ETS)
Impact of the COVID Pandemic on Physician Employment Agreements
Telemedicine and the COVID-19 Vaccination – What’s on the Horizon for 2021?
Related Posts
OSHA Issues COVID-19 Safety Rule: Emergency Temporary Standard (ETS)
Impact of the COVID Pandemic on Physician Employment Agreements
Telemedicine and the COVID-19 Vaccination – What’s on the Horizon for 2021?
Share
Join our growing team
We are looking for quality attorneys to help us do more for our clients. At Norris McLaughlin, each attorney has the same opportunity to succeed whether you’re at the beginning of a career or pinnacle of the profession.
Subscribe to our content
Receive timely legal information
delivered to your inbox
Subscribe to our content
Receive timely legal information
delivered to your inbox
© 2021, Norris McLaughlin, P.A., All Rights Reserved. Attorney Advertising.
Meritas

We use cookies to ensure that we give you the best experience on our website. If you continue to use this site we will assume you consent to our cookie policy. Learn more