The Department of Health and Human Services (“HHS”) continues to modify guidance related to reporting requirements of the provider relief funds (“Relief Funds”) that were part of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). The initial Post-Payment Notice of Reporting Requirements were released on July 20, 2020 and then later modified on September 19, 2020. We analyzed those changes in a previous article. In its latest guidance from October 22, 2020, HHS modified the Post-Payment Notice of Reporting Requirements for Relief Funds which should benefit providers.
Jameson E. Sauseda
Jameson advises clients on regulatory matters, mergers and acquisitions and other business transactions. In order to better understand clients’ financial situations, he earned a master’s degree in accounting with an emphasis on taxation. Jameson has experience analyzing financial statements, institutional investments and tax compliance regulations, including 501(r) compliance. While he is a talented attorney and analyst, his top priority is client communication. He’s known for his dedication to understanding clients’ unique circumstances and goals, and for his ability to clearly explain the legal issues impacting clients. He now applies both his legal skills and his tax background to achieve the best results for clients.
HHS Opens Application for $20 Billion of Phase 3 General Distribution Provider Relief Funds
On October 1, 2020 the Department of Health and Human Services (“HHS”) announced that it will distribute a total of $20 billion as part of Phase 3 of the Provider Relief Funds. The application for Phase 3 funding is now open and will be available from October 5 – November 6, 2020. However, HHS has urged providers to apply early, which may be an indication that the funds will be available on a first-come first-serve basis.
Below are some key details regarding Phase 3:
HHS Releases New Details on Provider Relief Fund Reporting Requirements
On September 19, 2020, the U.S. Department of Health and Human Services (HHS) released long-awaited details about upcoming reporting requirements for certain providers that accepted funding of one or more payments exceeding $10,000 from the Provider Relief Fund (PRF). Key aspects of HHS’ new PRF reporting guidance are summarized in today’s legal alert.
The FCC Launches COVID-19 Telehealth Program Amidst Eligibility Concerns
The Federal Communications Commission (“FCC”) has opened the COVID-19 Telehealth Program Application portal and is now accepting applications for the COVID-19 Telehealth Program (the “Telehealth Program”). Authorized by the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), the Telehealth Program will provide $200 million in funding to assist eligible health care providers deliver telehealth services to patients in their homes or other mobile locations in an effort to combat the novel Coronavirus 2019 disease (“COVID-19”). The funding is available for eligible health care providers responding to the COVID-19 pandemic by fully compensating providers for their telecommunication services, information services, and devices necessary for them to provide critical telehealth services. Notably, the Telehealth Program is not currently available to certain types of health care providers, including for-profit providers. Consequently, some providers, including local hospitals that are part of a larger for-profit health system, may find themselves ineligible for telehealth funding.
Coronavirus and Nonprofits
We understand the growing concern surrounding Coronavirus Disease 2019 (COVID-19) and the issues and uncertainties many nonprofit organizations throughout the country are facing as a result of its impact on everyday life around the world. From the most immediate issues – such as addressing workplace safety issues for employees and community stakeholders – to long term budgetary concerns – such as contingency planning for reduced funding due to the current bear market – we have provided a recap of the various issues the nonprofit executives should address.
Texas Health & Human Services Proposes Amendments to Fraud and Abuse Rules
As provided in the Texas Register on March 22, 2019, the Texas Health and Human Services Commission (“HHSC”) has proposed several amendments to Title 1 of the Texas Administrative Code, which include amendments to the rules and procedures for preventing and investigating Medicaid fraud and abuse.