CARES Act Provider Relief Fund

Frequently Asked Questions

CARES Act Provider Relief Fund Frequently Asked Questions

Provider Relief Fund General Information FAQs

Overview
General Distribution
Targeted Distributions
Attestation Process
Rejecting Payments
Terms and Conditions
Reporting
Requirements Balance
Billing
Appeals
Publication of Payment Data

General Distribution FAQs

Overview and Eligibility
Payment Application
Portal (i.e., DocuSign)
Determining Additional Payments
Data Sharing

Targeted Distribution FAQs

Rural Targeted Distribution
High-Impact Area Hospitals Impact
Area Targeted Distribution Skilled
Nursing Facilities Distribution Indian
Health Service Distribution

Provider Relief Fund General Information FAQs

Overview

Who is eligible to receive payments from the Provider Relief Fund?

Provider Relief Funds are being disbursed via both “General” and “Targeted” Distributions.

General Distribution

To be eligible for the general distribution, a provider must have billed Medicare in 2019 and
provide or provided after January 31, 2020 diagnoses, testing, or care for individuals with possible
or actual cases of COVID-19. HHS broadly views every patient as a possible case of COVID-19.
$50 billion will be disbursed in the General Distribution.

All providers retaining funds must sign an attestation and accept the terms and conditions
associated with payment. Providers must also submit tax documents and financial loss estimates
if they wish to be eligible for additional funds.

Targeted Distributions

A description of the eligibility for the announced Targeted Distributions can be found here.

U.S. healthcare providers may be eligible for payments from the remaining funds through Targeted
Distributions. Information on future distributionswill be shared when publicly available.

If I changed my mind after I rejected a Provider Relief Fund Targeted Distribution

payment through the Attestation Portal and returned the payment, can I receive a new
payment? (Added 5/29/2020)
No, HHS will not issue a new payment to a provider that received and then subsequently rejected
and returned the original payment. The provider may be considered for future distributions if it
meets the eligibility criteria for that distribution.

Is this a loan or a grant that I will need to pay back?

Retention and use of these funds are subject to certain terms and conditions. If these terms and
conditions are met, payments do not need to be repaid at a later date. These terms and conditions
can be found here.

My organization bills Medicare through the Medicare Advantage program. I did not
receive funding in the general distribution. When can I expect to receive funding? (Added
5/12/2020)
Providers that did not receive funding under the General Distribution may be included in future
allocations under the Provider Relief Fund. Additional information will be posted as available at
https://www.hhs.gov/provider-relief/index.html.

How will additional stimulus payments be processed or handled?

A description of additional disbursements can be found here.

Attestation

What action does a provider need to take after receiving a Provider Relief Fund payment?
(Modified 5/2026/2020)
The CARES Act requires that providers meet certain terms and conditions if a provider retains a
Provider Relief Fund payment. If a provider chooses to retain the funds, it must attest that it meet
these terms and conditions of the payment. The CARES Act Provider Relief Fund Payment
Attestation Portal will guide you through the attestation process to accept or reject the funds. Not
returning the payment within 4590 days of receipt of payment via ACH or within 60 days of
check payment issuance will be viewed as acceptance of the Terms and Conditions. A provider
must attest for each of the Provider Relief Fund distributions received.
Does the Provider Relief Fund Payment Attestation Portal require payment recipients to
attest that the payment amount was received? (Added 5/12/2020)
Yes. The Payment Attestation Portal requires payment recipients to (1) confirm they received a
payment and the specific payment amount that was received; and (2) agree to the Terms and
Conditions of the payment.
If a provider received two direct payments through the General Distribution, can a
provider accept one payment and then reject the other payment? (Added 5/12/2020)
Yes. If a provider would like to reject one payment, the provider may still accept future
distribution payments. The provider must use the Payment Attestation Portal to accept or reject
payments.

Rejecting Payments

How can I return a payment I received under the Provider Relief Fund? (Modified
5/2026/2020)
Providers may return a payment by going into the attestation portal within 4590 days of receiving
payment via ACH or within 60 days of check payment issuance and indicating they are rejecting
the funds. The CARES Act Provider Relief Fund Payment Attestation Portal will guide providers
through the attestation process to reject the funds.

To return the money, the provider needs to contact their financial institution and ask the
institution to refuse the received Automated Clearinghouse (ACH) credit by initiating an ACH
return using the ACH return code of “R23 - Credit Entry Refused by Receiver." If a provider
received the money via ACH they must return the money via ACH. If a provider was paid via
paper check, after rejecting the payment in the attestation portal, the provider should destroy the
check if not deposited or mail a paper check to UnitedHealth Group with notification of their
request to return the funds.

How should a provider return a payment it received via check? (Added 5/12/2020)
If the provider received a payment via check and has not yet deposited it, destroy, shred, or
securely dispose of it. If the provider has already deposited the check, mail a refund check for the
full amount, payable to “UnitedHealth Group” to the address below. Please list the check number
from the original Provider Relief Fund ACH payment or check in the memo.

UnitedHealth Group Attention: CARES Act Provider Relief Fund PO Box 31376 Salt Lake
City, UT 84131-0376

How does a provider who received an electronic payment return funding if their financial
institution will not allow them to return the payment electronically? (Added 5/12/2020)
Contact UnitedHealth Group’s Provider Support Line at (866) 569-3522.
Terms and Conditions

What is the definition of individuals with possible or actual cases of COVID-19? (Added
5/6/2020)
Unless the payment is associated with specific claims for reimbursement for COVID-19 testing
or treatment provided on or after February 4, 2020 to uninsured patients, under the Terms and
Conditions associated with payment, providers are eligible only if they provide or provided after
January 31, 2020, diagnoses, testing or care for individuals with possible or actual cases of
COVID-19. HHS broadly views every patient as a possible case of COVID-19.

Not every possible case of COVID-19 is a presumptive case of COVID 19. For clarification as it
relates to presumptive COVID 19 cases, refer to the Frequently Asked Question that defines a
presumptive case of COVID-19

What oversight and enforcement mechanisms will HHS use to ensure providers meet the
Terms and Conditions of the Provider Relief Fund payments? (Added 5/6/2020)
Failure by a provider that received a payment from the Provider Relief Fund to comply with any
term or condition can subject the provider to recoupment of some or all of the payment. Per the
Terms and Conditions, all recipients will be required to submit documents to substantiate that
these funds were used for increased healthcare-related expenses or lost revenue attributable to
coronavirus, and that those expenses or losses were not reimbursed from other sources and other
sources were not obligated to reimburse them. HHS will have significant anti-fraud monitoring
of the funds distributed, and the Office of Inspector General will provide oversight as required in
the CARES ACT to ensure that Federal dollars are used appropriately.

What is the definition of Executive Level II pay level, as referenced in the Terms and
Conditions? (Added 5/29/2020)
The Terms and Conditions state that none of the funds appropriated in this title shall be used to
pay the salary of an individual, through a grant or other mechanism, at a rate in excess of
Executive Level II. The salary limitation is based upon the Executive Level II of the Federal
Executive Pay Scale. Effective January 5, 2020, the Executive Level II salary is $197,300. For
the purposes of the salary limitation, the direct salary is exclusive of fringe benefits and indirect
costs. The limitation only applies to the rate of pay charged to Provider Relief Fund payments
and other HHS awards. An organization receiving Provider Relief Funds may pay an individual’s
salary amount in excess of the salary cap with non-federal funds.

