Update: CARES Act Funding for Medicaid Providers
Table of Contents
- [Music] hello my name is natalie westfall vice...
- That was a significantly large group of providers it included hospitals that...
- The medicare providers and get funds into their hands and that's what they...
- Distribution and so if you went to those it would...
- Attest to um and then to again uh focus in on the the concept of who's...
- Coronavirus so if at the end of the day um you receive more funds than your...
00:02
[Music]
hello
my name is natalie westfall vice
president of henry shine financial
services
since the onset of the covid19 pandemic
henry shine has been a trusted source of
valuable information for our customers
we've provided valuable education and
real-time updates on the karzak stimulus
package
the u.s department of health and human
services has released several tranches
of funding to various categories of
providers
00:36
and on june 9 it was announced that 15
billion of the provider relief fund
would be allocated to eligible medicaid
and children's health insurance program
providers
joining us today is king and spaulding's
mark polston
and allison casir who will provide us
with an in-depth overview of the
provider relief fund created in the
cares act
thank you so much we appreciate the time
and the opportunity to be here
we wanted to level set and put this
slide
up just to outline the congressional
01:07
response to the kovid 19 public health
emergency
just so that we could see all of the
billions in one place
you will see how the funding evolved
from response and vaccine development
to supportive provisions for individuals
to stimulus package and its plus
up with some of the provisions in these
bills expiring at the end of
july there may yet be a coveted package
covered four package in the next several
weeks
the house packs their health and
01:37
economic recovery omnibus
emergency solutions act or heroes act in
mid-may
the senate is not likely to take up that
bill but senate leadership
has expressed the desire to take a look
at the funding that has gone
out the door see if it's working and
also include expanded liability
protections
note that the program we are discussing
here
does not expire at the end of july it is
something where congress put the funding
in and the program as mark will describe
02:09
in detail
has evolved into various tranches
various requirements
and with that let me turn it over to
mark to describe the provider relief
fund created in the cares act originally
thank you very much allison as allison
said
the cares act funded to the tune
initially of a hundred million dollars
and then an additional 75 billion
i'm sorry i should have said 100 billion
dollars initially
02:42
and then an additional 75 billion
dollars were appropriated by congress to
go into
uh what has been uh commonly called the
cares act provider relief fund
now the purpose of the cares act
provider relief fund was
to provide stimulus through grants or
other types of mechanisms
to health care providers who were
feeling the effects
of the public health and public health
emergency was caused by the coronavirus
pandemic
03:13
the statute itself in the language
that is that appropriates the 175
billion dollars
states that the purpose of the program
is to provide these funds
to prevent to prepare for to respond to
the
coronavirus and to give eligible
health care providers we're going to
talk about what that means in a second
to give eligible health care providers
the funds necessary
to cover the expenses or lost revenues
that are attributable to the coronavirus
03:45
now one limitation that's built into the
statute and we'll hear about this
throughout the program
is that these funds must only be used
to reimburse for expenses or losses that
are used
excuse me that have been that have been
incurred
due to the coronavirus but if there's
another source of funding out there
whether it be the cares act
itself or some other federal source of
funding
which can be used to cover those
expenses or losses
04:17
karex funding cannot be used to cover
those same expenses or losses
in other words the cares act does not
allow you to double dip
from federal programs let's talk a
little bit about the definition of
eligible health care providers
because literally when you read the
language of the statute you realize that
just about anybody who provides health
care services in the united states
could be determined to be an eligible
health care provider
under the cares act statute in the
appropriations language
04:47
it means any public entity anybody who's
enrolled in the medicare
medicaid program whether they're a
hospital provider whether a physician
whether a supplier of medical services
such as dme
services uh and of course dental service
dental services would would clearly fall
within this very very broad
definition of eligible health care
providers um
what is uh interesting and what we'll
touch upon a little bit later in this
slide
05:19
is that it's not just that you have to
be an eligible healthcare provider to be
eligible for these funds
but you have to be one that is provided
diagnoses
testing or care for individuals with
possible
or actual cases of coven now we'll focus
in on the word
possible because possible is
interpreted very broadly by the
department of health and human services
and their view is that any patient
today who you might provide services to
05:51
health care services too is a possible
coed patient because
