New Details on Incentive Based Provider Relief Funds

by | Sep 23, 2020 | Blog, COVID-19, Reimbursement

CARES Act Provider Relief Fund

The U.S. Department of Health and Human Services (HHS) Provider Relief Fund has made $50 billion available for distribution to Medicare fee-for-service providers as financial relief during the coronavirus (COVID-19) pandemic.

Phases of Distribution

For Phase 1 General Distribution, HHS distributed $30 billion to eligible providers throughout the American healthcare system in April 2020.

For Phase 2 General Distribution, HHS made available $18 billion for eligible providers – those who participate in state Medicaid/CHIP programs, Medicaid managed care plans, dentists, and certain Medicare providers, including those who missed Phase 1 General Distribution payment equal to 2% of their total patient care revenue or had a change in ownership in 2019 or 2020.

Funding Specific To Nursing Homes

As part of the Targeted Distributions, HHS included U.S. nursing homes, beginning with an initial  distribution of  $4.9 billion to skilled nursing facilities (SNFs) .  A second distribution of almost $2.5 billion to skilled nursing facilities and nursing homes nationwide aimed to help combat the devastating effects of the pandemic. Additionally, a separate $2 billion incentive payment structure is providing more funding to nursing homes and skilled nursing facilities based on certain performance measures.

Performance Incentive PRF Payments

On September 17, 2020, HHS announced additional details regarding the $2 billion incentive payment structure for nursing facilities (see section “How is the $2 billion incentive payment to skilled nursing facilities and nursing homes being determined?”).  In order for a nursing facility to be eligible for payment under this incentive payment distribution, it must pass two initial gateway tests:

      • First, a facility must demonstrate a rate of COVID-19 infections that is below the rate of infection in the county in which the facility is located (Infection Measure). This benchmark requirement for infection rate reflects the goal of the incentive program to recognize and reward facilities that establish a safer environment than the community in which they are located.
      • Second, a facility must have a COVID-19 death rate that falls below a nationally established performance threshold for mortality among nursing home residents infected with COVID-19 (Mortality Measure).

For each performance period, the total available bonus payments will be determined based on aggregate performance on the infection measure. This total will then be split into separate payment pools for performance on the infection and mortality measures.

      • First, 80% of bonus payments will be available to providers that have positive performance on the infection measure.
      • Second, 20% of bonus payments will be available to providers that have positive performance on the mortality measure. Providers scoring below a threshold level of performance on the mortality measure will be deemed ineligible for payment in both the infection and mortality payment pools.

Tentative payment and audit dates by performance period are as follows:

Post-Payment Reporting Requirements

All recipients of Provider Relief Fund (PRF) payments are required to comply with the reporting requirements described in the Terms and Conditions and specified in future directions issued by the HHS Secretary. Per the September 19, 2020 General and Targeted Distribution Post-Payment Notice of Reporting Requirements, recipients will need to report their use of PRF payments by submitting healthcare related expenses attributed to coronavirus. The purpose of this notice is to inform PRF recipients that received one or more payments exceeding $10,000 in the aggregate of the data elements that they will be required to report as part of the post-payment reporting process.  Learn more in this supporting document to the July 20, 2020 Post-Payment Notice of Reporting Requirements: General and Targeted Distribution Post-Payment Notice of Reporting Requirement – PDF.   Please note that these reporting requirements do not apply to the Nursing Home Infection Control distribution or the Rural Health Clinic Testing distribution. The reporting system will now be available in early 2021. The required data elements include:

      • Demographic Information
      • Expenses Attributable to Coronavirus Not Reimbursed by Other Sources
      • Lost Revenues Attributable to Coronavirus
      • Additional non-financial data will also be collected (per quarter)

Auditing

PRF recipients may be subject to auditing to ensure the accuracy of the data submitted to HHS for payment. Any recipients identified as having provided inaccurate information to HHS will be subject to payment recoupment and other legal action.  Further, all recipients of Provider Relief Fund payments shall maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR § 75.302 – Financial management and 45 CFR § 75.361 through 75.365 – Record Retention and Access, and other information required by future program instructions to substantiate that recipients used all Provider Relief Fund payments appropriately.

Upon the request of the Secretary, the recipient shall promptly submit copies of such records and cost documentation and the recipient must fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with applicable Terms and Conditions.  Deliberate omission, misrepresentation, or falsification of any information contained in payment applications or future reports may be punishable by criminal, civil, or administrative penalties, including but not limited to revocation of Medicare billing privileges, exclusion from federal health care programs, and/or the imposition of fines, civil damages, and/or imprisonment.

For more details, please refer to the Terms and Conditions associated with each payment distribution and the Reporting Requirements and Auditing FAQs.

References:

Contact Proactive for support in reducing and/or managing outbreaks. Our Infection Control & Prevention focused services include:

      • Infection Preventionist Consultations
      • Infection Prevention & Control Training & Competency Assessments
      • Directed Plan of Correction Consultation
      • Policy and Procedure Development
      • Infection Control Focused Mock Surveys
      • Survey Support

 

Blog by Eleisha Wilkes, RN, RAC-CTA, Proactive Medical Review

Click here to learn more about Eleisha and the rest of the Proactive team.




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