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04/22/2020

CMS Provider Relief Fund - WATCH OUT - READ the Terms and Conditions!

CARES Act Provider Relief Fund
 
From the $100 billion appropriated to HHS, $30 billion is being directly disbursed to facilities and health professionals that billed Medicare FFS in 2019.  Disbursements began on April 10, 2020. According to HHS, distributions from the CARES Act Provider Relief Fund are grants, not loans, and do not have to be repaid. 

The funds will go to each organization's TIN which normally receives Medicare payments, not to each individual physician. These automatic payments will come to eligible organizations via Optum Bank with “HHSPAYMENT” as the payment description. 

Within 30 days of receiving the funds, clinicians must sign an attestation at (covid19.linkhealth.com) confirming receipt of the funds and agreeing to the terms and conditions.

According to CMS, these funds are grants, not loans, and do not have to be repaid.  So, It looks like free money you can use however you want...... MAKE SURE YOU READ THE  CONDITIONS associated with acceptance of the funding and understand what the funds are allowed to be used for:

Some of the conditions include:

"The Recipient certifies that the Payment will only be used to prevent, prepare for, and respond to coronavirus, and shall reimburse the Recipient only for health care related expenses or lost revenues that are attributable to coronavirus."

You must submit reports:

"Not later than 10 days after the end of each calendar quarter, any Recipient that is an entity receiving more than $150,000 total in funds under the Coronavirus Aid, Relief, and...."

"This report shall contain: the total amount of funds received from HHS under one of the foregoing enumerated Acts; the amount of funds received that were expended or obligated for reach project or activity; a detailed list of all projects or activities for which large covered funds were expended or obligated, including: the name and description of the project or activity, and the estimated number of jobs created or retained by the project or activity, where applicable; and detailed information on any level of sub-contracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees, to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 allowing aggregate reporting on awards below $50,000 or to individuals, as prescribed by the Director of the Office of Management and Budget."

You must maintain records and cost documentation:

"The Recipient shall maintain appropriate records and cost documentation including, as applicable, documentation required by 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 the reimbursement of costs under this award. The Recipient shall promptly submit copies of such records and cost documentation upon the request of the Secretary, and Recipient agrees to fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with these Terms and Conditions."

The following statutory provisions also apply:

"None of the funds appropriated in this title shall be used to pay the salary of an individual, through a grant or other extramural mechanism, at a rate in excess of Executive Level II"  ($197,300)

CLICK HERE TO READ ALL OF THE TERMS AND CONDITIONS  

Failure to abide by the terms and conditions:

Could result in False Claims Act liability for healthcare providers that do not make proper use of the funds.  Thus, recipients of the funds should carefully consider their ability to comply with the terms and conditions and should ensure that proper controls are in place for proper use of the funds.

There’s always FREE cheese ? in a mouse ? trap!

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