The CARES Act allocated $100 billion COVID-19 relief for health care providers. For the past month, the U.S. Department of Health and Human Services (HHS) has been distributing the Coronavirus Aid, Relief, and Economic Security Act (CARES) payments to health care providers and facilities as follows. Here is what you, your practice, or your facility must do to determine if you are eligible, to receive payments, see if you are receiving the correct amounts, and what you need to do to keep the money without penalty. 

First, the money is directed only to providers diagnosing or treating COVID-19 patients, or suffering health related costs and lost revenue as a direct result of diagnosing and treating COVID-19 patients, beginning January 31, 2010. Such providers will be referred to here as "COVID-19 providers."

Second, the distributions are coming in distinct phases. The first half of the allocation, $50 billion, was distributed to COVID-19 providers and facilities on an automatic basis. COVID-19 providers were not required to apply for this distribution. Decisions by DHHS on the amounts of payments were based on a COVID-19 provider or facility's percent share in the total cost of the program in 2019. DHHS had this data and made distributions accordingly. There is no review or appeals process for any providers regarding those distributions. 

IF YOU RECEIVED one of the Phase I automatic distributions, you are ELIGIBLE to receive more, in Phase II, when another $30 billion are being allocated. If you did NOT receive any Phase I distributions, you are not eligible for Phase II, BUT you may be eligible for one or more of the allocations listed below. 

Phase II requires COVID-19 providers to apply. The information required will include your tax and provider IDs, revenue data from 2018 cost reports, verification that you spent money since January 31, 2020, on health related costs and lost revenues directly attributable to COVID-19 patient care, and certification of your receipt of the funds. 

Third, another $10 billion is being distributed by DHHS to hospitals hardest hit by COVID-19 in high impact areas. Factors included in this calculation are the number of your ICU beds as of 4/10/2020, your total COVID-19 admissions from 1/1/2020 - 4/10/2020, and the facility's low-income patient ratio as determined by your Medicare Disproportionate Share Hospital (DSH) Adjustment. 

Fourth, another $10 billion distribution is being made to rural health clinics and hospital COVID-19 providers and facilities.

Fifth, an additional $400 million is allocated to Indian Health Services (IHS).

Finally, "a portion" of the total $100 billion COVID-19 relief distributions will be made to providers treating uninsured COVID-19 patients in a wide variety of diagnostic, testing, treatment and care settings, including office visits, telehealth, urgent care, specimen collection, antibody testing, nursing homes, and will include future vaccinations when a vaccine is approved. COVID-19 providers in this category must enroll as providers, and will generally be paid at Medicare rates. They must check patient eligibility and submit patient information and claims. 

More guidance is being released regularly by DHHS on these allocations and distributions.