Additional Relief Funding Could Be Available For Dentists Who Provide Services to State Medicaid and CHIP Patients

The Department of Health and Human Services (HHS) announced on Tuesday that they were going to provide an additional distribution from the Provider Relief Fund to eligible Medicaid and Children’s Health Insurance Programs (CHIP)  providers who participate in state Medicaid and CHIP programs. Dentists who qualify are able to apply for this funding, now, through a portal.

The payment available to each provider will be:

  • At least 2% of reported gross revenue from patient care with the final amount each provider receives determined after the data is submitted, including information about the number of Medicaid patients served by the provider.

To be eligible you must meet all of the following requirements:

  • Must not have received payment from the $50 billion General Distribution (this includes providers who have billed Medicare on a fee-for-service basis [Parts A or B] in Calendar Year 2019).
  • Must have directly billed Medicaid for health care-related services during the period of Jan. 1, 2018, to Dec. 31, 2019, or own (on the application date) an included subsidiary that has billed Medicaid for health care-related services during the period of Jan. 1, 2018 to Dec. 31, 2019.
  • Must either have filed a federal income tax return for fiscal years 2017, 2018 or 2019 or be an entity exempt from the federal income tax return filing requirement and have no beneficial owner who is required to file a federal income tax return (e.g. a state-owned hospital or health care clinic).
  • Must have provided patient care after Jan. 31, 2020.
  • Must not have permanently ceased providing patient care directly, or indirectly, through included subsidiaries.
  • Must have gross receipts or sales from providing patient care reported on Form 1040, Schedule C, Line 1, excluding income reported on a W-2 as a (statutory) employee if the applicant is filing as an individual.

The ADA released an article on Tuesday that provides additional information regarding this program as well as a link to the portal. To access this article please use the below link:

https://www.ada.org/en/publications/ada-news/2020-archive/june/hhs-releases-provider-relief-funds

HHS has also provided a number of FAQs on the Medicaid Targeted Distribution:

https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/index.html#medicaid-targeted

One point of caution/uncertainty:

  • Starting in April of this year HHS started releasing funds to providers who billed Medicare fee-for-service in 2019. HHS then told providers that they needed to accept these funds if they believe they were eligible. Advisors quickly noticed an inconsistency with HHS’s message.
    • On one hand, they were telling people that this money was for healthcare providers who were treating COVID-19 patients, but that they viewed every patient as a potential COVID-19 patient. This seemed to mean that as long as you were treating any patient, you were eligible for this money.
    • On the other hand, the legal language of the attestation read: “The Recipient certifies that it provides or provided after January 31, 2020 diagnoses, testing, or care [emphasis added] for individuals with possible or actual cases of COVID-19.” There is no further definition of what care of a “possible” COVID-19 patient means in the Terms and Conditions document.
  • We believe HHS knows about this inconsistency and we believe they are going to fix the language in the attestation Terms and Conditions document. However, as of today, they have not done this and if they don’t, you may not be eligible for this money if you are not providing or have provided diagnosis, testing or care for individuals with possible or actual cases of COVID-19. We will release an update as soon as we get an answer from HHS.

Links to our previous HHS blogs are below:

HHS Stimulus Money for Physician/Medical Practices

Update on HHS Stimulus Money for Physicians/Medical Practices

Update on Attestation Deadline for HHS Stimulus Money for Physicians/Medical Practices

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