Publication

April 28, 2020

All providers with a Medicare billing tax identification number may now apply for a grant from the Phase II CARES Act Provider Relief Fund via the following Provider Relief Fund General Distribution Portal.  This fund was recently supplemented with an additional $20 billion in funding following the $30 billion in Phase I Funds distributed between April 10 and April 17.  A Phase III round of funding aimed at Medicaid-heavy providers is reportedly in process and will follow. 

According to the U.S Department of Health & Human Services ("HHS"):

1. The $30 billion of Phase I was distributed proportionate to providers' share of Medicare fee-for-service reimbursements in 2019. Specifically, on Friday, April 10, $26 billion was delivered to bank accounts while the remaining $4 billion of the expedited $30 billion distribution was sent on April 17.
    
2. To initiate Phase II, HHS began distributing the remaining $20 billion of the general distribution to providers that submit costs reports such as hospitals automatically on April 24 to augment their allocation so that the whole $50 billion general distribution was allocated proportional to providers' share of 2018 net patient revenue. 

Providers such as physicians, groups, and others that do not utilize cost report data can now apply through the General Distribution Portal.  Providers are suggested to apply as soon as possible before funding runs out.  Certain terms and conditions apply as detailed here but, if met, the funds do not need to be repaid as they are grants and not loans.  The American Medical Association has put out guidance recommending having the following on hand while applying:

• Taxpayer Identification Number (TIN) that has received prior Provider Relief Fund payments;
   
• TINs of subsidiary organizations that have received prior Provider Relief Funds but do not file separate tax forms (i.e., subsidiary organizations that are accounted for in the parent organization’s tax filing);
   
• Medicare ID;
  • The portal’s customer service line responded that anyone with a billing TIN (including pediatricians and gynecologists) should complete the application;
     
• Amount of payments received;
   
• Lost March 2020 revenues;
   
• Estimated lost April 2020 revenues;
   
• Relief Fund payment transaction numbers/check numbers; and
   
• A copy of your most recently filed tax forms; see Appendix A: Federal Tax Classification Matrix (will need to upload these forms in the application).

HHS has clarified that Providers who have already received payments from the CARES Act Provider Relief Fund may be eligible to receive additional funds.  Providers who have already received payments from the CARES Act Provider Relief Fund must attest to each payment associated with their billing Taxpayer Identification Number(s). In addition, providers who have already received payments will need to upload their most recent IRS tax filings as well as estimates of lost revenues for March and April 2020.

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