At the COVID-19 White House briefing on April 7, 2020, CMS Administrator Seema Verma provided additional information on the distribution of the $100 billion health care relief fund (“Fund”) to health care entities as provided in the CARES Act.
After the briefing, CMS sent out a press release giving an update on requests under the Medicare Accelerated or Advanced Payment Program (“APP”) (Administrator Verma also mentioned amounts distributed under the APP during the White House briefing). Highlights on each are below.
On April 8, Hall Render held an Information Session on the Fund and expanded APP, including the updates described below. A recording of the Information Session is available here.
CARES Act $100 Billion Health Care Relief Fund
Administrator Verma provided the following information at the briefing:
- $30 billion from the Fund will be put out this week.
- This amount will be distributed to entities based on their “Medicare revenue.”
- Administer Verma did not indicate how this would be calculated (e.g., what is the lookback period and what types of Medicare payments are included).
- These are “essentially grants” with “no strings attached” and “health care providers can spend that any way they see fit.” This is interesting since the CARES Act contained language indicating that documentation and an application may be required. In addition, Secretary Azar previously had said that entities would need to agree to not bill uninsured patients to receive funds.
- Since CMS does direct deposit with many health care providers, the money will “go right into their bank accounts.”
- For Medicare providers not on direct deposit with CMS, it will require “some very simple registration.”
- This money will not be put out on a first-come-first serve basis.
- For providers who get the majority of their revenue from Medicaid, private payers or some other non-Medicare source (children’s hospitals, nursing homes, certain physician practice groups), those entities will get priority when the next round of the Fund is distributed.
We released a previous article with more information on the Fund (available here).
Medicare Accelerated Payment Program
In the Press Release, CMS stated that:
- Approximately $34 billion has been sent in the past week to health care providers under the APP.
- The streamlined process implemented by CMS for COVID-19 has reduced processing times for an APP request to between four to six days.
- In a little over a week, MACs have received over 25,000 APP requests and have already approved over 17,00 requests.
- Prior to the COVID-19 pandemic, just over 100 total APP requests were approved in the past five years, with most being tied to natural disasters, such as hurricanes.
- Amounts approved under the APP are completely separate from the Fund.
In a previous article, we provided an overview of the expanded APP (available here).
If you have questions or would like additional information about this topic, please contact:
- David Snow at (303) 801-3536 or dsnow@hallrender.com;
- Lori Wink at (414) 721-0456 or lwink@hallrender.com;
- Joseph Krause at (414) 721-0906 or jkrause@hallrender.com;
- Elizabeth Elias at (317) 977-1468 or eelias@hallrender.com;
- Benjamin Fee at (720) 282-2030 or bfee@hallrender.com; or
- Your regular Hall Render attorney.
Hall Render’s attorneys and professionals continue to maintain the most up-to-date information and resources at our COVID-19 Resource page, through our 24/7 COVID‑19 Hotline at (317) 429-3900, or your regular Hall Render attorney.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
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