Forget the Balance Billing Scare! Act Now to Receive Provider Relief Fund Payments
August 2020 Revised September 2020Practice Management General/Other
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Last revised September 2, 2020. Originally Published July 13, 2020.
The Department of Health and Human Services (HHS) is disbursing $175 billion in relief funds to hospitals and other health care providers on the front lines of the coronavirus response as part of the CARES Act. This funding supports healthcare-related expenses and/or lost revenue attributable to COVID-19. HHS is contracting with United Health Group to facilitate the delivery of these funds.
Originally, this program was available only to dentists participating in Medicaid and CHIPs. Fortunately, HHS has now opened the benefits available to all dentists, regardless of their network affiliation or payer contract.
Under the program, eligible dentists can receive reimbursement amounts of up to 2% of their annual reported patient revenue. For example, if your practice collected $2,000,000, you would be eligible for payments of up to $40,000 under the program. The payments are not loans and do not have to be repaid.
Permitted Uses of Funds
While the terms and conditions of the program contain a laundry list of expenses that the funds may not be used for (lobbying, gun control, abortions, pornography, etc.), HHS has also provided a number of permitted uses for which you will be able to easily qualify. In addition to covering lost revenue due to COVID-19, Provider Relief Funds can be used for health-related expenses incurred to prevent, prepare for, and respond to the coronavirus, including PPE and other clinical supplies and equipment used to provide healthcare services for possible or actual COVID-19 patients. Since virtually all dental practices spend in excess of 6% of collections annually on clinical supplies (before the COVID-19 increase), it will be quite easy for your practice to spend ALL Provider Relief Fund payments received on qualifying clinical supply and equipment expenses, including PPE.
HHS has concluded that the COVID-19 public health emergency has caused many healthcare providers to experience capacity constraints. As a result, patients who would ordinarily be able to receive all of their care from in-network health care providers may no longer be able to receive such care in-network. Accordingly, HHS requires that for all care for a presumptive or actual COVID-19 patient, doctors may not collect out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if their care had been provided by an in-network provider.
This provision has given many advisors heartburn, causing them to recommend that dentists not apply for these free funds. Fortunately, recent HHS guidance (FAQ added 7/22/2020) makes it clear that dentists will NOT be subject to these balance billing rules unless they are treating patients who actually have COVID-19 or have medical record documentation supporting a COVID-19 diagnosis.
To take advantage of these free funds, you must act quickly. The original deadline to apply for funding ended July 24, 2020. Fortunately, the deadline has been extended again until September 13, 2020, so apply now through the Enhanced Provider Relief Fund Payment Attestation Portal.
The McGill Advisory content is provided for informational purposes only and does not constitute legal, accounting, or other professional advice.
Copyright © 2020 John K. McGill & Company, Inc.