Home Health & Hospice Week

Beware the CARES Act conditions.

With new COVID-19 funding available via the replenished Paycheck Protection Program, providers may want to carefully weigh their options for COVID-19 assistance.

Remember, you won’t have to pay back money from the Small Business Administration’s PPP program or the Provider Relief Fund, as long as you meet certain terms and conditions. In contrast, you’ll need to repay accelerated payments within 210 days, with recoupments starting after day 120 (see related story on accelerated pay, p. 127).

Another difference: Even within the two programs where the payments can be forgiven, important differences exist, points out Dave Macke with VonLehman & Co. in Fort Wright, Kentucky. For example, with PPP loans, companies have to spend the amount within eight weeks, and can spend it only on payroll, rent, utilities, and/or mortgage interest.In contrast, there’s no deadline for CARES Act Provider Relief Fund spending, and it can go for any COVID-19-related expenses or losses, he says.

While the Relief Fund is a bit less structured, it comes with a bevy of documentation requirements, including these two that are worrying providers:

• 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.
• 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.

And the requirements aren’t casual.“All recipients will be required to submit documents sufficient to ensure that these funds were used for healthcare-related expenses or lost revenue attrib­utable to coronavirus,” the Department of Health & Human Services stresses on its Provider Relief Fund webpage. There will be significant anti-fraud and auditing work done by HHS, including the work of the Office of the Inspector General, says the webpage.

Good news: Proving your services were coronavirus-related shouldn’t be too tough.“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.

But proving that you have not used “the Payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse” may require more work, experts fear.“Expenses and losses cannot be charged twice,” points out consulting firm The Health Group in Morgantown, West Virginia.

To do: Depositing any Provider Relief Fund payments into a separate bank account will help you keep track of the funds, The Health Group advises.“When received, the healthcare provider should establish a liability account entitled ‘Unearned Provider Relief Funds,’” the firm recommends.“This liability account will be relieved as COVID-19 related expenses are incurred or as COVID-19 related lost revenues are computed and reported. Likewise, revenue will be recognized as qualifying expenses and lost revenues are recognized.”

Don’t forget: Even though HHS is emphasizing that providers don’t have to repay Provider Relief Funds, “such funds can only be used for COVID-19 related expenses or COVID-19 related lost revenues,” The Health Group stresses in its electronic newsletter.

And to keep their funds, providers must sign their attestations within 30 days and submit paperwork via the CARES Act Provider Relief Fund General Distribution Portal at https://covid19.linkhealth.com.