Provider Relief Fund
ALERT: The U.S. Department of Health and Human Services (HHS) announced that $30 billion is being distributed immediately – with payments arriving via direct deposit beginning April 10, 2020 – to eligible providers throughout the American health care system. This $30 billion is part of the CARES Act that provides $100 billion in relief funds to hospitals and other health care providers on the front lines of COVID-19.
These are payments, not loans, to health care providers, and will not need to be repaid. However, there are terms and conditions attached to these payments. We’ve collected the updates specific to you as a physician and you can view the full announcement from HHS.
- On May 22, HHS announced a 45 day deadline extension for providers who are receiving payments from the Provider Relief Fund to accept the Terms and Conditions for Provider Relief Fund payments. This announcement means providers have now been granted 90 days from the date they received a payment to accept HHS Terms and Conditions or return the funds. Read more.
- HHS released additional updates regarding the CARES Act Provider Relief Fund. Some of those updates are listed below and full details along with some of AAPM&R's considerationscan be found here from our May 8 news story.
- Providers who received a payment through this program and intend to keep the money are required to complete an attestation through the HHS attestation portal, which includes verification of the amount(s) received and an agreement to abide by the Terms and Conditions. Providers must complete this by June 3.
- A refined formula HHS is using to calculate total allocations for all providers. This formula may result in some providers having received funds in excess of the amount HHS calculates as due to them under the new formula, while other providers may now be eligible for additional allocation.
- A public release of the names of providers who have received allocations through the program and have attested to the terms and conditions. This public release includes the name, city, state, and amount of allocation for each provider.
- In addition to completing the attestation, HHS is also asking those who have received funds to submit revenue information through a general distribution portal.
- On April 22, HHS announced it is adding an additional $20 billion to the original $30 billion for what it describes as a $50 billion “general allocation.” The initial $30 billion was distributed between April 10 and April 17, and the remaining $20 billion is being distributed beginning Friday, April 24. The remaining fund distribution will be based on 2018 net patient revenue, not just Medicare fee-for-service.
Of the remaining $50 billion, $10 billion will be allocated for a targeted distribution to hospitals in areas that have been particularly impacted by the COVID-19 (application open as of 4/23); $10 billion for rural providers distributed as early as next week (no application needed); $400 million for Indian Health Services; there is an unspecified amount of funding allocated for treatment of the uninsured; and additional unspecified amount of funding for skilled nursing facilities, dentists, and providers that solely take Medicaid.
- On April 16, the CARES Act Provider Relief Fund Payment Attestation Portal officially opened. Providers who have been allocated a payment from the initial $30 billion general distribution must sign an attestation confirming receipt of the funds and agree to the terms and conditions within 30 days of payment. Due to the nature of the portal, AAPM&R has not yet been able to access the language in the attestation. We understand the portal has a variety of steps, including confirmation of eligibility, billing TINs, verifying payment information, attestations (likely related to the terms and conditions), and confirmation.
Additionally, we understand that several AAPM&R members have not yet received their Provider Relief Fund payment. Providers can contact UnitedHealth Group’s Provider Relations department at (866) 569-3522 about eligibility, whether a payment has been issued, and where it was sent.
- On April 14, HHS released updated terms and conditions, but we are awaiting additional clarification from HHS, as there are still many questions that remain (e.g., around balance billing, tax treatment, executive compensation, and more). Some of these questions may be clarified in the forthcoming attestation form. This form will be signed by providers to attest that they comply with the broad terms and conditions of the relief funds. We recommend that you carefully review the terms and conditions, including with your accountants/financial advisors, to determine the best course of action.
Paycheck Protection Program
May 15: The Small Business Administration (SBA), in consultation with the Department of the Treasury, released the Paycheck Protection Program (PPP) Loan Forgiveness Application and detailed instructions for the application. The form and instructions inform borrowers on how to apply for forgiveness of their PPP loans, consistent with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). SBA will also soon issue regulations and guidance to further assist borrowers as they complete their applications, and to provide lenders with guidance on their responsibilities. The documents released on May 15 will help small businesses seek forgiveness at the conclusion of the eight week covered period, which begins with the disbursement of their loans. View the application and instructions here.
On April 24, in response to AAPM&R's letter to Congress regarding the fourth COVID-19 package, the “Paycheck Protection Program and Health Care Enhancement Act” (“COVID 3.5”), was officially signed into law. The bill provides $484 billion in additional funding to replenish and supplement key programs under the CARES Act, including the PPP, small business disaster loans and grants, hospitals and health care providers, and testing. The small business loan programs authorized under the CARES Act had been quickly depleted after only two weeks of operation. View specific components of the bill here.
