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 Health Agency Updates COVID-19 Provider Relief Fund FAQs

The Department of Health and Human Services (HHS) on June 22 made updates to the COVID-19 Provider Relief Fund FAQs, which come ahead of two HHS webinars on the Medicaid Allocation application process, according to the American Health Care Association/National Center for Assisted Living (AHCA/NCAL).

To register for the HHS webinars, click here.

AHCA/NCAL also provided a summary of the changes HHS made to the FAQs specific to long term care providers. 
 
First, HHS added detail on calculating revenue and lost revenue (page 7): 

“You may use any reasonable method of estimating the revenue during March and April 2020 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 be the difference between your budgeted revenue and actual revenue. It would also be reasonable to compare the revenue to the same period last year.”  

On page 38, HHS also said patient out-of-pocket costs should be counted as revenue. And, on page 39, HHS indicates that revenue lost under Medicaid value-based purchasing programs may be counted as lost revenue, AHCA/NCAL said.  

Second, HHS changed the Duration of Terms and Conditions (page 9): 

“Some Terms and Conditions relate to the provider’s use of the funds, and thus they apply until the provider has exhausted these funds. Other Terms and Conditions apply to a longer time period, for example, regarding maintaining all records pertaining to expenditures under the Provider Relief Fund payment for three years from the date of the final expenditure.”

Third, HHS altered wording on Change in Ownership Additional Detail (page 9):

HHS elaborates upon scenarios in which sellers may not transfer funds, AHCA/NCAL said.  

Fourth, the association noted that HHS changed parts of the FAQs detailing Medicaid Allocations (page 38):

HHS notes that even a small General Distribution payment makes a provider ineligible for the Medicaid Allocation. “The department also added detail on who may apply noting that if a provider did not bill Medicaid/CHIP during the eligibility window, providers may apply for Medicaid allocation funding as long as they provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 after Jan. 31, 2020, and can produce evidence of such care,” AHCA/NCAL said.  

Additionally, the association said HHS limits on page 39 which providers who enrolled as Medicaid/CHIP providers in 2020 may apply. Also, on page 39, HHS notes that providers who bill under Medicaid Managed Care may apply.  

Fifth, AHCA/NCAL said Tax Information changes on pages 38 and 41 clarify needed tax documentation information.

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