- Compensation for Nursing Home Workers Infected by COVID - October 26, 2020
- Phase 3 of Provider Relief Funding Announced - October 19, 2020
- Issues Related to Disabled People with COVID in Group Settings - October 12, 2020
Providers, including nursing homes, have seen extra expenses and lost revenue due to coronavirus. They’ve faced these costs not only because of treating patients but in preparing facilities and due to the pandemic lockdowns.
On October 1, 2020, the U.S. Department of Health and Human Services announced Phase 3 of Provider Relief Funding, $20 billion in assistance to “providers on the frontline of the coronavirus pandemic.” Providers who already received funding under Provider Relief are invited to begin applying for funds as soon as October 5, 2020. Phase 3 also opened funding opportunities to those were previously ineligible. Deadline: November 6, 2020.
- Providers seeking their first payment: Providers who did not apply for, or rejected, a previous distribution. Providers who have not received a payment equal to approximately 2% of their patient care revenue from prior general distributions will receive a payment that, when combined with any prior payments, does equal 2% of revenue from patient care.
- Providers seeking additional (add-on) Payments: Providers that have already received payments may submit more information to become eligible for an additional payment of approximately 2% of annual revenue.
- New Providers: Healthcare providers that began practicing January 1, 2020 through March 31, 2020. This includes Medicare, Medicaid, CHIP, dentists, assisted living facilities, and behavioral health providers.
By including behavioral health providers, who were previously excluded, the relief order recognizes the increased mental health and substance abuse problems due to the pandemic and lockdown. It recognizes the explosion of anxiety and depression that behavioral health providers are treating
To calculate an equitable add-on payment, HHS will consider:
- Any change in operating revenues from patient care
- Any change in operating expenses from patient care, including expenses due to the pandemic
- Payments already received through prior Provider Relief Fund distributions
Payments will not be calculated until the HRSA has reviewed all applications from providers
To see the original press release, go here.
There are many terms and conditions of use to review. Some of them are as follows:
- You must have provided or diagnosis, testing, or care for potential or actual COVID-19 patients
- You can’t have been terminated or excluded from Medicare, Medicare Advantage, or Medicare Part D funding;
- You must only seek to be reimbursed for expenses or losses related to COVID-19;
- You must not use the funds to reimburse for expenses or losses that have been reimbursed from other sources (you’re not “double-dipping”)
- HHS can publicly disclose the funding
- There are various reporting requirements (consult an attorney)
- You must retain records
- Because of the public health emergency and the importance of getting people care where it is possible, out of network patients cannot be charged more than in-network patients during this time.
The Terms also contain seemingly off-point, political prohibitions on using the funds for things like gun control, legalization of drug advocacy, other kinds of lobbying.
Previously, it was a little fuzzy what expenses and lost revenue could be claimed. In June, the HRSA provided a little bit of clarification and it appears that the following are Allowable Expenses:
- Supplies used to provide healthcare services for possible or actual COVID-19 patients. Think PPE, testing kits, and thermometers.
- Equipment used to provide healthcare services for possible or actual COVID-19 patients. Think ventilators and oxygen.
- Workforce training. This will be helpful to providers who put together video training or held seminars to teach staff about risk factors, testing, social distancing, PPE, etc.
- Building or constructing temporary structures to help to isolate COVID-19 suspected or actual patients and the rest of the facility.
- Acquiring additional resources, including facilities, equipment, supplies, healthcare practices, staffing, and technology to expand or preserve care delivery. This will be especially helpful for facilities that increased staffing to ensure staff was not operating at multiple facilities, which was a major risk factor for spreading COVID to nursing homes.
The clarification, although less helpful, also extended to Allowable Lost Revenues, which include:
- Fewer outpatient visits
- Canceled elective procedures
- Increased uncompensated care
- Employee or contractor payroll
- Employee health insurance
- Rent or mortgage payment
- Equipment lease
- Electronic health record recording fees
All of this shows that the pandemic relief is intended to compensate for the overall lockdown results and people’s medical decisions in light of the need to socially distance and avoid infection, not only directly helping those with COVID.