Medicare Compliance & Reimbursement

Question: Our practice received Cares Act Provider Relief Fund (PRF) payments, and that money really helped us during the hardest months of the pandemic. The problem is that we don’t think the numbers align; our records indicate that we should have received more funding. Because there may be a discrepancy in our past reporting that determined our eligibility and the amount deposited into our account, we wondered if there is a way to dispute the financial records the Department of Health and Human Services (HHS) is using?

New York Subscriber

Answer: You are not alone in your concerns on PRF payment validity and the HHS methodologies for determining deposit amounts. “Many providers have received PRFs inconsistent with reported financial information or funding formulas outlined by HHS,” say Atlanta-based attorneys Hedy Silver Rubinger and Alexander B. Foster with Arnall Golden Gregory LLP in online analysis.

“To date, HHS has had no formal process to appeal or dispute funding decisions,” but a recently-added Frequently Asked Question (FAQ) from HHS suggests fresh guidance is on the way, Rubinger and Foster relate.

HHS is working on designing an appeals system for PRF recipients, according to the FAQ added on July 15.

“HHS recognizes that providers may have questions regarding the accuracy of their PRF payments,” the FAQ says. “HHS is developing a structured reconsiderations process to review and reconsider payment accuracy based on submitted supporting documentation. Details regarding this process will be provided in coming weeks.”

Tip: As HHS continues to revise its PRF guidance, you may want to revisit its FAQs, financial breakdowns, and online tools to ensure you are up to date on all policy changes.