they could be infected without you
knowing it so whether to be treated as a
possible
covered patient that's different we'll
talk a little bit about somebody who is
a presumptive code patient
because one of the requirements for
receiving these funds involves
how you must bill for patients who are
presumptive coca patients
there are two different definitions and
we'll get into that in a bit
so that's generally go back to you know
march
of this year when congress created the
06:23
provider relief fund
there is now a hundred billion dollars
that it needed to distribute
um and the the agency wanted to act
very quickly and wanted to act rapidly
and wanted to get funds out there to the
healthcare community because it
understood
that the healthcare community was
suffering both from the expenses that it
was incurring in order to address the
coronavirus
epidemic such as purchasing ppe
um creating new facilities temporarily
06:55
where people could be treated
creating drive-by locations for testing
all those things were increasing
expenses but perhaps
um most significantly because of the
need for social distancing and because
of the need
to um keep people from congregating in
places where they might infect each
other
many states in fact i think literally
every state in the union
was under an order to prove to stop
doing
unnecessary or excuse me non-urgent
07:26
health care services and as a result all
health care providers whether they be
hospitals physicians uh suppliers of
durable medical equipment
or dental providers for example suddenly
found that they could no longer
perform the services that they were
doing so these so-called elective
procedures
were halted which meant extensive
amounts of lost revenue
the agency wanted to respond quickly to
that and so
the first step that it took was in april
was to get out as much money as possible
07:59
in what they called the first round of
general distribution
um what the agency did with the first
round of general distribution
was it took 30 billion dollars and it
gave 30 billion dollars
without any application being required
to nearly 320
000 health care providers
who had been paid under the medicare fee
for service program for
some type of services in 2019
08:29
that was a significantly large group of
providers it included hospitals that
included
nursing homes skilled nursing facilities
home health agencies
physicians um if you had provided some
sort of
services and were paid for them from the
medicare program in in 2019
then you receive some amount of money
under this
30 billion dollar what's been called the
first tranche of
the provider relief fund general
distribution
uh significantly because many dental
09:01
providers
um of course the medicare program does
not generally cover dental services
but the medicaid program is far more
generous in terms of the coverage of
dental services
so as a result almost all dental
providers were left out
of this first tranche of general
distribution
in addition to there being some concern
about
providers who like dental providers um
did not receive medicare excuse me did
09:31
not provide medicare services and
therefore
missed out on some of the distribution
a number of providers in the country
were immediately critical
excuse me of the agency for distributing
the funds based upon
past receipts of medicare funding
many hospitals who were in so called
covet hot zones at that time
uh new york detroit um and and
another and new orleans for example uh
were critical because they needed
10:03
they felt the funds a larger
distribution of the funds
and they wanted to see that the funds
got distributed to hot spots
in addition as we said before large
medicaid providers were left out
not only dental providers but also
children's hospitals
who have a very very very low medicare
patient load
so as a result the agency
decided to issue a second round of
general distribution funds called the
we'll call it the second tranche of
funding uh in
10:34
april of uh late april of this year and
essentially what the agency did at that
point in time was to say
um we've distributed 30 billion dollars
we're going to distribute an additional
20 billion dollars to the same sets of
providers
who receive the general distribution
funds but we're going to
base their share of payments on
not just their medicare fee-for-service
billing
but we're going to base that upon their
their gross patient receipts or their
11:06
gross patient revenues
um so a second round of 20 billion
dollars was distributed
um to those providers who receive funds
in their
first general distribution um now again
uh what being left out of those rounds
uh were the
medicaid providers like dental providers
and children's hospitals
who had not received flat round excuse
me funding through the first round
i've described the agency's
decisions about how to distribute the
11:40
100 now 175 billion dollars of of
cares act provided relief funds has
really sorted up a policy decision upon
on the part of the agency and and what i
mean by that is that the agency
you know as we talked about the
statutory language at the beginning of
the session
you see there were really no rules as to
who the money should go to it should go
to
every eligible provider which is defined
as any provider who treated
a possible code patient and who also
12:11
incurred expenses and lost revenue as a
result
the agency through the past three months
has essentially distributed this money
in specific