Can providers who have ceased operation due to the COVID-19 pandemic still receive this
funding? (Added 5/29/2020)
If a provider ceased operation as a result of the COVID-19 pandemic, they are still eligible to
receive Provider Relief funds so long as they provided on or after January 31, 2020, diagnoses,
testing, or care for individuals with possible or actual cases of COVID-19. HHS broadly views
every patient as a possible case of COVID-19, therefore, care does not have to be specific to
treating COVID-19. Recipients of funding must still comply with the Terms and Conditions
related to permissible uses of Provider Relief Fund payments.

If a provider secures COVID-19-related funding separate from the Provider Relief Fund,
such as the Small Business Administration’s Paycheck Protection Program, does that affect
how they can use the payments from the Provider Relief Fund? Does accepting Provider
Relief Fund payments preclude a provider organization from seeking other funds
authorized under the CARES Act? (Added 5/29/2020)
There is no direct ban under the CARES Act on accepting a payment from the Provider Relief
Fund and other sources, so long as the payment from the Provider Relief Fund is used only for
permissible purposes and the recipient complies with the Terms and Conditions. By attesting to
the Terms and Conditions, the recipient certifies that it will not use the payment to reimburse
expenses or losses that have been reimbursed from other sources or that other sources are
obligated to reimburse.

How will HHS recoup funds from providers that are required to repay all or part of a
Provider Relief Fund payment? (Added 5/29/2020)
HHS has not yet detailed how recoupment or repayment will work. However, the Terms and
Conditions associated with payment require that the Recipient be able to certify, among other
requirements, that it was eligible to receive the funds (e.g., provides or provided after January 31,
2020, diagnoses, testing, or care for individuals with possible or actual cases of COVID-19) and
that the funds were used in accordance with allowable purposes (e.g., to prevent, prepare for, and
respond to coronavirus). Additionally, recipients must submit all required reports as determined
by the Secretary. Non-compliance with any Term or Condition is grounds for the Secretary to
direct recoupment of some or all of the payments made. HHS will have significant anti-fraud
monitoring of the funds distributed, and the Office of Inspector General will provide oversight as
required in the CARES Act to ensure that Federal dollars are used appropriately.

Reporting Requirements

What are the reporting requirements for providers attesting to receipt of Provider Relief
Fund payments and when will reporting begin? (Added 5/6/2020)
All providers receiving Provider Relief Fund payments will be required to comply with the
reporting requirements described in the Terms and Conditions and specified in future directions
issued by the Secretary. The specific reporting obligations imposed on providers receiving
$150,000 or more from any Act primarily making appropriations for the coronavirus response
and related activities, which is a statutory requirement, begins for the calendar quarter ending
June 30. The Secretary may request additional reports prior to that date. HHS will provide
guidance in the future about the type of documentation we expect recipients to submit.
Additional guidance will be posted at https://www.hhs.gov/provider-relief/index.html.

Balance Billing

Do the Terms and Conditions for the General, Rural or High Impact Distributions require
attesting to a ban on balance billing for all patients and/or all care, because “HHS broadly
views every patient as a possible case of COVID-19”? (Added 5/6/2020)
No. As set forth in the Terms and Conditions, the prohibition on balance billing applies to “all
care for a presumptive or actual case of COVID-19.”

The Terms and Conditions provision related to balance billing suggests that providers
that provide out-of-network care to an insured, presumptive or actual COVID-19 patient
can bill the patient’s insurer any amount, as long as they don’t bill the patient directly. Is
that correct? (Added 5/6/2020)
The Terms and Conditions do not impose any limitations on the ability of a provider to submit a
claim for payment to the patient’s insurance company. However, an out-of-network provider
delivering COVID-19-related care to an insured patient may not seek to collect from the patient
out-of-pocket expenses, including deductibles, copayments, or balance billing, in an amount
greater than what the patient would have otherwise been required to pay if the care had been
provided by an in-network provider.

The Terms and Conditions associated with the two General Distribution payments and the
Rural and High Impact payments require that “for all care for a presumptive or actual
case of COVID-19, Recipient certifies that it will not seek to collect from the patient out-of-
pocket expenses in an amount greater than what the patient would have otherwise been
required to pay if the care had been provided by an in-network Recipient.” How does HHS
define a presumptive case of COVID-19? (Added 5/6/2020)
A presumptive case of COVID-19 is a case where a patient’s medical record documentation
supports a diagnosis of COVID-19, even if the patient does not have a positive in vitro
diagnostic test result in his or her medical record.

How will a provider know the in-network rates to be able to comply with the requirement
to bill a presumptive or actual COVID-19 patient for cost-sharing at the in-network rate?
(Added 5/6/2020)
Providers accepting the Provider Relief Fund payment should submit a claim to the patient’s
health insurer for their services. Most health insurers have publicly stated their commitment to
reimbursing out-of-network providers that treat health plan members for COVID-19-related care
at the insurer’s prevailing in-network rate. If the health insurer is not willing to do so, the out-of-
network provider may seek to collect from the patient out-of-pocket expenses, including
deductibles, copayments, or balance billing, in an amount that is no greater than what the patient
would have otherwise been required to pay if the care had been provided by an in-network
provider.

If a hospital receives a Provider Relief Fund payment under the General, Rural or High
Impact Distribution and the hospital contracts with an independently contracted provider
(e.g., anesthesiologist or laboratory), is that independently contracted provider banned
from balance billing for care provided to a “presumptive or actual COVID-19 patient”?
(Added 5/6/2020)
Yes, if the independently contracted provider also attested to receiving a payment from the
Provider Relief Fund.

Appeals

Who determines the amount my organization will receive?

HHS will apportion relief funds to US healthcare providers with the intention of optimizing the
beneficial impact of the funds.
Who can I talk to at HHS about my distribution payment?
HHS is not taking direct inquiries from providers, and no remedy or appeals process will be
available. For additional information, please call the provider support line at (866) 569-3522.

How do I appeal or dispute a decision made?

There is no appeals or dispute process.

Publication of Payment Data

Is there a publicly available list of providers and the payments they received through the
Provider Relief Fund? (Modified 5/2026/2020)
HHS has posted a public list of providers and their payments once they attest to receiving the
money and agree to the Terms and Conditions. All providers that received a payment from the
Provider Relief Fund and retain that payment for at least 4590 days if received via ACH or 60
days from check issuance without rejecting the funds are deemed to have accepted the Terms
and Conditions. Providers that affirmatively attest through the provider portal or that retain the
funds past 4590 days of receipt of payment via ACH or within 60 days of check payment
issuance, but do not attest, will be included in the public release of providers and payments. The
list includes current total amounts attested to by providers from each of the Provider Relief
Fund distributions, including the General Distribution, Rural Distribution, and High-Impact
Areas Distribution. The list is available here.

What providers are included in the Provider Relief Fund data file on the CDC website?
(Added 5/12/2020)
The data that are posted here represent the list of providers that received one or more payments
from the Provider Relief Fund and that have attested to receiving at least one payment and
agreed to the associated Terms and Conditions. If a provider has received more than one
payment but has not accepted all of the payments (by attesting and agreeing to the Terms and
Conditions), only the dollar amount associated with the accepted payment or payments will
appear. These data displayed on the website will be updated biweekly.

