Funding Allocation for Private Pay AL - Additional Information NCAL has provided us with additional details that may be helpful as you prepare your applications for HHS distributions to private pay AL providers/ Some media resources have indicated that the application only needs to be "initiated" by September 13. Scott Tittle, ED of NCAL checked into this and found that there are some preliminary steps as a part of the application process to confirm an applicant's TIN which needs to at least be completed by the 13th. He shared that the application needs to be initiated by the 13th and would encourage everyone to go ahead and complete them if possible as well. Scott heard this morning that HHS has already started paying out distributions to private pay AL providers who have completed their applications.
Katherine Preede, VP at NCAL shared the following: There are a few items that certainly might be helpful to you and members. One thing I want to emphasize is that it is very unlikely we can answer all member questions. HHS is quite slow to respond to emails, or update the FAQs, and this is not without NCALs effort, it is much better for the provider to go straight to the CARES act hotline, CARES Act Fund Hotline at (866) 569-3522 (for TTY dial 711) with specific questions or review HHS's Frequently Asked Questions. NCAL is checking the FAQs every day to see if anything new is published.
Some very helpful links are below: AHCA/NCAL Tips Sheet: https://www.ahcancal.org/Survey-Regulatory-Legal/Emergency-Preparedness/Documents/COVID19/Tips-HHS-Medicaid-Portal.pdf
Q: Is this a loan or a grant that I will need to pay back? A: Retention and use of these funds are subject to certain terms and conditions. If these terms and conditions are met, payments do not need to be repaid at a later date. These Terms and Conditions can be found on the For Providers page.
Q: How should assisted living facilities calculate revenue from patient care? (Added 9/1/2020) A: "Patient care" means health care, services and supports, as provided in a medical setting, at home, or in the community to individuals who may currently have or be at risk for COVID-19, whereby HHS broadly views every patient as a possible case of COVID-19. Assisted living facilities that are applying for Phase 2 - General Distribution funds may include patient care revenue that supports residents' nutritional, housing, activities of daily living, and medical needs, including purchased services.
A: Resident fees that cover their accommodations can be considered patient service revenue.
Q: What was the methodology/formula used to calculate provider payment? (Modified 9/1/2020) A: The Phase 2 - General Distribution methodology will be based upon 2% of (revenues * percent of revenues from patient care) from the applicant's most recent federal income tax return for 2017, 2018 or 2019 and with accompanying submitted tax documentation. Payments will be made to applicant providers who are on the filing TIN curated list submitted by states to HHS or whose applications underwent additional validation by HHS.
A: No. However, HHS is making payments to safety net hospitals that serve the nation's most vulnerable citizens on the front lines in addition to the Phase 2 - General Distribution payments for Medicaid, CHIP, and dental providers. These hospitals serve a disproportionate number of Medicaid recipients and provide large amounts of uncompensated care and operate on thin profit margins. HHS may make further Provider Relief Fund payments to non-hospital safety net providers in the future.
Q: An organization has prescription sales as part of its revenue. Can these sales be captured in the data submitted as a part of revenue from patient care? (Added 9/3/2020) A: Generally no. Only patient care revenues from providing health care, services, and supports, as provided in a medical setting, at home, or in the community may be included. Patient care revenues do include savings obtained by providers through enrollment in the 340B Program. HHS is still reviewing potential exceptions to the rule as related to providers who provide unreported health care services as a part of the furnishings of pharmaceuticals.
Be sure to also see the HCAM/MCAL update released this evening regarding the Visitation Emergency Order.
For additional questions or concerns please contact Linda Lawther at LindaLawther@michcal.com.
Sept. 10, 2020 |