In a time when everything is changing, commitment and reliability are essential. At Draffin Tucker, our team of dedicated experts is staying informed of funding options, healthcare reimbursement changes, regulatory considerations, and all other developments related to COVID-19. We are committed to supporting businesses in the communities we serve by providing timely advice, staffing assistance, and information through education platforms, email alerts, one-on-one conversations, and our online COVID-19 Resource Center.

If you have specific questions on how these resources apply to your organization, please contact a member of our team, visit our COVID-19 Impact Assessment page or send an email to Coronavirus@draffin-tucker.com.

COVID-19 Impact Assessment Services
PPP Loan Forgiveness Assistance
Single Audits of Provider Relief Funds

Visit the following organization’s COVID-19 webpage for more resources and information by clicking on their name.

Centers for Medicare and Medicaid Services (CMS)

  • 2% Sequestration Suspension – As part of the CARES Act, all healthcare providers receiving Medicare payments will see the 2% sequestration reduction suspended until December 31, 2021. Find that information here.
  • 20% Payment Add-On – As part of the CARES Act, providers being reimbursed under the Medicare hospital Inpatient Prospective Payment System (IPPS) will experience a 20% increase in reimbursement for Medicare fee-for-service patients with a COVID-19 diagnosis code.  Find that information here.
  • Advance/Accelerated Payments – Hospitals were eligible to receive advance or accelerated payments from the Medicare Program.CMS is not accepting any new applications for the Advance or Accelerated Payment Programs. A fact sheet is located here.
    • Repayment and Reconciliation A provider or supplier may repay their accelerated or advance payment at any time by contacting their Medicare Administrative Contractor (MAC). If such payment is repaid in full, the repayment terms below will not apply.
      • If any balance remains as to an accelerated or advance payment, pursuant to the Continuing Appropriations Act, 2021 and Other Extensions Act, repayment terms are as follows:
            • Repayment does not begin for one year starting from the date the accelerated or advance payment was issued.
            • Beginning at one year from the date the payment was issued and continuing for eleven (11) months, Medicare payments owed to providers and suppliers will be recouped at a rate of 25%.
            • After the eleven (11) months end, Medicare payments owed to providers and suppliers will be recouped at a rate of 50% for another six (6) months.
            • After the six (6) months end, a letter for any remaining balance of the accelerated or advance payment(s) will be issued.

        Periodic Interim Payments (PIP) Providers: The timeline for repayments is the same for PIP and non-PIP providers. The recoupment process from bi-weekly PIP payments will begin after twelve months from the date the provider received their accelerated payment. Repayment will comport with the timeline described immediately above. Accelerated payments will not be included in the reconciliation and settlement of final cost reports.

        Letter Requiring Reimbursement: If a letter requiring reimbursement is issued, providers and suppliers will have 30 days from the date of the letter to repay the balance in full. If payment is not received within 30 days, interest will accrue at the rate of 4% from the date the letter was issued, and will be assessed for each full 30-day period that the balance remains unpaid. Information related to Extended Repayment Schedules will be included in these letters.

  • Medicare fee-for-service billing FAQs related to COVID-19 can be found here.

US Department of Health and Human Services (HHS)  – CARES Act Provider Relief Fund of $175 billion. Terms and conditions for all distributions can be found here.  Distributions to date are:

  • $92.5 billion in general distribution (Phases 1-3)
  • $20.75 billion in high impact relief funds
  • $11.09 billion in rural provider relief funds
  • $13.07 billion in safety net hospital provider relief funds
  • Uninsured relief funds (distributed on a per claim basis)
  • $10 billion for skilled nursing facilities
  • $520 million for Tribal Hospitals, Clinics, and Urban Health Centers
  • $1.06 billion for children’s hospitals

Reporting

HHS has released updated post-payment reporting requirements for the Provider Relief Funds (PRF) here.  Providers who received PRF payments exceeding $10,000 must first register in the Provider Relief Fund Reporting Portal which can be found here.  Prior to registration, providers should review the post-payment reporting requirements and the portal FAQs found here to determine their appropriate Reporting Entity and gather all necessary information.

Providers are encouraged to register in the PRF Reporting Portal in advance of the relevant Reporting Time Period dates. The registration process will take approximately 20 minutes to complete and must be completed in one session. The entire registration form must be completed for it to be saved. Once providers register for the portal they may report how they utilized the PRF for the period ending June 30, 2021.  Below is a chart of reporting deadlines:

  • The period of availability of funds is based on the date the payment is received (rather than requiring all payments be used by June 30, 2021, regardless of when they were received).
  • Recipients are required to report for each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments).
  • The period of availability of funds and reporting time period applies to all past and future PRF payments.
  • Recipients will have a 90-day period to complete reporting.
  • The reporting requirements are now applicable to recipients of the Skilled Nursing Facility and Nursing Home Infection Control Distribution in addition to General and other Targeted Distributions.
  • Provider Relief Fund recipients must only use payments for eligible expenses, including services rendered, and lost revenues attributable to coronavirus before the deadline that corresponds to the relevant Payment Received Period. These deadlines are based on the date the payments are received, as indicated in the table below – all funds will be available for at least 12 months and a maximum of 18 months. The payment is considered received on the deposit date for automated clearing house (ACH) payments or the check cashed date.  Providers must follow their basis of accounting (e.g., cash, accrual, or modified accrual) to determine expenses.