Why might a provider not be listed or listed with a different address than their service
location? (Added 5/12/2020)
Provider Relief Fund payments are being made to providers or groups of providers that are
organized within a Tax Identification Number (TIN). The information displayed is of providers
by billing TIN that have received at least one payment, which they have attested to, and the
address associated with that billing TIN. Providers will not be listed if they have not yet attested
to the payment terms and conditions or if they are within a larger billing entity that received
payment. In addition, the address listed for the billing TIN often corresponds with the billing
location (based on CMS’s Provider Enrollment, Chain, and Ownership System (PECOS)), and
may not align with the physical location of a health care practice site. Updated data will be made
available on the CDC’s website.

How often will the public reporting of payments data file on the CDC website be updated?
(Added 5/12/2020)
HHS will update the data biweekly.
Will HHS release additional data such as provider types, payment amount per distribution,
or payment recipients’ NPIs on the public reporting of payments data file on the CDC
website? (Added 5/12/2020)
HHS does not have plans to include additional data fields in this report.

Can a provider choose to have its payment data omitted from the Provider Relief Fund data
set on the CDC website? (Added 5/20/2020)
No. To ensure transparency, HHS will publish the names of payment recipients and the amounts
accepted and attested to by the payment recipient.

How is HHS publically reporting Provider Relief Fund payments? Would it be accurate to
add the payments received by a health care provider together based on the provider’s
name in order to determine how much a particular organization has received as a whole?
(Added 5/29/2020)
This approach may not be accurate. Each row in the public use file (PUF) is associated with an
individual billing TIN, which is the unique identifier that received and attested to one or more
payments. If an organization name is listed more than once, it may be because the organization
has more than one billing TIN that received a payment, or it may be because multiple providers
have the same name.

General Distribution FAQs

Overview and Eligibility

Which types of providers are eligible to receive a General Distribution Provider Relief
Payment? (Added 5/6/2020)
To be eligible for a General Distribution payment, providers must have billed Medicare on a fee-
for- service basis (Parts A or B) in Calendar Year 2019. Additionally, under the Terms and
Conditions associated with payment, these providers are eligible only if they provide or provided
after January 31, 2020, diagnoses, testing or care for individuals with possible or actual cases of
COVID-19. HHS broadly views every patient as a possible case of COVID-19.

All providers retaining funds must sign an attestation and accept the terms and conditions
associated with payment. Providers must also submit tax documents and financial loss estimates
if they wish to be eligible for additional funds.

How did HHS determine the additional payments under the General Distribution?
(AddedModified 5/1429/2020)
HHS is distributing an additional $20 billion of the General Distribution to providers to augment
their initial allocation so that $50 billion is allocated proportional to providers' share of 2018 net
patient revenue. The allocation methodology is designed to provide relief to providers, who bill
Medicare fee-for-service, with at least 2% of that provider’s net patient revenue regardless of the
provider’s payer mix. Payments are determined based on the lesser of 2% of a provider’s 2018
(or most recent complete tax year) net patient revenue or the sum of incurred losses for March
and April. If the initial General Distribution payment you received between April 10 and April
17 was determined to be at least 2% of your annual patient revenue, you willmay not receive
additional General Distribution payments.
How can I estimate 2% of patient revenue to determine my approximate General
Distribution payment? (Added 5/14/2020)
In general, providers can estimate payments from the General Distribution of approximately 2%
of 2018 (or most recent complete tax year) patient revenue. To estimate your payment, use this
equation:

(Individual Provider Revenues/$2.5 Trillion) X $50 Billion = Expected Combined General

Distribution.

To estimate your payment, you may need to use “Gross Receipts or Sales” or “Program Service
Revenue.” Providers should work with a tax professional for accurate submission.

This includes any payments under the first $30 billion general distribution as well as under the $20
billion general distribution allocations. Providers may not receive a second distribution payment if
the provider received a first distribution payment of equal to or more than 2% of patient revenue.

I am a healthcare provider that received a previous General Distribution payment and I

submitted my revenue information through DocuSign. Why am I not receiving an
additional payment? (AddedModified 5/1429/2020)
HHS is distributing an additional $20 billion of the General Distribution to providers to augment
their initial allocation so that $50 billion is allocated proportional to providers' share of 2018 net
patient revenue. Payments are determined based on the lesser of 2% of a provider’s 2018 (or
most recent complete tax year) net patient revenue or the sum of incurred losses for March and
April. If the initial General Distribution payment you received between April 10 and April 17
was determined to be at least 2% of your annual patient revenue, you willmay not receive
additional General Distribution payments. There may be additional distributions in the future for
which providers are eligible.

I submitted my financial information on the Provider Relief Fund Payment Portal. Why
have I not received funds yet? (Added 5/14/2020)
HHS is reviewing providers’ uploaded financial information. Payments will go out weekly, on a
rolling basis, as information is validated. HHS may seek additional information from providers
as necessary to complete its review.

I did not receive any payments from the previous General Distribution. Can I still receive
funding though the additional General Distribution? (Added 5/14/2020)
No, only providers that received a previous payment under the General Distribution are eligible
to receive funding through this additional distribution.

Can I receive additional funding through the Targeted Distribution if I received a General
Distribution payment? (Added 5/14/2020)
Yes, you may receive additional funding through Targeted Distribution payments related to
COVID-19. Additional allocations will be made separately from General Distribution payments.
You may also file claims for testing and treatment of uninsured COVID-19 patients.
Can I modify my application? (Added 5/14/2020)
Yes, providers can resubmit a General Distribution application. HHS will review the most recent
request.

What should a provider do if a General Distribution payment is greater than expected or

received in error? (Modified 5/2026/2020)
Providers that have been allocated a payment must sign an attestation confirming receipt of the
funds and agree to the Terms and Conditions within 4590 days of payment via ACH or within 60
days of check payment issuance. If a provider believes it was overpaid or may have received a
payment in error, it should reject the entire General Distribution payment and submit the
appropriate revenue documents through the General Distribution portal to facilitate HHS
determining their correct payment. If a provider believes they are underpaid, they should accept
the payment and submit their revenues in the provider portal to determine their correct payment.

Does HHS intend to recoup any payments made to providers not tied to specific claims for
reimbursement, such as the General Distribution payments? (Added 5/6/2020)
The Provider Relief Fund and the Terms and Conditions require that recipients be able to
demonstrate that lost revenues and increased expenses attributable to COVID-19, excluding
expenses and losses that have been reimbursed from other sources or that other sources are
obligated to reimburse, exceed total payments from the Relief Fund. Generally, HHS does not
intend to recoup funds as long as a provider’s lost revenue and increased expenses exceed the
amount of Provider Relief funding a provider has received. HHS reserves the right to audit Relief
Fund recipients in the future to ensure that this requirement is met and collect any Relief Fund
amounts that were made in error or exceed lost revenue or increased expenses due to COVID-19.
Failure to comply with the Terms and Conditions may be grounds for recoupment.

If, as a result of the sale of a practice/hospital, the TIN that received a General Distribution
payment is no longer providing health care services as of January 31, 2020, is it required to
return the General Distribution payment? (Added 5/19/2020)
Yes. If, as a result of the sale of a practice/hospital, the TIN that received a General Distribution
payment did not provide diagnoses, testing, or care for individuals with possible or actual cases
of COVID-19 on or after January 31, 2020, the provider must reject the payment. The CARES
Act Provider Relief Fund Payment Attestation Portal will guide you through the attestation
process to reject the payment.