rounds of funding that are targeted to
certain types of providers
um much of it reflecting the agency's
sort of policy
um you know desires to impact the policy
under the health care programs so for
example
um in early may
12:42
cms announced excuse me hhs announced
that it would distribute an additional
um 10 billion dollars uh to almost 400
to thousand rural health care providers
uh in the country uh that included
hospitals
rural health clinics and rural health
centers politically and policy wise
uh that was significant for this agency
which you know excuse me for this
administration
uh which wants to send the message that
it cares about rural providers
uh and so it targeted 10 billion dollars
of funds
13:13
to those rural providers but the agency
had not yet really addressed
the question about high impact
distributions
those hospitals and those other types of
facilities that are on the front line of
the coronavirus
and so they developed another round of
funding
which has been called the high impact
distribution around the funding
that was distributed to those hospitals
about 395 of them
that had 100 or more cobit 19 patient
admissions
13:44
between january and april um again this
was
in order to address the concerns by
those hospitals
that were seeing the brunt of paying for
excuse me of seeing the brunt of
addressing the coronavirus
uh pandemic that they were not being
adequately funded to address that
many of the these billions of dollars
went to hospitals and in the cities i've
just talked about
new york chicago detroit um
new orleans to some extent and other
major cities um
14:17
so that that was an attempt to address
that since then there has been a second
round
of call for high impact distribution
and the agency has made plans to
distribute some of these monies
out to the provider community who is
high
impact who have been highly impacted by
treating
covid19 admissions there was also an
allocation made for skilled nursing
facilities about 4.9 billion dollars in
may
that was given to these uh school
nursing facilities because
14:50
of the perception that they were also
on the front line of addressing the cova
pandemic
we've seen the stories we've seen the
uh and many of them may have relatives
in skilled nursing facilities and
understood
the impact that the virus has had on
treating patients
also being a sort of stopping place for
patients who are
leaving patient hospital admissions
after being uh
treated for covid um they maybe need a
resting place on the way to being
15:21
entering the general population these
skilled nursing facilities have seen an
uptake
and a patient as a result of that and
then finally
on may 29th the agency
decided to issue about a half billion
dollars of funds to
indian tribal hospitals and clinics and
other types of urban health centers
uh to address the problems that they
have been seeing and to provide some
funding
for them in response to the pandemic
15:52
now what's probably of most importance
to this audience of course is the most
recent round of funding
and i'm going to discuss that in a
second um
you this round of funding um in some
ways i think could be seen
as being it's not necessarily a targeted
distribution
it's not being given to providers who
have
um significant amounts of covet
inpatients for example uh it's not being
given to
you solely to tribal
16:25
facilities but it's a more general
distribution
and that general distribution
essentially is to go out to any type of
medicaid
or chip provider so
going back to the beginning of the
distributions of the
relief fund um i had said that
the agency initially wanted to jump out
and provide as much money as possible
to providers that they felt were most uh
affected
and the best way they had of doing that
was to identify all
16:56
the medicare providers and get funds
into their hands and that's what they
did with the general distribution
you see her on this slide that first
general distribution of 20 billion
dollars
cms excuse me hhs essentially wrapped
that up
um and said by june 3rd everybody who
felt that they were entitled to money
through the general distribution to
medicare providers had to have all their
applications in
on by june 3rd that date has come and
17:27
passed so that general medicare
distribution
timeline is now over um i also
referenced earlier that there's
going to be another round of funding for
high impact hospitals
and other facilities that have um
have have seen a number of positive
inpatient admissions from coven
the agency has now put that in process
but most significantly for this audience
the agency has finally opened up a
pipeline of funding that can be driven
17:58
towards
dental providers and the way they went
about doing that was to say that
they're now going to make 15 billion
dollars
available from the relief funds uh to
providers
who are eligible who also participate in
the state
medicaid in our chip programs and
significantly that have not received
payment from that first round of general
fund distribution
so if you were one of the people who one
of the providers
that is fortunate to be identified
18:29
through the medicare program
and you receive general distribution
funds there you're
you cannot receive general distribution
funds through the medicaid
program distribution only those who were
essentially left behind
uh now are are eligible to get those 15
billion dollars
of funds um the deadline
for this application is july 20th
um if you go to the hhs website or if
