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 HHS Clarifies Providers Do Not Need to Provide Revenue Information by June 3

In a late-breaking piece of information, the Department of Health and Human Services (HHS) has clarified that the June 3 deadline for long term care providers to submit revenue data to get COVID-19 financial relief is only for providers that received a Tranche 1 allocation and would like to submit financial information to receive additional Tranche 1 funding. 
In interpreting the announcement, the American Health Care Association/National Center for Assisted Living (AHCA/NCAL) said providers would still be required to ensure that their General Distribution payment is the lesser of 2 percent of their provider net revenue or the sum of incurred losses for March and April.
Below is the relevant HHS webpage text:   
ALERT: Providers need to take action by [TOMORROW,] June 3, 2020

Providers must submit revenue information to the 
General Distribution Portal by June 3, 2020, to be considered for an additional payment from the Provider Relief Fund $20 billion General Distribution.
Once providers submit their revenue information by June 3, 2020, if deemed qualified for additional payment, providers will then have 90 days from receipt of payment of the additional General Distribution funds to agree to the program Terms and Conditions.
AHCA/NCAL said it recognizes how challenging the lack of guidance is for providers and is working with HHS to secure additional information.

All other questions about the fund should be directed to the HHS Hotline at (866) 569-3522. HHS reported on May 22 that the call center now has access to additional data and new HHS guidance to better answer questions.
Tranche by Tranche Questions
Tranche 1: HHS has provided the formula and allocation process in its FAQs. The data source for the award amounts was 2019 Medicare Part A Fee-For-Service (FFS) net revenue.

Tranche 2: As above, HHS has provided the formula for Tranche 2 in its 
FAQs. Of note, HHS explains why a provider that received a Tranche 1 award may not have received a Tranche 2 award. The data source for Tranche 2 was the 2018 Medicare Cost Report.

Tranche 3: All skilled nursing facilities (SNFs) with Medicare-certified beds should have received an allocation on May 22. If the SNF did not receive an allocation this could be because:
--It is a Medicaid-only or private pay only facility; or
--Errors in the HHS data source (April 2020 CASPER Report).
If the SNF believes it should have received a Tranche 3 award or received the incorrect amount, they should contact the Hotline (above) and have the following information ready:
--Tax Identification Number(s) (TIN);
--CMS Certification Number(s) (CCN); and
--Dollar amount in question by building.
Also, for Tranche 3, the SNF Allocation, have the number of SNF-certified beds (Medicare, Medicaid, or both), the amount they received, and the amount they believe they should have received, AHCA/NCAL said.

“At this point, the above information is all HHS has shared. AHCA/NCAL continues to request clarification on Change in Ownership, TINs, and reporting window information,” the association said.
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