- On April 16, the U.S. Small Business Administration released a notice regarding new applications: SBA is unable to accept new applications at this time for the Paycheck Protection Program or the Economic Injury Disaster Loan (EIDL)-COVID-19 related assistance program (including EIDL Advances) based on available appropriations funding. EIDL applicants who have already submitted their applications will continue to be processed on a first-come, first-served basis. AAPM&R is advocating for a quick solution to provide more funding and we will share updated information when available.
To help you sort through the abundance of information, we have collected a variety of resources to help our physiatrists who may need small business assistance:
- U.S. Small Business Administration Interim Final Rule On April 2, the U.S. Small Business Administration (SBA) released an interim final rule that provides guidance on the provisions in the CARES Act, including:
- Eligibility requirements (page 5)
- A maximum loan amount of $10 million and a guide as to how to calculate your maximum loan amount (pages 8-10)
- Loan maturity of 2 years, rather than 10 years as the CARES statute originally provided (page 12)
- A loan interest rate of 1% (page 12)
- First payment deferred for 6 months, rather than 1 year as indicated in the CARES statute
The amount of loan forgiveness can be up to the full principal amount of the loan and any accrued interest. 75% of the loan forgiveness amount must be attributable to payroll, rather than operational costs (pages 13-15)
- The applicant must submit SBA form 2483 (page 15)
- The full rule is located here. Please note:
- The first 18 pages are useful to borrowers
- Pages 19-27 are useful to lenders
- Pages 28-31 are administrative law tasks to ensure the loans are legal
Accelerated Payment and Advance Payment Programs
In these programs, physiatry practices may essentially borrow against their expected future Medicare payments in order to maintain necessary financial resources during the COVID-19 crisis. The Accelerated Payment and Advance Payment Programs are different than the Provider Relief Fund and the Paycheck Protection Program. View more information in this fact sheet from CMS.
- April 26: The Centers for Medicare and Medicaid Services (CMS) has announced that it is suspending the Advance Payment Program, effectively immediately. Due to the additional funding for the Provider Relief Fund appropriated in the CARES Act and the Paycheck Protection Program and Health Care Enhancement Act, CMS is reevaluating the Advance Payment Program and will not be accepting any new applications. All pending and new applications for accelerated payments will also be reevaluated. CMS states that significant additional funding will continue to be available to hospitals and other health care providers through other programs, and we will keep the membership informed of any new developments.
Share Your Feedback: Private Practice Survey
We recognize that private practice PM&R physicians are facing a unique set of challenges. Knowing that many physiatrists are being placed in difficult situations and need access to resources and support, the Academy is identifying opportunities on how we can support you in this time of need. To ensure we are providing you the resources you need, please take five minutes and complete this survey. Thank you in advance for your time and feedback!
Critical Conversations: Private Practice Experiences During the COVID-19 Pandemic
Originally recorded April 2, 2020
This member-to-member conversational webinar gave participants the opportunity to ask their questions about small business loans, furloughing employees, and rapidly implementing telemedicine.
- Mehul J. Desai, MD, MPH, FAAPMR – from International Spine, Pain and Performance Center in Washington, DC
- Larry H. Chou, MD, FAAPMR – from Premier Orthopaedic and Sports Medicine in Havertown, PA
- Annie D. Purcell, DO, FAAPMR – from Redding Spine and Sports Medicine in Redding, CA
AAPM&R's Update on Financial Relief for Physiatrists
Originally recorded April 7, 2020
This discussion covered new opportunities for practices including the Medicare Accelerated and Advance Payment Program and the Small Business Administration's (SBA) loans.
- Stuart J. Glassman, MD, FAAPMR – from Granite Physiatry in Concord, NH
- Peter Thomas – from Powers Law in Washington, DC
- Kathleen Hatfield – from Powers Law in Washington, DC
PM&R Recruitment, Job Placement, and Supplementing Income During the COVID-19 Pandemic
Originally recorded April 20, 2020
Despite millions of jobs being affected due to COVID-19, recruiting is still taking place. This panel discussion featured PM&R recruiters who provided insights into what is happening with job placements.
- Randy Awni – Co-Founder of Miner/Mason & Associates in Los Angeles, CA
- Marc Duerden, MD, CIME, FAAPMR – from Indiana Medical Examinations in Indianapolis, IN
- Tony Stajduhar – President of Jackson Physician Group in Alpharetta, GA