Recent Updates to the Provider Relief Fund FAQs

HHS updates the Frequently Asked Questions (FAQs) on a regular basis. Following are some of the current noteworthy updates.

1. HHS has clarified the treatment of the Provider Relief Fund payments that were issued to the seller, prior to the completion of a sale. To summarize, if the transaction was a stock or membership purchase, the recipient of the funds may continue to use the funds. However, if the transaction was an asset purchase, then the fund recipient must use the funds for its eligible expenses and lost revenue, and return to HHS any unused funding. Although the funds do not transfer to the buyer, the buyer may be eligible for future funding.
2. HHS has also clarified that Provider Relief Funding may be used on any eligible expenses or lost revenue throughout the COVID-19 pandemic. At the conclusion of the pandemic, providers will return any unused funds back to HHS. HHS will provide the details on the returning of unused funds at a future date. The FAQs also notes that providers should maintain all records of their Provider Relief Fund payment expenditures for three years from the date of the final expenditure.
3. Clarification was provided for the calculation of lost revenue. To summarize, lost revenue estimates should be based on budget-to-actual or year-to-year revenue, should include revenue from all payer sources, and may include lost revenue from the value-based purchasing program, such as quality measure achievement payments.
4. The application process for the Medicaid targeting funding is currently open. HHS has clarified that Medicaid providers that did not qualify for the General Distribution and did not bill Medicaid/CHIP during the eligibility window, may apply for this targeted funding as long as they provided diagnosis, testing or care for persons with possible or actual cases of COVID-19, after January 31, 2020. Please note that HHS views every patient to be a possible COVID-19 case. Providers that do not meet these criteria may still qualify for future allocations of the Provider Relief Fund.

Marcum will continue to provide updates on future activity of the Provider Relief Fund. Please reach out to your Marcum Healthcare Advisor with any questions you may have.