An organization purchased a practice during or after the year of the organization’s most
recent tax filing and the purchased practice’s revenues are not reflected in the most recent
tax return. How does the organization account for these acquisitions when submitting
revenue information in the Payment Portal? (Added 5/19/2020)
An organization’s adjusted gross receipts should be calculated as gross receipts as shown on the
organization’s most recent tax return plus gross receipts of the practice acquired not reflected in
the organization’s tax return minus gross receipts of providers sold not reflected in the
organization’s tax return. If an organization’s adjusted gross receipts exceed the gross receipts
shown in the tax return by more than 20%, the organization is eligible to enter the adjusted gross
receipts figure in the Provider Relief Fund Payment Portal. Otherwise, the organization should
enter the gross receipts figure as shown on the tax return. Organizations that have already
submitted an application in the Payment Portal can resubmit a revised application using the
adjusted gross receipts number accounting for acquisitions, if the adjusted gross receipts exceeds
the gross receipts shown in the tax return by more than 20%. Gross receipts of acquired entities
that provide care as of January 31, 2020 and file their own tax returns cannot be included in such
adjusted gross receipts figure, because they should submit their own application as tax return
filers.

Can an organization that sold its only practice or facility under a change in ownership in
2019 and is no longer providing services, accept payment and transfer it to the new owner?
(Added 5/19/2020)
No. A provider that sold its only practice or facility must reject the Provider Relief Fund
payment because it cannot attest that it was providing diagnoses, testing, or care for individuals
with possible or actual cases of COVID-19 on or after January 31, 2020, as required by the
Terms and Conditions. Seller organizations should not transfer a payment received from HHS to
another entity. If the current TIN owner has not yet received any payment from the Provider
Relief Fund, it may still receive funds in other distributions.

Can a provider that purchased a TIN in 2019 accept a Provider Relief Fund payment from
a previous owner and complete the attestation for the Terms and Conditions? (Added
5/19/2020)
No. The new TIN owner cannot accept the payment from another entity nor attest to the Terms
and Conditions on behalf of the previous owner in order to retain the Provider Relief Fund
payment. If the new TIN owner did not receive a direct payment under the General Distribution,
it is not eligible to receive a payment under the General Distribution. However, the new TIN
owner may still receive funds in other distributions.

In the case of a merger of a provider entity (billing TIN) into another entity (billing TIN),
or the consolidation of two or more entities (each with a billing TIN), resulting in the
creation of a new entity (single billing TIN) between January 1, 2018 through January 31,
2020, how should the entities apply? (Added 5/20/2020)
If the non-surviving entity (billing TIN) received a General Distribution payment but was not
providing diagnoses, testing, or care for individuals with possible or actual cases of COVID-19
on or after January 31, 2020, that provider must reject the General Distribution payment. If the
surviving entity (billing TIN) received a General Distribution payment, it should accept the
payment and submit its adjusted gross receipts if its adjusted gross receipts exceed the gross
receipts shown in the tax return by more than 20% in the Provider Relief Fund Payment Portal to
be considered for additional Provider Relief Fund payments.

How should an organization currently undergoing a change in ownership to purchase a

practice report revenue in its application? (Added 5/20/2020)
Until the purchase is complete, the organization should only report current gross receipts in its
application and should exclude the practice it is intending to purchase. Any changes in
ownership that have not occurred should not be included in your revenue submission.
Submissions must be based on the organization that exists at the time of application, not a
projection of expected lost revenue from the practice that is being acquired.

An organization that sold part of a practice in 2019 or January 2020 received a payment
under the General Distribution that reflected the 2019 Medicare fee-for-service billing of
that part of the practice. Can it return a portion of the payment for the part of the
practice it no longer owns? (Added 5/20/2020)
No. A provider may not return a portion of a Provider Relief Fund payment. If a provider that
sold a practice that was included in its most recent tax return gross receipts or sales (or program
services revenue) figure, can attest to meeting the Terms and Conditions, it may accept the funds.
The Terms and Conditions place restrictions on how the funds can be used. In particular, all
recipients will be required to substantiate that these funds were used for increased healthcare-
related expenses or lost revenue attributable to coronavirus, and that those expenses or losses
were not reimbursed from other sources and other sources were not obligated to reimburse them.
Generally, if a provider anticipates that its COVID-related lost revenues or increased expenses
will be materially less than the value of the Provider Relief Fund payment received, the provider
should reject the entire General Distribution payment and submit the appropriate revenue
documents through the General Distribution portal to facilitate HHS determining their correct
payment.

A new organization that did not bill Medicare fee-for-service in 2019, and thus did not
receive a payment under the General Distribution, purchased in 2019 or January 2020 all
or part of a practice (i.e., a full or partial change in ownership) that did bill Medicare fee-
for-service in 2019. Can the new organization submit documentation through the Provider
Portal to receive payment? (Added 5/21/2020)
If a provider that purchased a practice or facility in 2019 or January 2020 did not bill Medicare
fee-for-service in 2019 and did not receive any Provider Relief Fund payment, it is not eligible
for payments under the General Distribution and may not submit its gross revenue receipts in the
Provider Relief Fund Payment Portal. However, the provider may still receive funds in future
distributions.

A parent entity submitting an application for a General Distribution payment from the $20
billion payment tranche has more than 20 subsidiaries with Billing TINs. How should it
complete the application in the Provider Relief Fund Payment Portal? (Added 5/20/2020)
The parent entity should attach and submit a statement as the first page of the uploaded tax return
file indicating any additional billing TINs not previously entered into the application forms as
well as the Provider Relief Fund payments that these billing TINs received.

Can an organization that received a General Distribution payment and provided care on or
after January 31, 2020 that sold, terminated, transferred, or otherwise disposed of a
provider accept the General Distribution payment (received via ACH or check) associated
with the sold provider? (Added 5/21/2020)
If an organization that sold, terminated, transferred, or otherwise disposed of a provider that was
included in its most recent tax return gross receipts or sales (or program services revenue) figure
can attest to meeting the Terms and Conditions, it may accept the funds. The Terms and
Conditions place restrictions on how the funds can be used. In particular, all recipients will be
required to substantiate that these funds were used for increased healthcare-related expenses or
lost revenue attributable to coronavirus, and that those expenses or losses were not reimbursed
from other sources and other sources were not obligated to reimburse them. Generally, if a
provider anticipates that its COVID-related lost revenues or increased expenses will be
materially less than the value of the General Distribution payments received, the provider should
reject the payment and submit its adjusted gross receipts in the Provider Relief Fund Payment
Portal.

A parent entity files a tax return (“Filing TIN”) but does not bill Medicare. The parent
entity has one or more subsidiaries that bill Medicare (“Billing TIN”) but do not file tax
returns (disregarded or consolidated entities). Accordingly, the parent entity did not
receive a payment under the $30 billion General Distribution and entering the parent’s
Filing TIN does not allow the Provider Payment Portal application to proceed. How should
this be addressed with respect to the application? (Added 5/21/2020)
The parent entity should complete an application by listing the Billing TINs of the respective
subsidiaries without entering its own Filing TIN. In the application, the parent entity should enter
the sum of all “gross sales or receipts” or “program service revenue” of all subsidiary entities with
Billing TINs in the applicable field in the application form. Further, the parent entity should submit
a statement on the first page of the uploaded tax return file stating (i) the parent entity’s Filing TIN
and that it does not bill Medicare and (ii) a schedule of the billing subsidiaries, their Billing TINs,
and gross sales or receipts.

