Covid | Stimulus
For those of you that received the stimulus check in your account today PLEASE DO NOT DISPERSE OR USE UNTIL THERE IS MORE CLARIFICATION. I have included 2 documents that need to be read. The most important one is the Relief Fund Payment Terms and Conditions from the Department of Health and Human Services.
physician-practice-financial-relief-guide
relief-fund-payment-terms-and-conditions-04092020
Look at the language in bullets 2, 3 and 6.
- “The Recipient certifies that it billed Medicare in 2019; currently provides diagnoses, testing, or care for individuals with possible or actual cases of COVID-19; is not currently terminated from participation in Medicare; is not currently excluded from participation in Medicare, Medicaid, and other Federal health care programs; and does not currently have Medicare billing privileges revoked.”
Many of my clients are Ortho, Rheum, Derm, Neuro and do not treat COVID-19. If you use this money, they may claw it back. I believe the government looked at the Tax ID numbers of the largest group practices without taking into account taxonomy and just started pushing money out!
- “The Recipient certifies that the Payment will only be used to prevent, prepare for, and respond to coronavirus, and shall reimburse the Recipient only for health care related expenses or lost revenues that are attributable to coronavirus”
So, there are strings attached to this Stimulus Money as indicated in number 2 above.
- “Not later than 10 days after the end of each calendar quarter, any Recipient that is an entity receiving more than $150,000 total in funds under the Coronavirus Aid, Relief, and Economics Security Act (P.L. 116-136), the Coronavirus Preparedness and Response Supplemental Appropriations Act (P.L. 116-123), the Families First Coronavirus Response Act (P.L. 116-127), or any other Act primarily making appropriations for the coronavirus response and related activities, shall submit to the Secretary and the Pandemic Response Accountability Committee a report. This report shall contain: the total amount of funds received from HHS under one of the foregoing enumerated Acts; the amount of funds received that were expended or obligated for reach project or activity; a detailed list of all projects or activities for which large covered funds were expended or obligated, including: the name and description of the project or activity, and the estimated number of jobs created or retained by the project or activity, where applicable; and detailed information on any level of sub-contracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees, to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 allowing aggregate reporting on awards below $50,000 or to individuals, as prescribed by the Director of the Office of Management and Budget.”
You must be able to account for this money so ensure you maintain strong records of expenditure because you will have to attest to the money spent.
There was a question on the statutory interest rate of 10.25%. “Should the repayment time frame constitute a hardship on a physician clinic receiving advance funds, the physician clinic can request an extended timeframe for repayment. Any funds not recouped or repaid after 210 days will be charged interest at a rate of 10.25% – beginning 30 days after a written payment demand letter is issued.”
This means that if you request an extension for repayment, at 240 days post Advance Payment Funding if you have not satisfied the repayment through 0 claims processing, you will have a demand issued for repayment starting on day 211 and interest will accrue at a rate of 10.25%.
I am advising my specialists to hold off on spending money at this time from the stimulus that was put in their account today until there is more clarification.
Sean M. Weiss is a Partner and serves as VP/Chief Compliance Officer for DoctorsManagement, LLC based in Knoxville, TN. DoctorsManagement, LLC services more than 20,000 clients nation-wide and has been in existence since 1956. Weiss serves as an Investigator and expert witness in Federal and State cases as well as an expert or lead in Administrative Law Judge Hearings. During his 25-year career, Weiss has engaged in more than 200 cases working with law firms and health systems across the country. Weiss serves as a third-party compliance and regulatory officer for more than a dozen health care organizations across the country of varying sizes. For more information on Sean M. Weiss or DoctorsManagement, LLC visit us online at www.doctorsmanagement.com or contact us directly at 800.635.4040. You can also follow Sean on his biweekly Blog on LinkedIn (Sean M. Weiss “The Compliance Guy”) or at www.thecomplianceguyblog.com
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