Provider Relief Fund attestation deadline approaching
Group practices who received a payment from the Department of Health and Human Services (HHS) under the Provider Relief Fund must sign an attestation confirming receipt of funds and agreeing to conditions of payment within 45 days of payment. That means groups who received funding from the initial distribution on April 10 have until May 24 to attest. Notably, not returning the payment within 45 days of receipt will be viewed as acceptance of the funds and associated terms and conditions.
HHS also announced this week that providers have until June 3 to submit revenue information to be considered for an additional payment from the $50 billion general distribution. While HHS automatically disbursed payments from the first tranche ($30 billion) starting on April 10, most group practices must submit a request to receive additional funds from the second tranche ($20 billion).
Finally, HHS updated and clarified FAQs on the Provider Relief Fund general distribution. With the Department updating their FAQs and website periodically without any formal announcement or notification, MGMA recommends that group practices review this new guidance. See MGMA’s resource on financial relief programs for more information.
SBA releases PPP loan forgiveness application
The Small Business Administration (SBA) released an application for Paycheck Protection Program (PPP) borrowers to submit to their lenders when seeking loan forgiveness. The application includes:
- Instructions on how to perform calculations for loan forgiveness;
- A list of documents borrowers must submit with the PPP loan forgiveness application;
- Confirmation that eligible nonpayroll costs still cannot exceed 25% of the total forgiveness amount;
- A newly created “Alternative Payroll Covered Period” for borrowers with biweekly (or more frequent) pay periods, which would allow the eight-week Covered Period to begin on the first day of the first pay period following PPP loan disbursement;
- Clarification that borrowers are generally eligible for forgiveness for payroll/nonpayroll costs paid and payroll costs incurred during the eight-week Covered Period (or Alternative Payroll Covered Period); and
- Additional FTE reduction exceptions.
While the application is helpful, it does not resolve all outstanding questions. MGMA hopes to see additional loan forgiveness guidance from SBA and will update membership on future developments.New COVID-19 resource: Maintaining cyber security while working remotely
To assist members in ensuring the security of their patient’s information when working outside their medical practice, MGMA has developed the new Maintaining Cyber Security while Working Remotely Toolkit. Home offices are increasingly being used during the COVID-19 pandemic, and they are generally more vulnerable to cyber attacks than systems located in medical offices. The resource offers action steps to ensure the physical security of devices, improve the security of your network, practical tips when working from home, and other recommendations. In addition, the toolkit outlines the recently-released guidance from the Office for Civil Rights on HIPAA enforcement discretion for telehealth.
MGMA advocates for additional relief for physician practices, ACOs
Last week, Democratic leadership in the U.S. House of Representatives introduced the ‘‘Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act,” which includes several provisions that directly pertain to medical practices. The legislation would make further amendments to the PPP, Medicare’s Advance Payment Program, and the Provider Relief Fund. While this bill is not expected to pass due to lack of bipartisan support, MGMA offered several key recommendations for consideration as Congress works to come to a bipartisan agreement.
Additionally, MGMA and other industry-leading associations have urged the Centers for Medicare & Medicaid Services (CMS) to provide flexibility for practices participating in a Medicare accountable care organization (ACO) and to protect them from potentially harmful losses created by the COVID-19 pandemic. Specifically, MGMA called on CMS to:
- Adopt a policy to give ACOs an option to be protected from losses in exchange for a reduced shared savings rate, no less than 40%;
- Extend the current June 1 Medicare Shared Savings Program (MSSP) deadline to voluntarily terminate to avoid financial losses to no earlier than Oct. 31;
- Reverse its decision to cancel the 2021 MSSP application cycle; and
- Pay ACO shared savings payments and advanced alternative payment model bonuses as soon as possible.