HHS clarified on its website and the payment portal that it is distributing the remaining $20 billion of the $50 billion general distribution to Medicare providers to augment providers’ allocations so that the whole $50 billion general distribution is allocated proportional to providers’ share of net patient revenue. The $50 billion of the Provider Relief Fund is allocated for general distribution to Medicare facilities and providers impacted by COVID-19, based on eligible providers’ net patient revenue. Indicating that they want the general distribution to replace a percentage of a provider’s annual gross receipts, sales, or program service revenue.

On the attestation page HHS communicates the allocation process and provides a way to estimate your allocation portion.  See Attestation

The Provider Relief Fund Application Portal is collecting four pieces of information for use in allocating remaining General Distribution funds:

1) a provider’s “Gross Receipts or Sales” or “Program Service Revenue” as submitted on its federal income tax return;

2) the provider’s estimated revenue losses in March 2020 and April 2020 due to COVID;

3) a copy of the provider’s most recently filed federal income tax return;

4) a listing of the TINs any of the provider’s subsidiary organizations that have received relief funds but that DO NOT file separate tax returns.

Providers must estimate lost revenue from March and April 2020. Providers can estimate March losses by comparing year-over-year revenue, and they can estimate April losses by using data from the first few weeks of April to estimate total monthly losses, or by extrapolating total monthly losses using data from March. HHS also states that providers can estimate lost revenue by using the difference between budgeted revenue and actual revenues.

The HHS terms and conditions for the $20 billion General Distribution maintain the terms and conditions for the prior $30 billion General Distribution. There are two additional terms and conditions:

• The recipient must submit general revenue data for calendar year 2018 when applying to receive a payment, or within 30 days after receipt of a payment.
• The recipient must agree that HHS can publicly disclose any payments a provider receives from the Provider Relief Fund, and acknowledge that such disclosure may allow third parties to estimate the recipient’s gross receipts or sales, program service revenue or other equivalent information.

HHS has a General Distribution Portal FAQs available.

We will continue to provide updates as HHS continues to clarify and streamline the attestation, application, allocation, reporting of financial information and use of the $50 billion Cares Relief general distribution funds.  Be sure you have marked the 30-days timeline that you need to attest to accept or return the funds.

Note that guidance is evolving on eligibility and use of funds.  It is important to track payments and track expenses.

Begin Recordkeeping and Documentation Practices.

• HHS is expected to release future guidance on the records needed to support the appropriate use of funds under the grant. Current guidance requires quarterly detailed reporting on amounts and the nature of expenses, including a list of all projects and activities for which funds were expended or obligated, and the amount of funds received that were expended or obligated for each project or activity. Preparation of templates and/or documentation recording this information can be a helpful base for such reporting.
• Consider creating a budget, memo or other internal document showing the use of funding.
• Collect and save relevant documents, emails and other communications related to the use of funds.

If you need assistance with any of these items, we are here to help.  Reach out to your WR Partner, your relationship manager or our Healthcare Services Team for more information:  healthcare@websterrogers.com.