Medicare relief payments
After sending $30 billion in direct payments starting April 10 based on Medicare fee-for-service payments from 2019, CMS is distributing another $20 billion starting April 24. The combination of the two payments, which distribute $50 billion allocated by the CARES Act for health care relief, will reflect each practice’s proportion of overall net patient revenue for 2018. These funds will be directly deposited in the accounts normally associated with Medicare payments. Each Tax Identification Number (TIN) linked to Medicare will receive a payment. Please note, these are payments, not loans, and will not need to be repaid.
Anyone who receives either of these payments must complete an attestation form accepting the terms and conditions (PDF). Please note, HHS is making these payments public. See below for more details on how the payments work.
Who will receive the second payment?
Those who would typically submit revenue data to CMS through cost reporting will receive a payment automatically. Those without adequate cost report data on file, including most dermatology practices, will need to submit their revenue information to determine the amount of their payment. Dermatology practices should submit an application if they did not receive at least 2% of their net patient revenue from 2018 (or most recent complete tax year) in the first payment. If your initial General Distribution payment, which you should have received in April, was at least 2% of your 2018 patient revenue (including all payers), you won’t receive the second distribution. If you do qualify for a second payment, you can estimate it with the following equation: (Individual Provider Revenues/$2.5 Trillion) X $50 Billion = Expected Combined General Distribution. You may use “Gross Receipts or Sales” or “Program Service Revenue” for your revenue calculation. If your total relief payment exceeds 2% of your 2018 net patient revenue and you feel you were overpaid, you should reject the entire General Distribution payment and submit appropriate revenue documents through the portal. HHS has noted they do not intend to recoup funds as long as the physician’s lost revenue and increased expenses exceed the amount of relief funding a physician has received. HHS does reserve the right to audit recipients in the future to ensure that this requirement is met and collect any Relief Fund amounts that were made in error or exceed lost revenue or increased expenses due to COVID-19. Failure to comply with the Terms and Conditions may be grounds for recoupment.
Practices that received a first payment and wish to receive a second payment need to visit the HHS portal and apply. Consider working with your accountant to complete the following:
Their TIN and the TINs of any subsidiary organizations that do not file separate tax forms
The amount of Medicare payments received
Lost March 2020 revenues
Estimated lost April 2020 revenues
Payment transaction numbers or check numbers from their first relief fund payment
A copy of their most recently filed tax forms, according to the chart below.
|Federal tax classification:||Provide:||From:||On IRS form:||And upload:|
Sole Proprietor/Disregarded Entity (LLC)
Gross receipts or sales
|1040, Schedule C||1040, Schedule C|
|C Corporation||Gross receipts or sales||Box 1a||1120||1120|
|S Corporation||Gross receipts or sales||Box 1a||1120-S||1120-S|
|Partnership||Gross receipts or sales||Box 1a||1065||1065|
|Trust||Gross receipts or sales||Box 1||1040, Schedule C||1041 and Schedule C|
|Tax-Exempt Organization||Program service revenue||Box 9||990||990|
Practices would also have to accept terms and conditions. More instructions are available here; HHS has also released a new FAQ about the general distribution portal that contains helpful information for accessing the portal and applying for a payment. You can also access the Cares Act Provider Relief Fund Application Guide for help completing the portal.
Also, new changes to the HHS website include:
HHS plans to process portal entries every Wednesday.
The terms of this round of grants include agreement that the grant amount could be shared publicly. It is currently unclear if this applies to first-round grants.
The portal also notes that second round application data could be shared with auditors. It is currently unclear if this applies to first-round grants as well.
Guidance on these payments remains fluid as HHS has been updating and adjusting its rules for disbursement. The AADA is monitoring changes and will update this page with new information as we have it.
Who received the first payment?
Any practice that accepts Medicare fee-for-service payment (not Medicare Advantage) should have received a payment directly to the practice’s TIN associated with Medicare. If you are an employed dermatologist, you should not expect to receive an individual payment directly. Your employer organization will receive the payment to their central billing office and determine how to disperse the funds. Solo dermatologists and dermatologist-owners of group practices should expect to see the funds in each TIN linked to Medicare.
How will I receive the payments?
The Department of Health and Human Services (HHS) has partnered with UnitedHealth Group to disperse the payments. The practice will be paid via Automated Clearing House account information on file with UnitedHealth Group or CMS. The automatic payment will come via Optum Bank with “HHSPAYMENT” as the payment description. If you receive paper checks from CMS, you will receive a paper check in the mail within the next few weeks.
What if I did not receive an automatic payment?
If you have not received a payment, you can go to the Provider Relief portal and follow the instructions on how to claim the second general distribution. A Medicare billing TIN is required. For more information, contact UHG’s Provider Relations at 866-569-3522.
What are the terms and conditions for accepting payment?
If you ceased practice operations as a result of the COVID-19 pandemic, you are eligible to use these funds as long as you care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19. The payments are intended to be used to prevent, prepare for, and respond to coronavirus. The funds are to reimburse for health care expenses or lost revenues attributable to coronavirus. If a physician does not have lost revenues or increased expenses due to COVIID-19 equal to the amount funded, then the funds must be returned. As a condition to receiving these funds, practices must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider and abstain from “balance billing” any patient for COVID-related treatment.
Providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The attestation will be done via web portal. HHS’s payment of this initial tranche of funds is conditioned on acceptance of the Terms and Conditions (PDF download). The Terms and Conditions require the submission of revenue information through the provider portal for later verification. If a provider receives payment and does not wish to comply with these Terms and Conditions, the provider must do the following: reject the funds and then submit the required information to the application for consideration.
The following are the steps that must be taken and the related deadlines:
Submit if you would like to accept or reject the funds before June 3, 2020.
If you missed this deadline, you will still be considered for future Provider Relief Fund Payments. Information on future distributions will be shared when publicly available.
If accepting the funds (and related terms and conditions), sign the attestation via the web portal and submit revenue information via the provider portal by July 9, 2020 .
If refusing the funds (and related terms and conditions), reject the funds and submit information via the application portal for consideration.
Note, if you accept the funds but would now like to reject them and retract your attestation, you may do so by calling the provider support line at (866) 569-3522; for TTY dial 711. Also note, HHS is posting a public list of providers and their payments once they attest to receiving the payment and agree to the Terms and Conditions.
For further information, please see the HHS Provider Relief site.
Medicare advance payments
Note: CMS suspended this program on April 26. Pending applications will be reevaluated given other relief payments CMS has made. Read the CMS announcement.
As part of the CARES Act, CMS expanded its accelerated and advance payment program. If you obtained a loan through this program, you will be required to start paying back the loan 120 days after receiving the loan and will need to pay back the full amount of the loan 210 days after receiving the loan. If you do not pay back the full amount by the time CMS requests full payment (within 31 days of a request) you will be charged accruing interest at a variable Treasury rate (9.625% as of April 21). Read more from CMS. The AMA has developed a list of FAQs on the program.
Additional COVID-19 business management resources
All content solely developed by the American Academy of Dermatology