you google hhs provider relief fund
you will be taken immediately to the
19:00
page that hhs has set up for the
provider relief fund
and on that page you will see
essentially a number of uh options uh to
click on
and one of them is for providers uh and
if you click on four providers
it will describe each of the various um
distributions or categories of
distributions that i've just described
they'll talk about the general
distribution
and how that works it'll talk about the
targeted distributions to
19:31
hot spot hospitals it'll talk about
safety net hospital distributions and
then finally it will talk about the
medicaid
and chip safety net hospital
distributions
and so if you click on that link it will
take you to all the applicable
documents that you will need what you
will need
is first you will need there is an
application
that needs to be completed and sent into
the agency that application will then
enable you
um to enter uh the provider relief
20:03
portal
and establish a username and once you
establish a username then you can follow
the application instructions to begin to
provide the information
that's necessary for the agency to be
able to determine whether or not you are
eligible
for those medicaid provider relief funds
so i'm going to transition now and talk
a little bit about
at this point in time uh as to
what sort of the strings are that are
20:32
attached
to the use of these funds
let's say that you're a successful
provider you're a medicaid provider your
dental provider
you've gone in you've identified
the um that's you are in fact the
eligible provider and we're going to
talk a little bit more
in a moment about exactly how you'll
know whether or not you're an eligible
provider for if you're mental
if you're it's a medicaid dental
provider um
but once you get in there you're going
to be asked um
21:03
to ultimately attest to a set of terms
and conditions
and that's very significant for you to
pay attention to what the terms and
conditions require of you
because um if you do not comply with
those terms and conditions
uh there could be consequences uh there
could be recruitment of funds
uh there could even be you know
potentially uh accusations of fraudulent
use of these funds
so let's spend a little bit of time
going through the terms and conditions
uh
and how they work um again
um just to let you know that as you work
21:36
yourself through the provider portal
ultimately at some point in time you're
going to be asked to attest
your acceptance of the terms and
conditions for retaining whatever
monies have been provided to you through
the provider relief
distribution here the medicaid
distribution
it's obviously only for eligible
providers
the what we'll be talking about
is in the terms and conditions what they
described as the permitted
use of the funds and the non-permitted
22:07
use of the funds
the terms and conditions discussed um
reports that you may be responsible for
completing and providing to
the federal government in order to let
them know how you
use these funds it notifies you that
they may that you must retain records
and that there may be audits in the
future
of how to use these funds and then
there's also a number of
additional um conditions upon which
you accept these funds at any agree that
you will not use them
22:38
so a classic one would be you cannot use
them for example
um to engage in any sort of prohibited
lobbying activities
you will only use them to cover your
expenses uh
and your lost revenue uh attributable to
the coronal virus
so again the initial tranche or what we
call the general distribution fund of
providers
relief funding those those providers
essentially didn't need to go through a
portal initially they were just
23:11
given the money it was in their bank
accounts the medicare program knows
their bank accounts because they pay
them on a daily basis
and those funds were portion of those
funds you just distributed in them
those providers had to go back and agree
after receiving the money that they
would in fact
combine comply with those sets of terms
and conditions and they were given
90 days from the date they received
those funds to sign that attestation
saying that they would comply with the
terms and conditions
if they had not within 90 days the
23:43
default rule was
hhs would assume that they
agreed to comply with the terms and
conditions they could keep the money
but the hhs was again going to assume
that they were going to comply with all
the terms and conditions
step forth under the program
now let's talk a little bit about the
medicaid and chip distribution that you
as dental providers you know eligible
for
again if you went to the hhs website
um you're going to be provided there are
24:15
three to four
sets of documents that are important for
you to look at one
would be a set of instructions for the
medicaid application
the second is the application itself the
third
is called what the agency is called
frequently asked questions
and there's a page there's a 37 to 38
page
set of frequently asked questions that
are updated on a daily
basis and when i say updated on daily
basis i really mean that i every day i
check the website i go back and i look
24:45
to see if there's any new um any new
answer that or question that's been
posed by the agency
and answered those terms that are set
forth in the
frequently asked questions answered lots
of questions about
how to complete the application um
should you be confused by certain things
