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HHS continues to shed light on how providers can know if they're receiving money as it eases concerns about who qualifies.

The $30 billion in COVID-19 funds being sent directly to health care providers has sparked questions among providers about whether they qualify for the funds, how they'll receive them, and what kinds of restrictions might apply.

Fortunately, there are answers out there. In addition to its initial story on release of the funds, PT in Motion News published a subsequent piece on how to find out if you're receiving any of the money. Here's more of what we know about the program.

You don't have to be "currently taking patients" as long as you were still seeing patients after January 31 — and HHS is taking a broad view of patients with "possible" COVID-19.
The basic requirement for the funds, according to HHS, is that you billed Medicare in 2019 and provided "diagnoses, testing, or care for individuals with possible or actual cases of COVID-19." As far as HHS is concerned, that includes everyone you treated: "HHS broadly views every patient as a possible case of COVID-19," HHS states.

You can still qualify for the money if you stopped operations due to the pandemic.
Again, from HHS: "If you ceased operation as a result of the COVID-19 pandemic, you are still eligible to receive funds so long as you provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19."

Payment is tied to your Taxpayer Identification Number.
Whether you're looking for funds for a large health system or as a solo practitioner, the relief payments are made to the billing organization according to its Taxpayer Identification Number, either via direct deposit or paper check. Here's how HHS breaks it down on its provider relief fund webpage:

  • Large Organizations and Health Systems. Large organizations will receive relief payments for each of their billing TINs that bill Medicare. Each organization should look to the part of their organization that bills Medicare to identify details on Medicare payments for 2019 or to identify the accounts where they should expect relief payments.
  • Employed Physicians. Employed physicians should not expect to receive an individual payment directly. The employer organization will receive the relief payment as the billing organization.
  • Physicians in a Group Practice. Individual physicians and providers in a group practice are unlikely to receive individual payments directly, because, as the billing organization, the group practice will receive the relief fund payment. Providers should look to the part of their organization that bills Medicare to identify details on Medicare payments for 2019 or to identify the accounts where they should expect relief payments.
  • Solo Practitioners. Solo practitioners who bill Medicare will receive a payment under the TIN used to bill Medicare.

You have to be in good standing with Medicare and other federal health programs.
Not surprisingly, providers can receive the money only if they aren't currently terminated from Medicare; aren’t excluded from participation in Medicare, Medicaid, or other federal health programs; or haven’t had their Medicare billing privileges revoked.

You have to attest to receiving the funds — and agree to the terms and conditions — within 30 days of receiving the payment.
Providers who received payment are required to attest that they've received the funds and agree to the program's terms and conditions within 30 days of receipt. You can do that by visiting the CARES Act Provider Relief Fund Payment Attestation Portal.

Documentation will be important.
Recipients of payment will be required to submit reports to HHS as needed to ensure compliance with the terms and conditions. HHS hasn't yet shared instructions about the form and content of the reports.

Not sure if you're receiving funds? Call 866-569-3522.
UnitedHealth Group is handling the stimulus payments for HHS — call their provider relations department to find out the status of a payment or whether you qualify. If you haven't set up direct deposit through CMS or UHG, you'll receive a paper check within the next week or two. Although CMS is not administering the program, if you are a Medicare provider and have questions that UHG can't answer, email COVID-19@cms.hhs.gov.

Additional money may be coming to other types of providers.
The administration is working on targeted distributions focused on providers in areas particularly impacted by the COVID-19 outbreak, including rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans. APTA sent a letter to HHS several weeks ago urging HHS to provide immediate assistance to physical therapy specialists, including pediatric physical therapy providers, that are dependent on Medicaid and have few or no patients with Medicare.

APTA can't provide legal advice or answer questions about individual cases.
Please note that APTA cannot provide legal advice, meaning that we are unable to provide clarification beyond what HHS has provided thus far. If you have questions beyond what has been provided, please consider consulting with a local attorney.


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