These reporting requirements will not apply to recipients of funds from the Rural Health Clinic COVID-19 Testing Program. If the only payment you received was from the Rural Health Clinic COVID-19 Testing Program, you should not register in the PRF Reporting Portal. For information about the Rural Health Clinic COVID-19 Testing Program reporting requirements contact RHCCOVID-19Testing@hrsa.gov or visit the Rural Health Clinic Testing website. The Rural Health Clinic COVID-19 Reporting Portal is available at www.rhccovidreporting.com.

  • Reimbursement from the HRSA Uninsured Program portal has opened. Additional information can be found here.

Originally the first reporting for funds expended through December 31, 2020 was due by February 15, 2021, but HHS has not established a new deadline yet.

Single Audit Auditee Summary
New to Single Audit?  Check out this resource – Single Audit Auditee Summary – to learn more about the requirements and how to prepare for a Single Audit.

OMB Compliance Supplement Addendum for Provider Relief Funds and other programs can be found here. This addendum supplements the 2020 OMB 2 CFR 200 Part 200, Appendix XI Compliance Supplement to provide additional guidance for programs with expenditures of COVID-19 awards that the auditor determines are major programs in audits performed under 2 CFR 200 Subpart F.

Rural Health Clinic (RHC) COVID-19 Testing and Mitigation Program Funding Program (RHCCTM)

The RHCCTM program received $460 million through the American Rescue Plan Act of 2021, and, in June 2021, HRSA provided $424.7 million to over 4,200 RHCs that were immediately eligible. To be eligible, the entity had to be considered a RHC by CMS before April 2021.  The funds must be utilized for COVID-19 testing activities and mitigation of the virus.

The reporting portal for these funds can be found here.

The American Rescue Plan (ARPA)
$1.9 trillion package intended to combat the COVID-19 pandemic includes multiple facets ranging from public health, economic impacts, and direct financial assistance broken out by:

  • State & Local Fiscal Recovery Funds $362 Billion
  • Direct Financial Assistance $656.18 Billion
  • Assistance to Individuals & Families $56.27 Billion
  • Education & Childcare $211.57 Billion
  • Health $86.24 Billion
  • Transportation $40.16 Billion
  • Other Programs $61.32 Billion

Health Resources and Services Administration (HRSA) – COVID-19 impact on the 340b program

Federal Communications Commission (FCC) – COVID-19 Telehealth Program

  • As of June 25, 2020, the FCC stopped accepting new applications for this program.
  • The Consolidated Appropriations Act (CAA) provided an additional $249.95 million to fund a second round of the COVID-19 Telehealth Program issued on January 6, 2021. The application filing window closed on May 6, 2021.  Information on this program and the filing portal can be found here.

Organizations

Medicare Administrative Contractors (MACs)

Visit the following organization’s COVID-19 webpage for more resources and information by clicking on their name.

Visit the following organization’s COVID-19 webpage for more resources and information by clicking on their name.

Social Security Payroll Tax Deferral

Under the Presidential Memorandum issued on August 8, 2020, the employee’s share of Social Security taxes may be deferred for those employees earning less than $4,000 on a biweekly basis (or the prorated amount for those on other payroll schedules) for payroll occurring between September 1, 2020 through December 31, 2020. These amounts are to be repaid in 2021. On August 12, 2020, Treasury Secretary Steven Mnuchin stated that the program was not mandatory, allowing employers to choose whether they would participate in the deferral program.

On August 28, 2020, the IRS issued Notice 2020-65, which was the first guidance provided for the deferral of employee Social Security taxes.

Under the Notice, the Treasury outlined that the repayment of the deferral would occur through additional withholding from the employee’s payroll during the period January 1, 2021 through April 30, 2021. The Notice also stated that employers should make alternate arrangements with any employee from whom the additional withholding could not be collected. It was also clarified that the $4,000 limit was determined on a payroll-by-payroll basis, and that prior payrolls should not be considered.

While the Memorandum suggested Treasury “explore avenues, including legislation, to eliminate the obligation to pay the taxes deferred…”, no such steps toward forgiveness were outlined in the Notice. Therefore, at this time, it is prudent for employers and employees to plan for the deferred amounts to be repaid in 2021.

Please check back for additional updates. The information above represents a general overview. You should consult your payroll and/or tax advisor prior to making decisions related to this program.

Visit the following organization’s COVID-19 webpage for more resources and information by clicking on their name.