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HHS Stimulus Payments Explained
By Saurabh Gupta, Ph.D.

Some members of the SDPA have contacted the Government Affairs Committee (GAC) to request information on the nature of direct deposits or other payments received, without request, from the federal government through the Health and Human Services Administration (HHS). They also expressed concern about their rights and obligations associated with these payments. The following is intended to address these questions and concerns, using HHS.gov as the chief source of information. It should be noted that like some other provisions of the CARES act, a bill passed in late March, its implementation was less than ideal. Information about its various provisions were not adequately shared by the federal government or not done so in a timely fashion, which led to mass confusion. Moreover, some of these funds found their way into healthcare practices’ bank accounts before explanation was widely disseminated. Therefore, it is unsurprising that folks are confused.

HHS stimulus payments were distributed to healthcare practices that participated in Medicare in 2019 and “provided after January 31, 2020 diagnoses, testing, or care for individuals with possible or actual cases of COVID-19.” (note: This is intentionally broad because treating anyone is treating a person with a possible case of VIVID-19). These practices are to receive their share of $30 billion, based on their 2019 fee-for-service reimbursements for that year. Moreover, the funds are being distributed in a phased approach. Round 1 was to be delivered by April 24, 2020. This required an attestation. Some providers who received funds were notified in an email that they must attest to the receipt of these monies, while others providers stated they had received no such email. Fortunately, according to HHS.gov, “These are payments, not loans, to healthcare providers, and will not need to be repaid.” Notwithstanding, if you received this initial round of funding, you must attest. Although the HHS.gov site itself posts conflicting information, stating you were to do this within 30 days of receipt of the monies in one page of the site, the attestation page states that you have 90 days. Regardless, if you received funds, we recommend you attest immediately. The following is a link to a page where you can attest: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html.

Round 2, is intended to be another distribution of healthcare providers’ share of another $20 billion. To eligible to receive these funds, eligible providers must have submitted financial data to a “General Distribution Portal” by June 3rd, found using the same link as above, where more detailed financial information is requested and providers are asked to agree to be subject to potential audit and comply with requests for information to verify their practices were financially impacted by the pandemic. Although the deadline has passed, if you wish to be eligible to receive round 2 funding, we recommend completing the information requested in the General Distribution Portal. These funds may still be available, and HHS has stated this will also make you automatically eligible for future rounds of funding.

Finally, it is worth noting that the HHS states that if you received the initial round of funding and completed your attestation, you must also complete the requested information in the General Distribution Portal, along with the above stated agreements for audit and review of your practice’s financial records, in order to keep the Round 1 funding, even if you are not requesting additional funding. It is unclear whether this necessarily means the Round 1 funding will be “clawed back,” if you fail to do this, though that may be the official position of the HHS. Some providers may be willing to attest receipt of the initial funds but may be unwilling to agree to provisions of an audit. In this case, we recommend that you set these funds aside at least until your 2020 taxes are filed and perhaps longer, in case the federal government seeks to recover those funds. Whether these funds will be considered taxable income, is also unclear and as of yet there is no published guidance that we were able to find. We recommend consulting an accounting professional regarding these latter two questions.

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