Deadline Extended: CARES Act Provider Relief Fund Dental Distribution

Winthrop & Weinstine, P.A.

The deadline to apply for the $15 billion CARES Act Provider Relief Fund Dental Distribution has been extended to August 3, 2020. The FAQs on the Dental Providers Distribution changes almost daily so this guidance is current as of July 24, 2020. Here are ten key issues to understand:

  1. The amount providers are eligible to receive from this targeted distribution is approximately 2% of reported gross revenue from patient care.
  2. To be eligible to receive payments, providers must be on a “curated list of dental practice TINs” developed by HHS from third party sources and HHS datasets. Providers who are not on the “curated list” can still apply but will have to submit additional validation documentation.
  3. Providers who received a payment from the $50 billion General Distribution are not eligible to apply for the Dental Providers Distribution.
  4. Funds may be used to cover lost revenue attributable to Covid-19 or for health related expenses incurred to prevent, prepare for and respond to Covid-19.
  5. Funds cannot be used to seek collection of out-of-pocket payments from a presumed or actual Covid-19 patient that are greater than what the patient would otherwise have been required to pay in-network.
  6. Fund recipients are required to attest to terms and conditions, including consenting to the public disclosure of the amount received.
  7. Recipients who receive more than $10,000 in the aggregate will be required to comply with specific reporting requirements on the use of funds received.
  8. Recipients must maintain records and documentation to support that the funds were used for permitted expenses and lost revenue consistent with the terms and conditions.
  9. The funds do not have to be repaid provided that the funds were used as permitted and that the recipient complied with the applicable terms and conditions.
  10. HHS has stated that it will have significant anti-fraud monitoring of funds distributed and that non-compliance with any term or condition is grounds for recoupment.

The application can be found here, and the application instructions can be found here.

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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