I can only say that the FAQ says to use the most recent tax return. I can't remember exactly what the Docusign prompt said, but it definitely didn't specify 2018. I suspect it doesn't make too much difference.
I believe the distribution that began on the 24th was to hospitals and others who file cost reports. I don't think HHS has published the funding forumula for others, other than saying it's based on lost revenue.
My best guess is that HHS will use the tax return as a reality check against the claimed revenue losses for March and April. If you say you lost $1 million per month in March and April, and your total revenue for whatever tax year you submit is only $2 million, you will probably go to some kind of review/reject queue.
Based on what I have seen, my GUESS is that HHS will sum up all of the accepted loss claims, divide that number by whatever portion of the $20 billion they intend to distribute based on these applications, and send EFT's for the resulting fraction of claimed losses.
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David Smith FACMPE
Executive Director
United Imaging Consultants
Mission KS
(785) 393-8387
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Original Message:
Sent: 04-27-2020 10:02
From: Keith Chew
Subject: CARES Provider Relief
This second round is for those practices that do not see any or many Medicare covered patients, thus trying to provide assistance based upon revenue loss, not losses based upon Medicare calculations/extrapolations. The reasoning behind asking for the 2018 tax return is that the 2018 return is known to be completed. The extension to file the 2019 tax return makes the certainty of the availability of that 2019 tax return questionable...... That's my insight for what its worth.....
Keith E. Chew, MHA, CMPE, FRBMA
Principal – Consulting with Integrity
18 Hawks Nest Chatham, IL 62629
217-971-5293 Direct
Original Message------
David,
It is unclear to me whether to use the most recent tax return or the 2018 tax return. The website states that this distribution is based on 2018 Net Patient Revenue.... Yet the first round was based on 2019 Medicare Fee for Service Revenue... not sure if they are doing the calcs behind the scenes and we do, as you suggest just send 2019 tax return, or if this round is based on 2018 and we should send the 2018 return. I am not sure we were right, but we submitted the 2018 return for this second round.
$50 billion general allocation
$50 billion of the Provider Relief Fund is allocated for general distribution to Medicare facilities and providers impacted by COVID-19, based on eligible providers' 2018 net patient revenue. The initial $30 billion was distributed between April 10 and April 17, and the remaining $20 billion is being distributed beginning Friday, April 24.
· To expedite providers getting money as quickly as possible, $30 billion was distributed immediately, proportionate to providers' share of Medicare fee-for-service reimbursements in 2019. On Friday, April 10, $26 billion was delivered to bank accounts. The remaining $4 billion of the expedited $30 billion distribution was sent on April 17.
· This simple formula used the data on-hand to get the money out the door as quickly as possible. The Administration was transparent and upfront additional funds would be going out quickly to help providers with a relatively small share of their revenue coming from Medicare fee-for-service, such as children's hospitals.
· HHS will begin distribution of the remaining $20 billion of the general distribution to these providers on April 24 to augment their allocation so that the whole $50 billion general distribution is allocated proportional to providers' share of 2018 net patient revenue.
· On April 24, a portion of providers will automatically be sent an advance payment based off the revenue data they submit in CMS cost reports. Providers without adequate cost report data on file will need to submit their revenue information to the General Distribution Portal for additional general distribution funds.
Thanks,
Michael W. Langenberg, FRBMA
Executive Director for University Radiology
2240 Sutherland Ave Ste 107
Knoxville, TN 37919
(865) 803-2973 (Cell)
mlangenberg@utrad.com
www.utrad.com