HHS Provider Relief Fund May Have $25 Billion less than Expected

Eligible healthcare facilities have begun to recover lost revenue from COVID care for uninsured patients through the U.S. Department of Health and Human Services (HHS) Provider Relief Fund. However, with benefits subject to funding limitations, and the recently proposed removal of an additional $25 billion from the Provider Relief Fund, organizations without efficient processes in place may find themselves at a disadvantage. Implementing swift, proactive remedies may help ensure claims reimbursement while available.

The Provider Relief Fund, which includes funds received from the Public Health and Social Services Emergency Fund, as appropriated in the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136), provides relief to hospitals and other healthcare entities in the form of reimbursement for treating uninsured individuals with a COVID-19 diagnosis. This relief fund is part of the $100 billion of funding, distributed under the CARES Act, to support healthcare-related expenses or lost revenue attributable to the COVID-19 pandemic, and to ensure needed testing and treatment for the uninsured.

Healthcare entities that have conducted COVID-19 testing of uninsured individuals or provided treatment to uninsured individuals with a COVID-19 diagnosis on or after Feb. 4, 2020 can request claims reimbursement through the program electronically, and will be reimbursed in most cases at typical Medicare rates.

For claims reimbursement, a COVID-19 Uninsured Program Portal was launched by HHS on April 27, 2020, to allow healthcare providers to receive reimbursement for those services provided electronically. Claims can be submitted for professional and facility services through the portal.

HHS is processing claims on a rolling basis, and reimbursement for such services will be distributed on a first-come, first-served basis.

This apparent excess of relief benefits should not serve as an invitation to procrastinate on claim submittals, as reimbursement is subject to available funding. With this, healthcare facilities have been prompted to move quickly and efficiently on COVID-19 claim submittals for the uninsured.

Bearing in mind that the approval process can take several days, providers that have completed the registration requirements and have a timely claim submittal process are in a more favorable position to receive reimbursement while funding is still available.

At the same time, the U.S. Senate is now narrowing COVID-19 relief asks, proposing to remove provider funding with a slimmer new COVID-19 relief bill. The new bill includes benefits requested by healthcare providers, such as liability protection, but does not set aside the additional $100 billion in grants providers had asked for, according to a draft text of the proposal. The initial offering would have added $25 billion to the $175 billion Provider Relief Fund that lawmakers created to help healthcare providers offset lost revenue and coronavirus-related expenses, but that funding is now excluded from the narrower bill.

Hospitals have also asked Congress to relax the repayment terms and interest rates on Medicare loans many providers took out at the beginning of the COVID-19 crisis. Still, the scaled-back Senate GOP proposal does not include that provision either. An extension of telehealth flexibilities through at least 2021 was also left out of the smaller bill.

At the end of September, funding for the federal government expires, with expectations of a “must-pass vehicle” for further legislation ─ serving as a call to action for healthcare facilities to accelerate claim submittals.

The rapid implementation of the many COVID-19 code sets and revisions that prompted new guidelines and clarifications has created a disruption to the workflow for many hospitals engaged in COVID coding and billing. The result of this has been an increase in inaccuracies on reimbursement and a spike in denials.

With a discernible cap on the HHS Provider Relief Fund sums available for healthcare facilities, combined with the probability of fewer benefits for funding than initially anticipated, it is essential for hospitals to ensure timely and clean claim submissions.

Establishing a comprehensive COVID compliance plan with an internal audit function is well-advised to protect against denials efficiently.

Incorporate edit functions for certain considerations, such as validating COVID-19, ensuring that ICD-10-CM code assignments are accurate, and implementing potential billing edits around the testing and treatment of the uninsured.

Claim procedures must be assessed and verified, requiring effective communication of updated charging and billing guidelines across departments. This will help ensure claim accuracy for charging and billing for labs, coding, modifiers, and condition codes related to COVID-19.

Take into account all the components required to identify issues, in order to verify accuracy before billing. A high rate of clean claims will be the most significant factor in ensuring accurate and timely payment and safeguarding your organization’s reimbursement on COVID-19 testing and treatment of the uninsured before provider funds are depleted.

The Centers for Disease Control and Prevention (CDC) has made available a list of providers that have attested to receiving one or more payments from the relief fund, and those receiving high-impact payments. This list of providers can be accessed on the CDC website:

https://data.cdc.gov/Administrative/Claims-Reimbursement-to-Health-Care-Providers-and-/rksx-33p3/data

Programming Note: Listen to Susan Gatehouse report this story live today during Talk Ten Tuesdays.