What’s new in the CARES Act Provider Relief Fund FAQs as of Aug. 17

• The U.S. Department of Health and Human Services (HHS) balked Aug. 17 when it failed to release guidance to providers related to how they will be required to file reports to support the amounts they received for lost revenue and the increased expenses incurred as a result of COVID-19.
• HFMA will continue to monitor the HHS Provider Relief Funds website and update members when guidance is available.
• HHS did provide additional clarity around applying for phase two of the general distribution, which is detailed below.

The U.S. Department of Health and Human Services (HHS) balked  when it missed its self-imposed deadline of Aug. 17 to release guidance to providers related to how they will be required to file reports to support the amounts they received for lost revenue and the increased expenses incurred as a result of COVID-19. HFMA will continue to monitor the HHS Provider Relief Funds  website and provide an update for members when guidance is available.

In terms of updates to the FAQs, HHS provided details (eligibility requirements, payment calculation formula) on Aug. 14 related to an additional allocation for select children’s hospitals. HHS also provided additional clarity around applying for phase two of the general distribution, specifically related to the following:

• Providers without Tax Filings or Audited Financial Statements (added Aug. 18): If an organization does not have tax filings, nor audited financial statements, it may submit internally-generated financial statements or, in the case of federal grantees, the most recent four quarters of SF-425 forms.
• Part A Providers that Experienced a Change of Ownership (added Aug. 18): Medicare Part A providers that experienced a change in ownership and meet the other eligibility criteria for phase 2 of the general distribution may receive additional funds if the revenue from the included subsidiaries that were acquired is greater than 20% of the revenue figure on the most recent tax filings or audited financial statements.
• Revenue Reporting for 2019 or 2020 Organizations that Experienced a Change of Ownership (modified on 8/17) if approved by CMS by 8/10/20: In addition to completing the Revenue Worksheet for any adjustments to revenue, providers should include supporting documentation for any adjustments reflected on the worksheet. Examples of supporting documents could include internally generated financial statements, valuation reports that would reflect revenue  or budget-to-actual revenue comparisons.