Can a parent organization transfer Provider Relief Fund payments to its subsidiaries?
(Added 5/21/2020)
Yes, a parent organization can accept and allocate funds at its discretion to its subsidiaries. The
Terms and Conditions place restrictions on how the funds can be used. In particular, the parent
organization will be required to substantiate that these funds were used for increased healthcare-
related expenses or lost revenue attributable to COVID-19, and that those expenses or losses
were not reimbursed from other sources and other sources were not obligated to reimburse them.

A vertically-integrated organization has both patient care revenues as well as revenues that
are not directly related to patient care (e.g. insurance, retail, real estate). How should this
scenario be addressed with respect to the application? (Added 5/21/2020)
The applying organization should complete an application by listing the Billing TINs of the
eligible subsidiaries that provide or provided after January 31, 2020, diagnoses, testing or care
for individuals with possible or actual cases of COVID-19. In the application, the parent entity
should enter the sum of all “gross sales or receipts” or “program service revenue” of all eligible
subsidiary entities that provide or provided after January 31, 2020, diagnoses, testing or care for
individuals with possible or actual cases of COVID-19 and enter the subsidiaries’ Billing TINs in
the applicable fields in the application form. Further, the parent entity should submit a statement
on the first page of the uploaded tax return file stating (i) the parent entity’s Filing TIN and (ii) a
schedule of the eligible subsidiaries, their Billing TINs, and gross sales or receipts. Any revenues
from subsidiaries that are not directly providing diagnoses, testing, or care for individuals with
possible or actual cases of COVID-19 may not be included.

How does HHS calculate who gets specific amounts of funding?

HRSA distributed the initial $30 billion in Provider Relief funds in proportion to a provider’s
2019 Medicare Fee for Service billings. A description of the allocation methodologies is
provided here.

Are hospitals and health systems in all states and territories eligible?
Yes.

If a provider owns several hospitals, can the provider retain the funds or must the provider
distribute the funds throughout their system? (Added 5/12/2020)
The Provider Relief Fund payment recipient has discretion in allocating the Provider Relief
funds to support health care related expenses or lost revenue attributable to COVID-19, so long
as they are not reimbursed from other sources and other sources were not obligated to reimburse
them.
Payment Portal

Why does the General Distribution website say I have to attest before requesting additional
funds?
The CARES Act requires that providers meet certain terms and conditions to receive Provider
Relief Funds. In order to keep the initial General Distribution payment, and in order to be
eligible to receive additional General Distribution funds, you must attest that you meet these
terms and conditions and you must submit your financial and tax information.

Why do I need to upload my tax forms?

The $50 billion general allocation is apportioned based on provider revenue. Tax forms are
needed to ascertain and confirm provider revenue.

What documents do I need to begin entering in the payment portal?

1. TIN that received prior Provider Relief Fund payments
2. TIN(s) of subsidiary organizations that received prior Provider Relief Funds but do not
file separate tax forms (i.e., subsidiary organizations that are accounted for in the parent
organization’s tax filing)
3. Amount of payments received
4. Relief Fund payment transaction numbers / check numbers
5. A copy of your most recently filed tax forms

Who is eligible to receive additional payments through the Provider Relief Fund Payment
Portal?
Any provider who received a payment from the Provider Relief Fund as of 5:00 pm EST Friday,
April 24, 2020 can apply for additional funding via the Provider Relief Fund Payment Portal.

Providers who have not received funding as of 5:00 pm EST Friday April 24, 2020 are not
eligible to use the Provider Relief Fund Payment Portal. However these providers may still be
eligible for payments from the Provider Relief Fund through other mechanisms, including the
Targeted Distributions.

What information is HHS collecting in the Provider Relief Fund Payment Portal?
The Provider Relief Fund Payment Portal has been deployed to collect information from
providers who received General Distribution payments prior to April 24, 2020 at 5:00 pm EST.

The Provider Relief Fund Payment Portal collects four pieces of information to allocate
remaining General Distribution funds:

1) a provider’s “Gross Receipts or Sales” or “Program Service Revenue” as submitted on

its federal income tax return;
2) the provider’s estimated revenue losses in March 2020 and April 2020 due to COVID;
3) a copy of the provider’s most recently filed federal income tax return;
4) a listing of the TINs for any of the provider’s subsidiary organizations that received
relief funds but DO NOT file separate tax returns.

This information may also be used to allocate other Provider Relief Fund distributions.
HHS is collecting: the “gross receipt or sales” or “program service revenue” data to have an
understanding of a provider’s usual operations; the revenue loss information to have an
understanding of COVID impact; and, tax forms to verify the self- reported information. HHS is
collecting information about organizational structure and subsidiary TINs so that we do not
overpay or underpay providers who file tax returns covering multiple legal entities (e.g.
consolidated tax returns).

Providers meeting the following criteria are required to submit a separate portal application:
(a) Provider has received Provider Relief Fund payments as of 5:00pm EST Friday April 24,
2020 AND
(b) Provider has filed a federal income tax return for 2017, 2018, or 2019.

As such, each entity that files a federal income tax return is required to file an application even if
it is part of a provider group. However, a group of corporations that files one consolidated return
will have only the tax return filer apply.
Each provider submitting an application is required to list the TINs of each subsidiary that (a) has
received Provider Relief Fund payments as of 5:00 EST Friday April 24, 2020 AND (b) has not
filed federal income tax returns for 2017, 2018, or 2019.

Do not list any subsidiary’s TIN that has filed a federal income tax return, because such
subsidiary is required to submit a separate application.

For example:

1) A parent entity and two subsidiaries received Provider Relief Fund payments. The
parent filed a federal income tax return, but the two subsidiaries did not as they are
consolidated with the parent.

The parent should submit an application and list the subsidiary TINs therein. The
subsidiaries cannot submit an application as they did not file a tax return.

2) A parent entity and two subsidiaries A and B received Provider Relief Fund
payments. The parent and subsidiary A filed a federal income tax return, but the
subsidiary B did not as it is consolidated with the parent.

The parent and subsidiary A should submit separate applications. The parent would list
the TIN subsidiary B in its application.

What information do I need before I start the application process?

 Eligibility
To enter the Provider Relief Fund Payment Portal you must meet two criteria:
1. You must have already received a Provider Relief Fund Payment by 5:00 pm EST,
Friday April 24, 2020
2. You must attest to having received the payment via the Provider Attestation Portal, and
you must agree to the Terms and Conditions on the attestation portal.
 Data
Before you initiate your application via the Provider Relief Fund Payment Portal, please
collect the following data
1. The Taxpayer Identification Number for the organization applying for Provider Relief
funds. (“Application TIN”)
2. The Taxpayer Identification Number(s) of any subsidiary organizations if and only if
those organizations do not file separate tax returns, but rather consolidate into the returns
of the “Application TIN”. If your organization has subsidiaries that file separate tax
returns, a separate application must be made for each subsidiary that files a separate
return.
3. An estimate of the organization’s lost revenue for March 2020 and April 2020. Lost
revenue can be estimated by comparing year-over-year revenue, or by comparing
budgeted revenue to actual revenue. For April 2020, an estimate of the total monthly
loss based on data from the first few weeks in April or by extrapolation from March data
is acceptable.
4. A copy of the most recent tax form filed by the organization associated with
the Application TIN.

Who should fill out this form?

Any person authorized by the provider organization may complete this form. We recommend it
be completed by an organization’s corporate office, specifically, the CFO or other accounting
professional.

Will I be penalized if I take several days to collect the necessary information?