um those frequently asked questions will
also
tell you the basics of like for example
who is eligible for the various
uh distributions and there's a portion
of those faqs
that address the medicaid and chip
25:16
distribution
and so if you went to those it would
tell you
who's eligible let's go over that the
providers who are eligible
again or those who did not receive
general distribution funds i.e those
medicare providers
and um you're one of those and you build
medicaid and ship the medicator chip
programs
or you could have billed not just to a
fee for service program but also to a
medicaid managed care plan
25:46
for health care related services from
january
through may 31st of 2020 so those from
january 2020 to may 31st to 2020
so that of course would uh include most
dental providers in the united states
they'd be eligible they'd probably build
to
either fee-for-service medicaid or
medicaid mco
um they were providing
healthcare-related services and if they
did it in that window
that's step one of their eligibility um
so when must you apply you have until
26:18
july 20th
uh to submit the data that's required by
the application in part of the
information that that application is
going to require is going to require
tax information by which you will be
able to demonstrate to the agency
what your gross revenues are because
that's the what the
agency will use uh to determine the
amount of money that you will receive
from this 15 billion dollar funds
um they're looking for information on
26:51
your your tax revenue or your tax
returns and the gross revenues from that
uh for either calendar year 17 18 or 19.
um you can determine which one you want
to provide to them
but they will look at the gross revenue
portion of that and that
you're essentially going to be capped at
two percent of your
gross patient revenue now the agency and
the faqs
also say that
the final amount each provider will
receive may be affected by
other data that's submitting submitted
27:24
including information about the number
of medicaid patients that these
providers serve
now in theory the federal government has
that information as to the
number of medicaid patients um so once
you've completed this
application process they've discussed
the the idea of that you're
you'll receive at least two percent of
your gross revenues you will also be
asked for
information about loss revenue so in
addition to
providing tax return information they
will ask
for you to estimate what your loss
27:54
revenue was for a particular period of
time
and the agency has said that when you
think about estimating what your loss
revenue was for say
march or april of may of 2020
that's attributable to the coronavirus
um you're permitted to
look at any sort of past budgeting or
projections that you had used in your in
the prior year
to um you know take the delta between
your budgeted number and what you've
actually received
to come up with a lost revenue amount
now in theory once you've completed
28:27
the provider access station portal
um and you completed the application by
july 20th
you will then begin to receive funds
from the agency um
you are not going to be required to
attest at the time that you apply for
the funds
but they will require you to attest uh
to the current terms and conditions
after um you have complied with um
after you have received the money so
let's talk a little bit about how that
attestation process again is going to
28:59
work
um one thing to keep in mind
is that the application that you provide
and the attestation that you're going to
be required to
um agree with uh
is what i would call taxpayer
identification number or
tin specific what do i mean by that
um reference back to what i was talking
about with the application
where the agency wants to see your gross
receipts on your tax returns
they want that buy tax identification
29:29
number and they're going to provide
the amount of revenue to a taxpayer
identification
number so in other words they're
thinking in their minds that the
eligible provider
is a an entity that has provided a tax
return through this tax identification
number
so you those who you know wherever the
the bank account information that is
linked to that taxpayer identification
number is that's who is going to be
receiving these funds
um that's also who will be attesting to
30:01
these funds
so you could be an organization where
you may have two or three or four or
five or ten provider numbers
that all roll up into one consolidated
tax return
and is filed under one taxpayer
identification number
that organization will be attesting to
those funds and that organization will
also be receiving this fund
but if you're a provider say for example
a solo practitioner who has um you know
his or her own individual tax
identification number you'd be
30:32
receiving those funds and you would be
attesting to those funds so again it's
organization specific
as focused in through the taxpayer
identification number
what the attestation process really
requires you to do
is to say that you will comply
with all the terms and conditions we're
going to delve into those in a moment
you recognize that the terms and
conditions are material to
hhs's decision to give you this money uh
that's important
31:02
uh because by acknowledging that
you agree to comply with the terms of
condition is material to the
the secretary's decision means that um
if you some way in or in some way
accused of
fraudulently certifying to these terms
