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HHS Provider Relief Fund Reporting Requirements Change Terms for Recovering Lost Revenue

The Department of Health and Human Services (HHS) has issued guidance that contradicts the department’s June FAQ about calculating lost revenue from Covid-19 that may be recovered through the Coronavirus Aid, Relief, and Economic Security Act’s (CARES) Provider Relief Fund (PRF).

In the June FAQ, HHS said providers could “use any reasonable method of estimating the revenue during March and April 2020 compared to the same period had Covid-19 not appeared.” This latest guidance defines lost revenue that may be recovered as being limited to “a negative change in year-over-year net patient care operating income.” The guidance further specifies that providers generally will only be able to apply their PRF payments to lost revenue up to a facility’s net patient operating income for 2019.

As HHS announced previously, providers who have received more than $10,000 from the PRF are required to submit a report by Feb.15, 2021, on the use of those funds through Dec. 31, 2020, and, if necessary, a second and final report by July 31, 2021.

The PRF funding provided through the CARES Act and subsequent legislation was intended to reimburse eligible providers for healthcare-related expenses and lost revenues attributable to Covid-19. HHS had included a general commitment to reporting on the use of the PRF funds in the terms and conditions that PRF fund recipients agreed to for the funding. Previously HHS said it would issue detailed reporting instructions by Aug. 17, 2020 and the reporting system would be available Oct. 1. The reporting system is not yet available.

Please contact your U.S. senators and representatives today and ask them to urge the White House and HHS to reinstate the Covid-19 PRF reporting requirements that HHS outlined in June. Providers must be able to use these funds to recover any revenue lost due to Covid-19, rather than struggling to once again change course to respond to shifting guidance from HHS.

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CMS Makes Covid-19 Data Collection a Requirement in Conditions of Participation

The Centers for Medicare & Medicaid Services (CMS) is requiring Covid-19 data collection and reporting as a condition of participation (CoP) for hospitals participating in the Medicare and Medicaid programs, including psychiatric facilities.

CMS added the requirement with other provisions in an interim final rule and said it will accept comments for 60 days. The rule noted the requirement will become effective when it is published in the Federal Register, although it did not list a specific date.

Under the new requirement, hospitals will need to report daily data, including—but not limited to—the number of confirmed or suspected Covid-19 positive patients, intensive care unit beds occupied, and the availability of supplies and equipment, such as ventilators and personal protective equipment.

CMS warned in the rule that if a hospital fails to comply with this new CoP, it could face possible termination from the federal healthcare programs.

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HHS Extends Phase 2 General Distribution Deadline to Sept. 13

The Department of Health and Human Services (HHS) has extended the deadline to apply for Phase 2 General Distribution Funding for Medicaid, Medicaid managed care, Children’s Health Insurance Program, dental providers, and certain Medicare providers until Sunday, Sept. 13.

This funding is through the Provider Relief Fund, which the federal government established in this year’s Coronavirus Aid, Relief, and Economic Security Act (CARES) and Paycheck Protection Program and Health Care Enhancement Act. These payments do not need to be repaid to the government if providers comply with terms and conditions.

HHS has extended this Phase 2 General Distribution Funding deadline before, with the latest deadline scheduled for this Friday, Aug. 28. Providers now have a few extra weeks to apply.

Click here to read HHS’ six steps to applying for the Phase 2 General Distribution.

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2020 NABH Annual Survey Starts Aug. 28!

Data Collection for the 2020 NABH Annual Survey Starts this Week!
 
I am pleased to announce that data collection for the 2020 NABH Annual Survey will begin on Friday, Aug. 28. Your participation in this survey will help us continue to provide an accurate, up-to-the-minute picture of the U.S. behavioral healthcare industry. Please note that we have added a few new questions related to substance use. This will help us better measure our membership’s activities.

Look for a Message from Consulting Firm Dobson DaVanzo & Associates, LLC

Our contractor, Dobson DaVanzo & Associates, will conduct the NABH Annual Survey again this year. Dobson DaVanzo & Associates brings extensive data-analysis experience and data-security expertise to this project. The firm has analyzed data for the last several NABH Annual Surveys.

Dobson DaVanzo will send personalized links to the survey instrument via e-mail directly to the CEOs of all NABH-member hospitals and residential treatment centers. If you receive a request to participate in the survey, please respond as soon as possible.

Submit Your Data Online

The 2020 online entry form will provide a personalized, secure e-mail link for each facility. You will be able to enter, save, and review data— and review that data internally with others in your organization who have completed the survey—until you click “Done” on the survey’s last page. You may not make changes after you have submitted your data. You will receive complete instructions with the survey instrument.

Your Participation in Essential!

The survey data are used in dozens of ways to help protect mental health and addiction treatment benefits; ensure fair and adequate payments; improve patient care; and communicate trends to the media, payers, benefit consultants, and the public.

Within your organization, you can also use the NABH aggregate data you will receive to measure how your facility compares with national trends. Because the survey collects the most current information about the field, it can provide a valuable perspective for administrative and clinical operations. The NABH Annual Survey Report is an invaluable strategic planning tool as well as a reference document every behavioral healthcare organization should have.

If you have any questions or suggestions about this survey, please feel free to contact me directly at Shawn@nabh.org or contact Kirsten Beronio at Kirsten@nabh.org.

Thank you for your time. We appreciate your help!

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HHS to Host Provider Relief Fund Webinar on Thursday, Aug. 13

The Health and Human Services Department (HHS) will host an informational webinar for healthcare providers about applying to the CARES Act Provider Relief Fund this Thursday, Aug. 13 at 3 p.m. ET. Please click here to register.

HHS announced on July 31 that certain Medicare-participating providers would have another opportunity to receive additional Provider Relief Fund payments. These are the providers who missed an early June deadline to apply for additional funding equal to 2% of their total patient care revenue from the $20 billion portion of the $50 billion phase 1 General Distribution, including many Medicaid, Children’s Health Insurance Program (CHIP), and dental providers with low Medicare revenues. These eligible providers may now submit their application for possible funding by Friday, Aug. 28.

HHS has also extended the deadline to Aug. 28 for providers who participate in Medicaid and CHIP to apply for up to 2% of their total patient care revenue from a separate funding distribution for Medicaid providers.  To be eligible for this funding, providers must not have received any funding from the Medicare focused distribution of funding from the Provider Relief Fund.

Providers can access the same portal to apply for both Medicare-based and Medicaid-based funding.

HHS has hosted a series of webinars to address questions from providers throughout the application process, and Thursday’s webinar is the next provider and provider organization webinar in this series.

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