No. HHS will be processing applications in batches every week. Funds will not be disbursed on a
first-come-first-served basis, which is to say, an applicant will be given equal consideration
regardless of when they apply.

Why does the website say my TIN is not eligible?

HHS is collecting tax and financial loss data from providers who have already received
payments under the General Distribution. If you have not already received a Provider Relief
Fund payment you are not eligible to submit your tax and financial loss information to the
Provider Relief Fund Payment Portal. However, this does not mean that you are ineligible for
forthcoming Provider Relief funds.

If you received a General Distribution payment by 5:00 pm EST, Friday April 24, 2020 and are
being told that your TIN is ineligible, please check to see if you entered your TIN correctly and
check to see that the TIN matches the TIN for the organization that received a Provider Relief
Fund payment.

Are Tax ID’s that did not receive initial General Distribution payment eligible?
Organizations that have not received any General Distribution payments as of April 24, 2020
may be eligible for relief funds in future distributions. The Provider Relief Fund Payment Portal
is only collecting tax IDs from providers who have received a General Distribution payment.

What is a Federal Tax Classification?

The Federal Tax Classification describes the type of tax filer that the applicant is for purposes of
the applicant’s federal income tax return with the IRS, for example Partnership or S Corporation.
How do I know if I’m a sole proprietor/disregarded entity? C Corporation? S
Corporation? Partnership? Trust? Tax-Exempt Organization?
The answer is determined by the type of the applicant’s entity and any tax elections the applicant
has made.

Which tax form did the applicant file for the most recent year?
• Form 1040 The applicant is a sole proprietor or provides services as the sole member
of an LLC.
• Form 1065 The applicant is a partnership.
• Form 1120 The applicant is a C corporation.
• Form 1120-S The applicant is an S corporation.
• Form 990 The applicant is a tax-exempt organization.
• Form 1041 The applicant is a trust.

Which type of supporting documentation should I submit if I am an institution without IRS

filings? (Added 5/14/2020)
All providers that have filed tax returns in 2019 or 2018 should submit the filings as supporting
documentation. If a particular healthcare provider has a legitimate reason (e.g. tax exempt) for
not having IRS filings, then alternative financial statements are acceptable. If the entity is tax
exempt, the entity should use Net Patient Revenues from its most recent audited annual financial
statements as a substitute for “Program Services Revenue” when prompted. Further, the entity
should submit its most recent audited financial statements as a substitute for the federal income
tax return Form 990 requested.

Where do I find my Gross Receipts or Sales?

 • Form 1040 Box 1 of Schedule C
• Form 1065 Box 1a
• Form 1120 Box 1a
• Form 1120-S Box 1a
• Form 990 Use Part I, 9 “Program Services revenue”
• Form 1041 Box 1 of Form 1040 Schedule C
[Note: you use a Form 1040 Schedule C also for Form 1041]

Which information should be submitted in the Provider Relief Fund Payment Portal by a
state-run entity (e.g. state university medical center) that has no parent organization that
files a federal income tax return?
The applying state entity should select “Tax-Exempt Organization” in the dropdown menu for
“Federal Tax Classification.” The state entity should use Net Patient Revenues from its most
recent audited annual financial statements as a substitute for “Program Services Revenue”.
Further, the state entity should submit its most recent audited financial statements as a substitute
for the federal income tax return Form 990.

How do I estimate lost revenue in March or April?

You may use a reasonable method of estimating the revenue during March and April compared
to the same period had COVID-19 not appeared. For example, if you have a budget prepared
without taking into account the impact of COVID-19, the estimated lost revenue could be the
difference between your budgeted revenue and actual revenue. It would also be reasonable to
compare the revenues to the same period last year.

Why is the Provider Relief Fund Payment Portal asking for Gross Receipts or Sales?
HHS is asking for Gross Receipts because it is a measure of revenues you received during the
applicable filing period.

Why is the Provider Relief Fund Payment Portal asking me to estimate my revenue? HHS
realizes that a final revenue number may not be available until a certain time after the end of
April. As the program seeks to provide liquidity support to the healthcare system in a timely
manner we are using estimated revenues.

Where do I find program service revenue if I am a tax exempt organization?

Box 9 of the Form 990.

Do I submit 2019 or 2018 forms?

Submit the most recent form that you have filed with the IRS (typically 2017, 2018 or 2019).

What if I haven’t filed taxes for the year being requested?

If you are required to, but have not filed a tax return in 2017 or 2018, you are ineligible to apply.
You should file the applicable tax return and then re-apply.

If I have more than one Tax ID but I either have not attested or did not receive payments
on some or all of them, am I eligible?
You must attest for all payments received to be eligible for additional General Distribution
funding. You are only eligible to apply for additional funding through the Provider Relief Fund
Payment Portal if you have TINs that have received prior relief fund payments. Fill out one
application for each eligible TIN that has received a Provider Relief Fund payment and for which
there is a corresponding tax filing. If you are a subsidiary of a tax filing organization, and do not
file a separate tax return, you are ineligible to apply for additional funds.
Where do I find my Medicare ID?
Providers may find their Medicare ID number by logging into the Medicare Provider Enrollment,
Chain, and Ownership System (PECOS).

What is a CAQH Provider ID? Where do I find it?

Council for Affordable Quality Healthcare (CAQH) Provider ID number is the unique identifier
assigned to each CAQH ProView user at the time of registration. If you have been invited to join
CAQH ProView by a health plan, hospital or other participating organization, you may have
received a welcome letter with your CAQH Provider ID Number. New users also have the option
to self-register through the CAQH ProView Provider portal: https://proview.caqh.org/pr. Upon
completion of the self-registration process, users will receive a welcome email with their unique
CAQH Provider ID Number.

How many requests should I make?

You may make one request for each TIN that has received prior Provider Relief Fund payments.
Determining Additional Payments

How can I estimate the total payment amount I can anticipate through the General
Distribution? (Added 5/14/2020)
In general, providers can estimate payments from the General Distribution of approximately 2%
of 2018 (or most recent complete tax year) patient revenue. To estimate your payment, use this
equation:

(Individual Provider Revenues/$2.5 Trillion) X $50 Billion = Expected Combined General

Distribution.

To estimate your payment, you may need to use “Gross Receipts or Sales” or “Program Service
Revenue.” Providers should work with a tax professional for accurate submission.

This includes any payments under the first $30 billion general distribution as well as under the $20
billion general distribution allocations. Providers may not receive a second distribution payment if
the provider received a first distribution payment of equal to or more than 2% of patient revenue.

How long does it take for HHS to make a decision on additional General Distribution
funding? When can I expect to receive additional funds? (Modified 5/29/2020)
ForHHS is working to process all providers submitting tax and financial loss information, HHS
intends to distribute additional funds within 10 business days of the submission’ submissions as
quickly as possible. HHS is distributing an additional $20 billion of the General Distribution to
providers to augment their initial allocation so that $50 billion is allocated proportional to
providers' share of 2018 net patient revenue. Payments are determined based on the lesser of 2%
of a provider’s 2018 (or most recent complete tax year) net patient revenue or the sum of
incurred losses for March and April. If after further review of your resubmitted revenue
information, the initial General Distribution payment you received between April 10 and April 17
was determined to be at least 2% of your annual patient revenue, you may not receive additional
General Distribution payments. It is the Department’s intention to distribute relief funds as
quickly as possible.

How do I find out if my funding request was not approved?