and conditions uh the secretary
says your your statements there were
material to me
so i therefore believe that is
fraudulent and i can pursue
fraud remedies against you
the agency also wants you to know that
if you fail to comply with these terms
31:33
and conditions in the future
uh they therefore have the opportunity
and the power and the right to recoup
those funds from you
and then finally
the terms and conditions apply not only
directly to the
to who's receiving those but all those
subresis
sub recipients and contractors so back
to by um
back to my statement about the taxpayer
identification number
if you are an organization that
has several different provider numbers
under that tax id
32:05
that attestation applies not only to the
organization that submits the tax id
but it's also going to be binding upon
those providers who are
who are rolled up into that taxpayer
identification
number
so this is just an example of the
attestation process that those
providers who receive medicare funds um
will be uh were required to attest to
um back on january by by june 3rd
they had to attest that they were
eligible
32:40
uh because they actually build medicare
in 2019 remember that was one of the
conditions upon which they received
their money
uh they had to attest also uh that they
provided
care on or before excuse me on or after
january 31st
uh for patients who were to diagnose
tests or care for patients with
possible or actual cases of covet again
possible
the very expansive definition and
literally means almost any patient
they also had to attest they were not
terminated from medicare
33:10
medicaid providers are obviously going
to have to attest to something similar
and that they're not otherwise excluded
from any federal health care programs
or that their billing privileges were
revoked so
we know that this is the attestation
process that the medicare providers went
through
um we also know um
that uh for those providers such as
dental providers who are going to be
applying for the medicaid transfer funds
that they're going to have a similar set
of
requirements that they're going to
33:41
attest to um
and then to again uh
focus in on the the concept of who's
getting this money
if you are in a group practice are
employed by a practice
you will not be receiving those funds
the employer organization which is
probably the taxpayer identification
organization
that's who will receive those relief
funds um as the billing organization
if you are in a group practice um
34:13
individual physicians and i guess dental
providers
in a group practice are unlikely to
receive the individual payments directly
because you probably built through the
group and that's who the really fun
payments are going to go to so you
should look to that organization that
bills
in this case the medicaid programs to
identify the details of the medicaid
payments that you would receive
or should be receiving to identify those
accounts
that would expect relief payments for
you
34:44
now let me round up here and talk a
little bit about a little bit of a
deeper dive on these terms and
conditions because they are significant
and i think all dental providers should
be
made aware of what they say
as as you move through the application
process and decide whether or not
you want to agree to the strings that
are attached to these funds
we're going to talk about the permitted
use of funds how these funds are not
to be used and then we'll talk a little
bit about the balance billing concept
which is probably
35:17
uh the most significant um here so
again the funds uh according to the
statute are there
there to for expenses um that you would
use
uh that you incurred because of the
coronavirus or you intend to occur
so a lot of this probably isn't going to
apply to dental providers
but they would as you see with with
larger providers like medic
like hospitals are large physician
practices
to the extent that you are retrofitting
facilities opening up new centers of
35:50
operations
um you know increasing workforce and
trainings creating space where you can
isolate individuals who come into your
into your facilities those would be
permitted use and those would be perfect
expenses so the funds could be used to
offset the cost of all of that
um and in fact
when you certify to these funds you'll
be asked to certify that
the relief fund payment will not be used
to reimburse expenses or losses
that have been reimbursed from other
36:21
sources
or other sources of funding
so um let me pause on that because i was
a bit of a quick
transition um recall now we talked about
that
at the very beginning in this program
that congress appropriated these funds
to offset expenses and lost revenue
i just covered the expenses portion
um you still are permitted to retain
these funds if your expenses
do not uh add up to the amount of money
36:51
that you receive through the release
fund because you may have losses
um that far exceed the amount that you
may receive from the relief fund
but as we also talked about at the
beginning of the program
you are also going to certify that
you're not going to use this money to
pay for expenses or lost revenues that
have been
otherwise paid for by other programs so
for example if you are
taking part in a small business payroll
37:22
protection program
um or you're involved in the fema
program um
you cannot use funds that the fema
program gave you to pay for the same
expenses and then claim those expenses
