Late Tuesday, HHS updated its Provider Relief Fund FAQ with five pages of key questions and answers on how the targeted Medicaid/CHIP distribution would work, including: further details on which providers are eligible, documents they will need for the application, and how the payments are to be calculated. Members are encouraged to review these Medicaid Distribution FAQs that begin on page. 31. The newly-updated HHS PRF website also now includes instructions about how to apply for the Medicaid distribution. These should be reviewed carefully prior to applying. Providers can only apply once and the instructions outline the information providers will need to collect in advance in order to be prepared to submit their application through the Enhanced Provider Relief Fund Payment Portal

To be eligible to apply, one must be a Medicaid or CHIP provider who meets ALL of the following conditions:

  • Has directly billed Medicaid between January 1, 2018 and December 31, 2019  or own a subsidiary that has billed Medicaid during this time.
  • Filed a federal income tax return or is exempt from doing so;
  • Provided patient care after 1/31/2020;
  • Did not permanently cease providing patient care directly, or indirectly through included subsidiaries; AND
  • Did not receive a payment from the $50 billion General Distribution of the Provider Relief Fund (these were payments were disbursed in April to Tax Identification Numbers (TINs) who had billed Medicare).

This issue of having received a General Distribution can be a bit complicated and confusing for some organizations. The key to determining if you meet this final eligibility criteria is based on understanding Tax Identification Numbers (TINs) and which services in your organization are covered by which TIN. HHS clarifies, in its FAQs , providers may still be eligible for a Medicaid distribution, "if their Filing TIN or one of the Billing TINs was not eligible for the $50 billion General Distribution and is a Medicaid provider on the state-provided list of eligible Medicaid and CHIP providers."  If, for example, an assisted living provider who bills Medicaid operates under the same TIN as its Skilled Nursing Facility, who received a General Distribution payment, this provider would not be eligible to apply. LeadingAge encourages members to review the HHS FAQs section on Medicaid Targeted Distribution (beginnig on page 31) and the application instructions carefully to determine their own eligibility to apply. 

For those who are deemed eligible and HHS can verify they are on the state-provided list of eligible MEdicaid/CHIP providers (or can be verified through additional information), HHS has indicated that payments will be based upon "2% of (gross revenues * percent of gross revenues from patient care) for CY 2017, 2018 or 2019, as selected by the applicant."  Once applications are received and the information validated, payments will be disbursed on a rolling basis. HHS did not provide a timeframe by which providers could expect to receive payments except to say, "HHS is working to process all providers' submissions as quickly as possible."

LeadingAge has observed that there are some inconsistencies in the information provided in the FAQs, the application instructions and the original HHS announcement that we are seeking to get resolved with HHS in the coming days. One of those discrepancies is the deadline to apply. The HHS FAQs state July 3 but the application instructions note a July 20 deadline for submitting applications. LeadingAge will provide more information as it resolves these issues with HHS. In addition, members will have the opportunity to pose their own questions to Senior Advisor to the HHS Secretary, Nick Uehlecke, on Friday, June 12 by joining our daily Member Update call.