If you have attested and submitted tax forms and loss estimates, you should receive a payment or
other response within 10 business days.
How will HHS notify me that my application has been processed? (Modified 5/29/2020)
You will receive an email when your application is completed. You will receive noa notification
from HHS as to the final status of your application once submitted. You should expect. HHS is
distributing an additional funds, if you are to receive any, within 10 business days of completing
your application.

How will HHS notify me if they need additional information?$20 billion of the General
Distribution to providers to augment their initial allocation so that $50 billion is allocated
proportional to providers' share of 2018 net patient revenue. Payments are determined based on the
lesser of 2% of a provider’s 2018 (or most recent complete tax year) net patient revenue or the sum
of incurred losses for March and April. If additional information is requested, HHS will use the
email address used to access the Provider Relief Fund Payment Portal.

When can I expect to receive additional funds?

Funds should be disbursed within 10 days of the submission of your application.after further
review of your resubmitted revenue information, the initial General Distribution payment you
received between April 10 and April 17 was determined to be at least 2% of your annual patient
revenue, you may not receive additional General Distribution payments.

Data Sharing

Why am I being redirected to DocuSign to fill out certain elements?

HHS is using DocuSign to securely pass encrypted data to HHS. Neither DocuSign nor
UnitedHealth Group will have access to your data.
What is DocuSign doing with my data?
DocuSign is securely passing your data to HHS in encrypted files. Neither DocuSign nor
UnitedHealth Group will have access to your data.

What information is shared with UnitedHealth Group, UnitedHealthcare, Optum, or any

other subsidiary of UnitedHealth Group?
UnitedHealth Group and its subsidiaries will not have access to any information collected from
providers, nor do they participate in determining the methodology used to allocate Provider
Relief Fund payments. UnitedHealth Group will know the amounts of relief funding paid to
providers, as UnitedHealth Group is processing the payments.

Who has access to my revenue data?

HHS will have access to your revenue data to optimally allocate Provider Relief Funds. HHS will
not share your revenue data with any other entities, in or outside of government, except as
prescribed by law.

Targeted Distribution FAQs

Rural Targeted Distribution

What was the formula used to make the Rural Distribution payment to rural hospitals?
(Added 5/12/2020)
Rural Distribution payments were made to rural acute care general hospitals and Critical Access
Hospitals (CAHs), Rural Health Clinics (RHCs), and Community Health Centers located in rural
areas. Hospitals and RHCs will each receive a minimum base payment plus a percent of their
annual expenses. This method accounts for operating cost and lost revenue incurred by rural
hospitals for both inpatient and outpatient services. The base payment will account for RHCs
with no reported Medicare claims, such as pediatric RHCs, and CHCs lacking expense data, by
ensuring that all clinical, non-hospital sites receive a minimum level of support no less than
$100,000, with additional payment based on operating expenses. Rural acute care general
hospitals and CAHs will receive a minimum level of support of no less than $1,000,000, with
additional payment based on operating expenses.

Is it accurate that rural hospitals would receive 4% of operating expenses from the Rural
Distribution? What year’s Medicare cost report was used? (Added 5/12/2020)
Rural hospitals received a graduated base payment plus approximately 2% of total operating
expenses reported on their most recent, publicly available cost reports. The base payment
gradually increases from $1 to $3 million depending on hospital operating expenses and
establishes a floor for rural hospitals to support their financial stability during the COVID-19-
pandemic. The additional amount is a percentage of each individual hospital’s total operating
expenses so that payments are related to the actual operating expenses that rural hospitals are
incurring. Worksheet G-3, Line 4 of the Medicare hospital cost report was used for total
operating expenses. If cost reports were more or less than a year in length, then total operating
expenses were adjusted to reflect a full year.
Will the Rural Distribution include urban health care hospitals that have obtained
classifications as rural facilities under a 42 CFR 412.103 exception? (Added 5/12/2020)
No. Eligibility for Rural Distribution payments is limited to rural acute care general hospitals,
Critical Access Hospitals (CAHs), Rural Health Clinics (RHCs), and Community Health
Centers that are located in a rural area as defined by HHS’s Federal Office of Rural Health
Policy. The 42 CFR 412.103 exception hospitals include a significant number of very large
urban facilities. The Rural Distribution payments focused on smaller rural hospitals that are
struggling to remain financially viable.

How were rural providers identified for the Rural Distribution? (Added 5/14/2020)
Rural facilities were identified based on their provider type and the physical addresses of the
hospital or clinic site as reported to CMS for rural acute care general hospitals, critical access
hospitals (CAHs), and independent rural health clinics (RHCs), and to HRSA for Community
Health Centers, regardless of affiliation with organizations based in urban areas. HHS used
the December 2019 CMS Provider of Services file to identify hospitals, CAHs, and RHCs.
Due to data constraints, facilities that were not included in the December 2019 Provider of
Services file were not included in the Rural Distribution.

How does HHS define rural for these payments? (Added 5/12/2020)
For the Rural Distribution, HHS used the Federal Office of Rural Health Policy’s definition of
rural, which includes:
1. All non-Metro counties.
2. All Census Tracts within a Metropolitan county that have a Rural-Urban Commuting
Area (RUCA) code of 4-10. The RUCA codes allow the identification of rural Census
Tracts in Metropolitan counties.
3. 132 large area census tracts with RUCA codes 2 or 3. These tracts are at least 400 square
miles in area with a population density of no more than 35 people per square mile.

Did both freestanding and provider-based rural health clinics receive funding under the
Rural Distribution? (Added 5/14/2020)
If the RHC is owned by a rural hospital or CAH, the hospital received the payment. Rural
hospitals that own RHCs (also known as provider-based RHCs) report their RHCs’ operating
expenses as part of the hospital cost report. Since provider-based clinics operate under the
ownership and administrative and financial control of the hospital, the RHC expenses are
included in the base payments and additional payments calculated for the rural hospital. These
provider-based RHCs did not receive separate payments. Urban hospitals did not receive Rural
Distribution payments and neither did provider-based RHCs. If the RHC is a freestanding,
independent facility, then it received the payment directly.

Which rural providers received a payment under the Rural Distribution? (Added
5/14/2020)
Rural Distribution funding is targeted at organizations that provide acute and primary care in
rural areas. Acute care hospitals in rural areas and Critical Access Hospitals (CAHs) in rural
areas and non-rural areas are eligible for Rural Provider Relief funding. CAHs outside of rural
areas are included in the rural provider distribution because CAHs have a unique safety net role
and statutory charge. That statute also initially gave state governors the authority to designate
necessary provider CAHs, a number of which did not make a distinction between rural and
urban designations.

In addition to hospitals, the following types of organizations received payments: freestanding

(not provider-based) Rural Health Clinics (RHCs) and Community Health Centers. For provider-
based RHCs, RHC funds were distributed through the rural hospital and CAH allocation.

Which data sources did you use for operating costs for hospitals, rural health clinics, and
other facility types? How recent was the data used? (Added 5/14/2020)
HHS analyzed the following files to identify facility locations and operating costs:
 Provider of Services Files, December 2019 update, https://www.cms.gov/Research-
Statistics-Data-and-Systems/Downloadable-Public-Use-Files/Provider-of-Services/index
 Healthcare Cost Report Information System (HCRIS), 1/17/2020 update,
https://www.cms.gov/Research-Statistics-Data-and-Systems/Downloadable-Public-Use-
Files/Cost-Reports contains the most recent cost report data available. For most hospitals,
this is the 2018 fiscal year. We used hospital data from 2016 to replace missing data for
two hospitals and 2017 data for 16 hospitals.
 The HRSA Bureau of Primary Health Care extracted data from the most recent Uniform
Data System (UDS) to identify rural Community Health Center sites.

