CARES Act Provider Relief Fund - Application Guidance Document

Hey y’all, this is V.1.1 CARES Application - Medicaid.pdf (1.7 MB) our guidance document on how to complete an application for CARES Act Provider Relief Funds for Medicaid-accepting practices who didn’t get any Medicare money.

Thanks to all the SOAPMites for their careful review: Bob Stephens, Sue Kressly, @cdiasio, and @chip. A special thanks to Stephanie Glier of the AAP’s Federal Affairs division. She provided thoughtful review and analysis, and most importantly is clarifying some of the vaguer language directly with HHS.

I will be hitting some of the highlights of the document tomorrow on Episode #12 of the Chip and Paulie Show . We anticipate that this document will contain most of the common questions people are asking. We’re posting it now so that you can take some time to review it before the webinar.

While this document has been checked for accuracy and represents our best guidance as of 6/17/20, rules can change. I will do my utmost to keep it updated as new information comes out, and I’ll repost new versions here. ALL THE ERRORS ARE MINE, MINE, MINE.

As a courtesy, we have included OP- and PCC-specific guidance on reporting from those systems. I would be delighted to add similar sections on guidance for eCW, Athena, etc.; please send them to me at sberman@plateaupediatrics.com. Please keep instructions (including screenshots) under a page in length; alternatively we can outlink to your external document with instructions.

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I wish, as moderator here, I could mark this with 5 <3’s but we’ll settle for making sure this gets highlighted at the top of the forum.

I don’t know if all the pediatricians out there know HOW LUCKY THEY ARE to have @SKB on their side.

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Thank you so much!!! @SKB, I don’t know if I have told you this lately, but you are amazing!!!

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@SKB is my hero!!! :heart_eyes::heart_eyes::heart_eyes:

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@SKB Wow! Just speechless at how helpful and incredibly thorough this document is.

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Hope it doesn’t get old hearing it… this is awesome! Thanks for sharing.

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Thank you so much for sharing this with all of us!

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This is an incredible document, and amazing me how one can misinterpret the English language! Glad I waited for your answers!

For Field 13 I was planning on just taking 2019s bank deposits for March and April and subtracting 2020s bank deposits, as that is a very easy number for me to find, would that not be accurate enough?

Unfortunately, I now have more questions that hopefully you can answer. In VT, what are the CHIP programs called for Field 19?

I’m sure I’ll probably have more questions, but thanks again for always being a place to come!
A

That method is a great approximation for many practices who don’t have other variables in play that would affect the delta between their 2019 and 2020 businesses.

Other practices might need to do some adjustments. For example, our practice would have lost some 2020 revenue (compared to 2019) even if COVID hadn’t happened, because of staff changes: one of our NPs left in January 2020 and one of our docs went on maternity leave in March and April. While we made some adjustments to our schedule, we knew our numbers would be down already. It’s not really fair to blame all that on COVID.

VT CHIP is called Dr Dynasaur. You can see all the state Medicaid and CHIP program titles here:

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My practice is doing okay right now. I have already used my PPP money. I have just been approved for another SBA loan. Should I still proceed with the Cares Act provider relief fund and the additional SBA loan?

I completed and submitted our CARES application and wondered about how to change the loss number from an (+) to a (-) number as recommended on page 25 of the guidance document? Thanks!

Unfortunately HHS did not provide or publish a mechanism for altering an application after submission. I suggest you contact the attestation portal helpline (see p. 18).

It depends on what you mean by “right now.” See a similar thread here:

You can apply for the money, then hold on it until COVID is no longer an emergency. You can always return it if you don’t need it or can’t use it, without any interest or penalty. But (unless HHS ends up granting additional distributions), this is the only chance you’ll get at relief from HHS.

Hi Suzzane. I got my PPP and just yesterday completed my EIDL application without a problem, but now in CARES Act I may have some difficulty. In Puerto Rico we receive Medicaid as a block grant to our Government’s Medicaid office, which transfers it to one of it’s agencies (ASES for it’s Spanish acronym), who them contracts with 5 insurances companies to administer the funds. These insurance companies then contract Independent Physician Association (IPAs) who then we have to contract with to provide the services with via capitation or staff model. Therefore, technically while we have to abide by all the Medicaid rules, our contract is is with these IPA’s not Medicaid. My question is: 1-Would we have problems with the Attestation or an Audit. 2- Why no Chimps!

Thank you for your response! Happy Friday.

When you say return it, are you referring to the SBA loan or the Cares Act Relief Fund?

I presume when you see Medicaid patients, you don’t file a claim; you’re simply paid according to contract by the IPA, right?

This raises the question: Is your practice TIN, or the IPA TIN, going to apply and receive the funds? My assumption is, if you are a freestanding practice and the IPA has no ownership/governance of your practice, then it’s proper for you to apply. If, on the other hand, Puerto Rico Medicaid turned in TIN numbers of the IPAs, then they expect the IPAs to apply on your behalf, then redistribute the money downstream to individual practices.

If you start the TIN Validation process and you’re immediately approved, then I would presume you were on PR’s prelist of TINs, they expected your practice to apply, and you have your answer. If you start the TIN Validation process and you are pended/delayed, then that forbodes a problem. If this is the case, please let me know offline and we can contact HHS and/or PR Medicaid to see what their expectation is.

The provider relief fund money.

Okay, what I’m thinking, and please correct me if I’m wrong. Is to apply for the Cares Act relief fund. Accept the additional SBA loan money and put that money in a separate account, not touch it for now, since my office is doing ‘okay’ right now, but in the event that COVID-19 or something else happens, then I will already have access to that money. If I end up not needing the SBA loan in about 1 year, I plan to send it back.
For the Cares Act relief fund, I haven’t thought much about it, but I plan to use that for my current expenses.
Thoughts?

That seems like sound reasoning!

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