HHS provides additional updates on CARES Act Provider Relief Fund FAQs

• The week of June 22,  the U.S. Department of Health & Human Services (HHS) added a bit more clarity on what to include in the lost revenue calculation and the attributable time frame for allowable expenses or lost revenue.
• HFMA’s Chad Mulvany says HHS needs to provide guidance on how to calculate shared savings payments or NPRA sharing, given it’s not as simple as tacking a percentage onto the fee-for-service payment.
• Although it’s understood that if providers have leftover Provider Relief Fund money that they cannot expend on permissible expenses or losses at the conclusion of the pandemic, they will return this money to HHS. What’s not clear is what HHS considers the end of the pandemic.

Via these blog posts, I will likely provide regular updates to CARES Act Provider Relief Fund FAQs for the foreseeable future. The week of June 22, the U.S. Department of Health & Human Services (HHS) added a bit more clarity around what to include in the lost revenue calculation and the attributable time frame for allowable expenses or lost revenue. Here are two items of note:

1. Value Based Payments Included in Lost Revenue Calculation (page 39 as of June 26): According to the FAQs, “Lost revenue estimates should be based on budget-to-actual or year-over-year, and should include revenue from all sources that can be attributed to COVID-19. This may include value-based payments, such as quality measure achievement payments.”

Takeaway

The payments on volume-based Pay for Performance (P4P) models will be relatively easy to calculate. It seems to me that HHS needs to provide guidance on how to calculate shared savings payments or NPRA sharing, given it’s not as simple as tacking a percentage onto the fee-for-service payment (e.g. Advanced APM bonus payment, hospital value based purchasing program).

2. Timeframe for providers to use PRF funds to cover COVID-19 expenses or revenue loss (page 39 as of June 26): According to the FAQs, “HHS expects that providers will only use Provider Relief Fund payments for as long as they have eligible expenses or lost revenue. If, at the conclusion of the pandemic, providers have leftover Provider Relief Fund money that they cannot expend on permissible expenses or losses, then they will return this money to HHS. HHS will provide directions in the future about how to return unused funds.”

Takeaway

It is still unclear what defines the “conclusion of the pandemic,” and I and others are still trying to get an answer to this from HHS.