Home Health & Hospice Week

Take spending documentation duties seriously.

Providers should soon receive official word that their CARES Act Provider Relief Fund payments are theirs to keep, according to industry reps.

Health and Human Services Deputy Secretary Eric Hargan and his team have “confirmed that HHS does not intend to take back any of the funds from the first distribution based on the calculation determined under the second formula,” National Association for Home Care & Hospice President William Dombi says. Home health and hospice agencies were concerned about takebacks of Provider Relief Fund payments when the amount distributed in the first round was greater than the calculated amount set out in the second distribution (see Eli’s HCW, Vol. XXIX, No. 16).

This was a serious concern, because most HHAs and the vast majority of hospices were in the situation of receiving more in their first distribution than they were supposed to receive overall.“Our cost report data shows about 85 percent of HHAs were given more under the round 1 formula than would be calculated under the round 2 formula,” Dombi tells Eli.“For hospices, that number is closer to 97 percent.”

But now agencies can breathe a sigh of relief.“HHS will be issuing an FAQ to clarify the standard applied to the first and second distributions very soon,” Dombi reports.“If they are unable to finalize the FAQ in time to have providers submit an attestation by the 30-day deadline, HHS will extend the deadline.”

Audits Are Coming

Providers aren’t quite out of the woods yet, though. In accepting the Provider Relief Fund money, providers must agree to terms and conditions, including that the funds “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,” HHS specifies.

Providers must submit reports to show they comply with this requirement, and HHS will check to make sure the funds were fully spent on COVID-19-related expenses and losses, Hargan reportedly told NAHC.

Heads up: The terms and conditions have grown more complex as well.“HHS has added another page of requirements to its 10-page terms and conditions,” reports the Health Care Financial Management Association.

The additions require providers to submit general revenue data for calendar year 2018; give HHS consent to publicly disclose payments providers may receive; and acknowledge that payment dis-closures may allow others to estimate providers’ “gross receipts or sales, program service revenue or other equivalent information.” Providers also must agree not to charge patients out-of-network costs.

Plus: “None of the funds … shall be used to pay the salary of an individual … at a rate in excess of Executive Level II,” the conditions specify. That is currently $197,300, points out consulting firm The Health Group in Morgantown, West Virginia.

At least HHS has alleviated fears about what’s coronavirus-related.“HHS broadly views every patient as a possible case of COVID-19,” it says on its Relief Fund page under the “Who is eligible for initial $30 billion” section.v

Note: The newly lengthened terms and conditions are at www.hhs.gov/sites/default/files/terms-and-conditions-provider-relief-20-b.pdf.