April 16, 2020

HHS Outlines Relief Fund Payment Terms and Conditions

The Department of Health and Human Services (HHS) released a document during the week of April 6, outlining Relief Fund Payment Terms and Conditions from the Public Health and Social Services Emergency Fund established by Congress in response to the COVID-19 crisis.

The document offers guidance to health care providers and practices on the appropriate use of payments from the fund. It is critical that providers review the terms and conditions surrounding the distributed funds. The HHS requires relief funding recipients to provide care for the diagnoses, testing or care of individuals with possible or actual cases of COVID-19. HHS has clarified that every patient is possibly classified as a COVID-19 patient.

The terms and conditions include a requirement for possible or actual COVID-19 cases that require providers to certify that they will not seek to collect out-of-pocket funds from patients in amounts that exceed what they would have been required to pay from in-network health care providers. The policy applies to any possible COVID-19 patient who seeks care from an out-of-network provider.

Another provision requires that payments will only be used to prevent, prepare for and respond to COVID-19 and will only reimburse the provider for health care-related expenses or lost revenues that are attributable to the disease. The HHS secretary will provide future guidance on how to submit appropriate documentation to ensure compliance with the terms and conditions.

The fact sheet includes a link to an Attestation Portal. Providers who have been allocated a payment from the initial $30 billion general distribution must sign an attestation confirming receipt of the funds and agree to the terms and conditions within 30 days of payment.

Providers receiving funds should review all the terms and conditions to ensure they are complying with all regulations. For more information on these developments, please review the American College of Radiology® COVID-19 website.