Many healthcare providers were pleased to find an “HHS stimulus payment” from the CARES Act Provider Relief Fund earlier in April. This payment was a grant, not a loan, based on a provider’s pro-rata share of Medicare billing in 2019. As part of the terms and conditions of this payment providers were required to provide an attestation to HHS confirming the receipt of funds and agreeing to the terms and conditions of the payment.
HHS launched this portal (called the “Payment Attestation Portal”) on Thursday April 16th to allow providers to complete this attestation. On April 24th, 2020, HHS announced that the second tranche of the provider relief fund of $20,000,000,000 would be distributed to providers after providing information in the “General Distribution Portal.” Note that these are separate portals both found on the HHS.gov Coronavirus relief website.
To complete the initial attestation
To complete the initial attestation providers will need to provide the following information:
1. Complete EIN of the provider.
2. The last 6 digits of the bank account where the funds were received.
3. The amount of the initial provider relief fund payment.
4. Completion of the certification.
Information needed to complete 2nd General Distribution
To claim the 2nd General Distribution, providers also should be prepared to provide the following information:
1. EIN of the provider.
2. Banking details (checking and routing number)
3. Gross Receipts per last filed tax return.
4. Estimated revenue losses from March & April 2020 – this can either be vs a prior year or versus a previously budgeted or forecasted amount.
5. Most recently filed tax return.
6. EINs of any subsidiary organizations that receive payments but may not have filed separate tax returns – such as Single Member LLC’s treated as a disregarded entity.
As part of these certifications, providers will need to agree to the terms & conditions of the payment. There still exists uncertainty and ambiguity to some of these terms, including the current provision of care for an individual with possible or actual cases of COVID-19. Prior guidance on the HHS website stated “HHS broadly views every patient as a possible case of COVID-19” and not just patients specifically diagnosed with COVID-19. Therefore, so long as a provider provided treatment after January 31, 2020 and billed Medicare, they will have been deemed in compliance with this term and condition.
Providers should note the other terms and conditions of the program, including uses and limitations of the funds, limitations on “balance billing,” and potential reporting requirements.
Edward McWilliams, CPA
Ed is a Partner in the firm’s tax and business advisory practice focusing on providing services to middle market private companies across different industries as well as to early stage startups. Ed has over a decade of experience providing tax and business consulting services to these companies of different sizes and across different industries, bringing a broad and diverse knowledge base and strategic solutions to the many complex issues that businesses face.