CARES Act Provider Relief Fund: General Distribution Portal Opens

Butler Snow LLP

Butler Snow LLP

Medicare providers who have received payment from the Provider Relief Fund as of 5:00pm EST Friday, April 24, 2020 are eligible to apply for additional funds by submitting data about their annual revenues and estimated COVID-related losses to the Provider Relief Fund Application Portal.  The funds do not need to be repaid if certain terms and conditions are met.  The portal may be accessed at the following link:

The US Department of Health and Human Services (“HHS”) states that funds will NOT be disbursed on a first-come-first served basis, and applicants will be given equal consideration regardless of when they apply.  Providers should receive payment within ten days of application.  HHS would like the General Distribution to replace a percentage of a provider’s annual gross receipts, sales or program service revenue.

The information that will be collected through the portal includes:

  • “Gross Receipts or Sales” or “Program Services Revenue” as submitted on its federal income tax return;
  • The provider’s estimated revenue losses in March 2020 and April 2020 due to COVID;
  • A copy of the provider’s most recently filed federal income tax return;
  • A listing of the TINs any of the provider’s subsidiary organizations that have received relief funds that do not file separate tax returns.

The documents needed to begin the application process include:

  • TIN that has received prior Provider Relief Fund payments;
  • TINS of subsidiary organizations that have 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);
  • Amount of payments received;
  • Relief Fund payment transaction numbers/check numbers;
  • A copy of your most recently filed tax forms

In order to determine estimated revenue losses, HHS states that providers may use a reasonable method of estimating the revenue during March and April compared to the same period had COVID-19 not appeared.  HHS provides, “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.  Each entity that files a federal income tax return is required to file an application even if it is part of a provider group.”

We will continue to monitor this program and provide updates as they become available.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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