Our hospital’s operating costs have gone up dramatically in recent months after COVID-19
started. Will our increased operating costs be reflected in the Rural Distribution formulas?
(Added 5/14/2020)
No. Rural provider allocations are based on historical operating expense data to enable rapid
distribution of funds to meet immediate rural needs.

How were facilities identified for the Rural Distribution? (Added 5/20/2020)
Facilities were identified from the December 2019 CMS Provider of Services file. Due to data
constraints, facilities that were not included in the December 2019 Provider of Services file were
not included in this rural allocation.

High- Impact Area Targeted Distribution

Why is HHS targeting these hospitals for COVID-19 High Impact Area funding? (Added
5/12/2020)
In allocating the funds, the Administration is working to address both the economic harm across
the entire healthcare system due to COVID-19 and the economic impact on providers directly
treating patients with COVID-19. The distribution takes into consideration the challenges faced
by facilities serving a significantly disproportionate number of low-income patients and that
inpatient admissions are a primary driver of costs to hospitals related to COVID-19.
How were COVID-19 High Impact Area funds allocated? (Added 5/12/2020)
Of the $12 billion distribution, $10 billion was allocated based on a fixed amount per COVID-19
inpatient admission. The remaining $2 billion of the $12 billion was distributed based off each
hospital’s portion of Medicare Disproportionate Share Hospital (DSH) payments and Medicare
Uncompensated Care Payments (UCP).
How many payments did HHS make under the COVID-19 High Impact Area Distribution?
(Added 5/12/2020)
HHS made 336 COVID-19 High Impact Area Distribution payments to 395 hospitals and health
systems that provided inpatient care for 100 or more COVID-19 patients through April 10, 2020.
Some payments were made to hospitals and health systems that operate more than one hospital.

Should providers continue to update their high- impact data? (Modified 5/19/2020)
Providers should update their capacity and COVID-19 census data to ensure that HHS can make
timely payments in the event that the provider becomes a high-impact provider. Providers can
continue to update their information through the same method they used previously.

How were COVID-19 High Impact Area payments distributed? (Added 5/12/2020)
HHS partnered with UnitedHealth Group to deliver funds. Payment were sent via Automated
Clearing House (ACH). The automatic payments were sent via Optum Bank with “CARES Act
HighImpactAreaPmt*HHS.GOV” in the payment description. Payments were sent to the group’s
central billing office. All relief payments were made to provider billing organizations based on
their TINs.

Why was April 10 chosen for providers to submit data on COVID-19 admissions? (Added
5/29/2020)
In order to allow HHS to calculate and make payments in a fair, transparent, and timely manner
based on submitted COVID-19 admissions data, the Department selected April 10 as the cut-off
for the COVID-19 High Impact Area distribution.

Will areas with emerging or future COVID-19-positive cases have an opportunity to apply
for a High Impact Area distribution? (Added 5/29/2020)
HHS may make additional COVID-19 High Impact Area distributions. If HHS decides to make
an additional distribution, the Department will announce any additional COVID-19 High Impact
Area distributions in advance and give a deadline and method for providing updated data.

What was the rationale behind requiring at least 100 COVID-19 admissions to be eligible
for this payment? (Added 5/29/2020)
HHS used COVID-19 admissions as a proxy for the extent to which each facility experienced
lost revenue and increased expenses associated with directly treating a substantial number of
COVID-19 inpatient admissions. The hospitals that received COVID-19 High-Impact Area
distributions encountered, in the aggregate, 129,911 admissions, or over 70% of the total number
of COVID-19 inpatient admissions reported by April 10, 2020.

Skilled Nursing Facilities Distribution

What is the Skilled Nursing Facility funding amount and how did HHS determine the
amount? (Added 5/26/2020)
HHS will distribute $4.9 billion in additional funding (over and above General Distributions
received) to more than 13,000 skilled nursing facilities. Eligible facilities range in size of
between six and 1,389 beds. This represents a range of distributions between $65,000 and
$3,255,500 and a national average distribution of ~$315,600 per facility. Each Skilled
Nursing Facility received a fixed distribution per facility of $50,000 plus distribution of
$2,500 per bed.
Which Skilled Nursing Facility providers received a payment under the SNF Distribution?
(Added 5/26/2020)
HHS allocated funding for certified Skilled Nursing Facilities with a capacity between six and
1,389 beds.

How will HHS disperse the Skilled Nursing Facility distribution payments? (Added
5/26/2020)
Most SNF fund payments will be dispersed electronically based upon banking account
information associated with the organization’s billing TIN. If the organization’s billing TIN
does not have a bank routing number associated with it, the organization will most likely receive
a paper check.

Indian Health Service Distribution

Which Indian Health Service (IHS) providers received a payment under the IHS
Distribution? (Added 5/29/2020)
HHS allocated funding for IHS, Tribal, and Urban Indian Health programs. This includes IHS
and Tribal hospitals.

How was IHS Distribution funding allocated across eligible entities? What was the
formula used to make the IHS Distribution payment to IHS providers? (Added 5/29/2020)
HHS allocated $500 million to IHS, Tribal, and Urban Indian Health programs. Approximately
4% of the $500 million in available funding was allocated for Urban Indian Health programs,
consistent with the percent of patients served by Urban Indian Organizations (UIOs) in relation
to the total IHS active user population, as well as prior allocations of IHS COVID-19 funding.
IHS divided remaining funding equally between hospitals (48%) and clinics (48%).

HHS used different formulas for each of the different facility types.
 IHS Hospitals and Tribal Hospitals
o Per hospital allocation = $2. 815 million base + (Total Operating expenses *
3%)
 IHS and Tribal Clinics/Programs
o Per IHS clinic allocation = Base amount of $187,000 + 5% of (estimated service
population * average cost per user)
 IHS Urban Programs
o Per IHS Urban Indian health allocation = Base amount of $181,250 + 6% of
(estimated service population * average cost per user)

Which data sources did HHS use for operating costs for IHS and tribal hospitals? How
recent was the data used? (Added 5/29/2020)
HHS analyzed the following files to determine the allocation for IHS Distribution to IHS and
tribal hospitals:
 Provider of Services Files, December 2019 update.
 Healthcare Cost Report Information System (HCRIS), 1/17/2020 update, contains the
most recent cost report data available. For most hospitals, this is the 2018 fiscal year.
 Total operating expenses are reflected in Worksheet B PART I COL 26 of the cost report.
How did HHS determine operating costs for IHS clinics and Urban Indian Health
Organizations? (Added 5/29/2020)
HHS identified the service population for most service units, and estimated an operating cost of
$3,943 per person per year based on actual IHS spending per user from a 2019 IHS Expenditures
Per Capita and Other Federal Health Care Expenditures Per Capita.

How will payments be distributed? (Added 5/29/2020)

HHS is partnering with UnitedHealth Group to deliver funds. Each organization’s payment will
be sent via Automated Clearing House (ACH). The automatic payments are sent via Optum
Bank with “CARES Act Tribal&IndianHlthPmt*HHS.GOV” in the payment description.
Payments are sent to the group’s central billing office. All relief payments are made to provider
billing organizations based on their Taxpayer Identification Numbers (TINs).