COVID-19: Relief for Healthcare Providers

When the going gets tough, the tough get going!

During this pandemic, the President has launched several relief programs for Healthcare providers like you.  Please take a moment to go through these summarized, simplified terms and conditions that may affect you.

If you have received a payment from the Public Health and Social Services Emergency and have retained the payment for at least 30 days without contacting HHS regarding remittance of those funds, you are deemed to have accepted the Terms and Conditions mentioned below.

Non-compliance to any Term or Condition is grounds for recoupment of some or all of the payment.

The following is the summary of the Terms and Conditions.  A complete copy may be found at the links mentioned below.

  1. FFCRA (Families First Coronavirus Response Act) Relief Fund Payment Terms and Conditions
    1. You acknowledge that you plan on submitting claims for reimbursement for COVID-19 Testing, and/or Testing-Related Items and Services provided to FFCRA Uninsured Individuals.  FFCRA Uninsured Individuals mean individuals who, as of the date of service for which payment is sought, is not enrolled in
      1. Federal health care program
      2. A group health plan, or health insurance coverage offered by a health insurance issuer.
    2. The recipient of the fund acknowledges that each time the Recipient submits such claims for reimbursement, each claim must be in full compliance with these Terms and Conditions.
    3. COVID-19 Testing is an in vitro diagnostic test for the detection of SARS-CoV-2, or the diagnosis of the virus that causes COVID-19
      1. Is FDA approved (510(k), 513, 515 or 564 or
      2. The developer has requested, intends to request, emergency use authorization under section 564 of Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360bbb-3) unless previously denied
  2. Uninsured Relief Fund Payment Terms and Conditions
    • You acknowledge that you plan on submitting claims for reimbursement for care, or treatment related to positive diagnoses of COVID-19 provided to individuals who do not have any health care coverage at the time the services were provided.
  3. Relief Fund Payment from $20 Billion General Distribution Terms and Conditions
    • You certify that you
      1. have billed Medicare in 2019,
      2. have provided or currently provide diagnoses, testing or care for individuals with possible or confirmed COVID-19 after January 31, 2020

You also certify that the payment received:

  1. will only be used to prevent, prepare for, and respond to coronavirus
  2. is only for health care related expenses or lost revenues attributable to coronavirus
    • losses that have not been, or will not be reimbursed from other sources
  3. You may be needed to submit reports to the Secretary to ensure compliance with conditions. 
  4. You shall also submit general revenue data for 2018,
    1. when applying to receive, or
    2. within 30 days of having received a payment
  5. The information relating to this fund disbursement may be publicly disclosed.
  6. If you have received funds of more than $150,000 (in total under any appropriation for coronavirus response) shall submit a report to the Secretary and the Pandemic Response Accountability Committee within 10 after the end of each calendar quarter.
  7. You shall maintain appropriate records and cost documentation and other information required by future program instructions and will co-operate with all audits conducted.
  8. You certify you will not seek to collect from out-of-network patients an amount greater than what the patient would otherwise pay out-of-pocket for an in-network visit.

The following General Provisions in FY2020 also apply

  1. Executive Pay: None of the funds shall be used to pay the salary of an individual at a rate in excess of Executive Level-II
  2. Prohibition for Gun Control Advocacy:  None of the funds made available may be used to advocate or promote gun control
  3. Lobbying:
    1. None of the appropriation shall be used for normal, and recognized executive-legislative relationships for publicity, propaganda use or other purposes.
    2. Funds may not be used to pay the salary or expenses related to any activity designed to influence legislation, appropriations, regulation, administrative action.
  4. Abortions:  None of the funds appropriated shall be expended for any abortion. (Please refer to the complete Terms and Conditions for further Limitations on Abortion Funding Prohibition)
  5. Embryo Research: Prohibits Use of Funds for Embryo Research
  6. Controlled Substances: Prohibits Promotion of Legalization of Controlled Substances
  7. Pornography: None of the funds may be used to maintain or establish a computer network unless such network blocks the viewing, downloading, and exchanging of pornography.
  8. ACORN Funding:  None of the funds may be provided to the Association of Community Organizations for Reform Now (ACORN)
  9. Needle Exchange Funding: No funds appropriated shall be used to purchase sterile needles or syringes for the hypodermic injection of any illegal drug, except in limited circumstances (please check the links below for the complete Terms and Conditions)

Government-wide General Provisions also apply

  1. Propaganda: No part of any appropriation shall be used directly or indirectly for publicity or propaganda.
  2. Privacy Act: None of the funds made available may be used in contravention of the Privacy Act.
  3. Confidentiality Agreements: None of the funds may be made available for a contract, grant, with an entity restricting employees or contractors from lawfully reporting waste, fraud, or abuse to designated investigative or law enforcement representative.
  4. Unpaid Federal Tax Liability: None of the funds made available may be used to enter a contract or provide loan to any corporation that has any unpaid Federal tax liability.
  5. Criminal Felony Limitation: None of the funds may be used to enter into a contract or agreement or provide a loan to any corporation that was convicted of a felony criminal violation under Federal law within the preceding 24 months.

The complete list and details of the Terms and Conditions may be found at https://www.hhs.gov/sites/default/files/terms-and-conditions-provider-relief-20-b.pdf

https://www.hhs.gov/sites/default/files/terms-and-conditions-ffcra-relief-fund.pdf

https://www.hhs.gov/sites/default/files/terms-and-conditions-uninsured-relief-fund.pdf

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