under the provider relief
funds similarly if you have a business
interruption
insurance program that pays you for
losses
you may find yourself precluded from
being able to get
coverage for your business losses
through the provider release fund itself
let's talk a little bit about balance
37:53
billing balance billing is significant
and it's something that's confusing and
there probably needs to be a deeper dive
perhaps a program on balance billing
alone
but let me explain the concept this has
not come at all from
the cares act this is a policy
that this agency has decided to adopt
as a string that's attached to the
coping related
relief files um balance billing
essentially means
38:24
of course that um you build a patient
uh for the balance of what is not
covered by insurance
the as a result of the coronavirus um
a lot of patients were forced to see
um health care providers
or suppliers who were not within their
uh
necessarily within their networks so
they weren't within their hmo or they
weren't within their
mco and the agency has said that
they that they would like to have
38:56
providers
who are providing code related care
they are prohibited from balance billing
those providers for out-of-network
uh cost so the example would be
a physician sees a patient uh provides
covert related
care to that patient uh the physician
cannot
um the patient is not within the
physician
excuse the physician is not within the
patient's uh commercial network
um a commercial insurance network the
39:28
commercial insurer
pays some or little for that and there's
a significant balance on the bill
the covid if that physician
receives relief funds under the provider
release
funding program he or she is prohibited
from balance billing the patient for
those funds
um and the um
the rationale behind that is um that the
agency
once uh during the pandemic doesn't want
to discourage
39:59
patients from going to see those
providers that needs to
even and they may be blocked out of
their network because some providers
just no longer available
this may or may not be a big issue for
the
uh dental community um it has happened
with some significant frequency
um in the acute care hospital setting
and in the physician setting
um in and i have counsel patients excuse
me i have counseled um providers as to
how they should
uh identify when there may be a
40:30
potential balance billing problem
um but it really the reason it may not
be
a significant problem for the dental
community is
it only applies when you're providing
services to somebody who is a known cova
patient and you're provided coverage
related care
or they're a presumptive covered patient
that you're providing code related
care and a provocative covalent patient
is somebody who
um the medical record would suggest that
they have coveted even though they don't
have a positive
co-diagnosis test in their record
41:01
so since it's linked to providing
um those types of services
excuse me since the balance billing
requirement is linked to
uh those who are providing uh coveted
related care
there is probably not going to be a
significant number of
dental providers who are going to be
caught up in the need to assess whether
or not
they're they're caught up in a balanced
billing problem but the balance billing
issue
is significant it's a significant term
and condition
um for the receipt of these
41:34
provider care relief funds there are
another um
there are a number of other significant
uh conditions uh that under the terms
and conditions that
uh dental providers should be aware of
only discuss one or two more
before i turn the program back to
allison but the first
um first one to be concerned about i
think is
we've already really covered it that
you're acknowledging that you're going
to only use these funds to cover your
expenses
and losses attributable to the
42:05
coronavirus so if at the end of the day
um you receive more funds than your
expenses
or your losses then you may be in a
situation where
there may need to be some reconciliation
and some return of funds go back to the
agency
because you are capped at what those
expenses and losses ultimately are
the second term and condition i think
it's worth uh focusing on is that
you will have to at some point in time
provide reports
uh to the um
42:36
coronavirus accountability commission
or i think it's actually called the
pandemic response accountability
commission
this was created by the cares act and
it's essentially a grouping of
inspector general types who will be
looking into whether or not the federal
government appropriately
distributed funds whether those funds
are being used
as required by statute and
the terms and conditions speak
specifically to the fact that at some
point in time in the future
uh the department of hhs will provide
uh some mechanism for you to report back
43:09
the amount of funds that you received
the expenses that you're using as funds
to offset and the losses that you're
using as funds to offset
so they there will be some point in the
time where
those reports will be looked at by the
accountability commission
uh and there may be some audits
associated with that as well
so as you are going through and
determining whether
you have coveted related expenses
whether you have coveted related losses
always bear in mind that the time to
account for those in an appropriate
43:40
fashion uh and to make sure that you
have all your documentation orders
now because if you do receive these
