The soon to be passed Coronavirus Aid, Relief, and Economic Security Act includes these key details surrounding the Health Care Industry, Not-for-Profits, and debt restructurings.
Health Care
- $100 billion in direct financial aid to health care institutions (Special Public Health and Social Services Emergency Fund Allocation)
- $1.3B for supplemental awards targeted to community health centers for detection, prevention, diagnosis and treatment of COVID-19 (Section 3211)
- Medicare sequester countermanded – lifts related 2% reduction from May 1st to December 31st (Section 3709)
- Medicare Hospital Inpatient Prospective Payment System add-on payment of 20% for COVID-19 patients during the emergency period (Section 3710)
- Increasing access to post-acute care during the emergency period by waiving Inpatient Rehab Facility 3-hour rule to permit transfers out of the hospital facility to make room for COVID-19 inpatients (Section 3711)
- Revising payment rates for durable medical equipment under the Medicare program by suspending planned reductions through the duration of the emergency period (Section 3712)
- Importantly, revised payment rates for items and services on March 6, 2020 (and through the emergency period) from 100% of the adjusted payment amount to (i) 75% of the adjusted payment amount and (ii) 25% of the adjusted fee schedule (Section 3712)
- Hospitals can elect to receive up to 100% of Medicare prior period payments (125% for critical access hospitals) for up to a 6-month period, as an advance, with loan repayment not starting for four (4) months and have twelve (12) months to repay without interest (Section 3719)
- Delay of Disproportionate Share Hospital (DSH) reductions through November 30, 2020 (Section 3813)
Not-for-Profits (Including Health Care Institutions)
- Under the 5-year loan program to be developed by Treasury, low-interest rate program targeted to not-for-profits with 500-10,000 employees with no principal and interest due for at least 6 months (Section 4003)
Debt Restructurings (Section 4013)
- From March 1, 2020 and ending on earlier of December 31, 2020 or through the emergency period and 60 days thereafter
- Financial institutions may elect to suspend the requirements under GAAP for loan modifications that would otherwise be categorized as a troubled debt restructuring
- The rationale for loan modifications must be related to COVID-19
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