Chambliss, Bahner & Stophel, P.C.

Today, the Department of Health and Human Services (HHS) announced the delivery of the initial $30 billion tranche from the $100 billion provider relief fund established under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which was passed into law by President Trump on March 27, 2020.

HHS simultaneously released guidance regarding facility and provider eligibility for funding, as well as the terms upon which payment of this initial wave of dollars is conditioned.

Importantly, HHS reiterated that these funds are payments, not loans, which are separate and distinct from the billions of dollars the Centers for Medicare and Medicaid Services has already delivered under its Accelerated and Advanced Payment Program (AAPP). 

We have previously explained the implications of the AAPP and its distinction from the provider relief fund in two separate client updates “Support for Health Care Providers During the COVID-19 Pandemic” and “Separate Funding for CMS AAPP and $100 Billion in Loans Under Cares.”

Facilities and providers will be allotted a portion of the $30 billion based on their share of 2019 Medicare fee-for-service (FFS) reimbursements. Funding is being distributed from Optum Bank—beginning today—by direct deposit using Automated Clearing House account information on file with the Centers for Medicare & Medicaid Services.