funds you will be
preparing a report to the accountability
commission and there's a high likelihood
that there will be some review of those
um and if you cannot document um your
expenses or your losses
there will be some return to fund so
that sort of is
it from my perspective for the high
level review of what the terms and
conditions require
i'm now going to turn it over to allison
who's going to talk about what may be
44:11
coming up
next for more provider relief funding
allison do you want me to
do you want to take it from here thank
you
thank you mark um and mark if you would
advance to the next slide
um when you add up all of the different
components and different distributions
of the provider relief fund
that have been announced to date that
leaves for those of you counting keeping
score at home that leaves about 65
billion
44:41
of the 175 billion remaining
and not yet spoken for how this
remaining
money is distributed is the subject of a
great deal of interest as you can
imagine from stakeholders and from
members of congress who authored
and supported this funding the members
of congress
are hearing daily from their
constituents about how the funds are
getting out into the community
who's hurting who's been left behind and
who needs to be taken care of in the
next tranche
45:12
these members have communicated with
written letters to
hhs secretary azar urging
in some cases particular segments of the
health care provider community that have
not yet gotten the benefits of the fund
or
need to be have further attempts to make
them whole
um they are trying to address those
specific concerns
in addition members of congress are
seeking greater transparency
45:42
in who has gotten this money where has
it gone what's a sort of final
accounting tally
and this is for a couple of reasons um
it is both to understand where
the funding that is in there you know
sitting in this fund where it's gone
where the remainder should go
to properly address what what health
care providers have had to do
to respond to this public health
emergency
it is intended to provide a bit of a
46:12
road map should future additional
funding be needed
and as mark alluded to it is important
for oversight um
members of congress as you can imagine
want to
understand where the money has gone and
you know to the extent their
constituents or
or particularly segments of their
um healthcare community um have have
not been taken care of they want to know
about that
and this is all relevant sort of this
understanding the transparency it is all
46:43
relevant frankly because if you look
in the june 9th hhs announcement
the very last line of the hhs press
release
notes that hhs and we've got the quote
here is working on an additional
allocation to distribute really broadly
to dentist
so having it is helpful that mark went
through
all of the steps and all of the strings
that are attached
because there will be another um you
know according to hhs
47:13
there will be another announcement
and perhaps not limited to um just this
space there may be
others so it's important to understand
how the program has evolved and
developed
and stay tuned both to henry shine's
website
and to the hhs provider relief fund
website to see
what comes next and what you are
eligible for
and with that i think that concludes our
program i don't know that there are any
specific questions but we would be happy
47:45
to address any
thank you mark and allison for your time
today are there any
important next steps that our customers
should be taking right now
while we wait for more information on
this topic well i'll go first with that
natalie i think that
um if if you are interested in the
karazhak
release fund i would i would definitely
take a tour around the hhs website
um you will not uh not every question
that anybody has will
48:15
will be answered um it's it's not as
scary as it sounds but
um you know you can easily download the
instructions you can easily download
um the application form uh and review
those that that's the first place to
start
uh where it starts to get a little um
hairy is when
you start going through the terms and
conditions uh there's a lot of legal
language that's used in the terms and
conditions there's a lot of
cross-referencing to other statutes and
other parts of the program
and that's where i think a lot of
48:46
people's concerns start to come in and
start to
try to understand um what what best
it is uh that we're trying to understand
exactly what those terms mean
um but yeah i would start off with going
to the website
and doing a little bit of self tutorial
there
okay great the only thing the only thing
i would add is
um to the extent that you are
finding that that distributions aren't
haven't reached you yet or you are in
need of something i always always
49:19
encourage folks to
reach out to their members of congress
and let them know
um you know the next covid package is
being developed um
members do want to respond and i just i
think that is
helpful to share with them how this
funding
is translating in the real world
great well thank you both very much i'd
really like to thank you for your time
today and your valuable insights on this
really important topic
and for our listeners we hope you found
this information to be helpful
49:51
please visit the henry shine page for
access to the most up-to-date
information
and helpful links to learn more about
the funding available through the cares
act
thanks for participating today