Alert: COVID-19 closures
The closure order from July 13 does not impact dental practices.
Article updated Aug. 3 to reflect new application deadline of Aug. 28.
Dentists with a tax identification number have until Aug. 28 to apply for funding through the Enhanced Provider Relief Fund Payment Portal. The Provider Relief Fund, which provides eligible dentists a reimbursement of 2% of their annual reported patient revenue, was created by the CARES Act and the Paycheck Protection Program and Health Care Enhancement Act.
The Department of Health and Human Services extended the deadline to Aug. 28, 2020, to submit applications for two of the CARES Act Provider Relief Fund distribution categories: the Medicaid (Medi-Cal) and CHIP Distribution and the Dental Provider Distribution.
Assistance hotline available for providers
HHS continues to regularly update the Dental Distribution FAQs as well as a the General Overview FAQs about the Provider Relief Fund. To speak to a live representative who can answer questions about the application, call the Provider Support Line at 866.569.3522.
Balance billing concerns in terms and conditions
Many dentists have raised concerns or seen discussion in their network about a section in the terms and conditions that states:
“The Secretary has concluded that the COVID-19 public health emergency has caused many health care providers to have capacity constraints. As a result, patients that would ordinarily be able to choose to receive all care from in-network health care providers may no longer be able to receive such care in-network. Accordingly, for all care for a presumptive or actual case of COVID-19, Recipient certifies that it will not seek to collect from the patient out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network Recipient.”
According to this condition, if you receive the Provider Relief Fund payment, you are agreeing to not balance bill insured patients with presumptive or actual cases of COVID-19. The critical distinction in this term is that the prohibition does not use the phrase “possible cases of COVID-19” and instead uses the specific term “presumptive.”
HHS states in several documents that it “broadly views every patient as a possible case of COVID-19. Not every possible case of COVID-19 is a presumptive case of COVID 19.” According to HHS, a presumptive case of COVID-19 “is a case where a patient’s medical record documentation supports a diagnosis of COVID-19, even if the patient does not have a positive in vitro diagnostic test result in his or her medical record.” Note that the balance billing prohibition applies to “presumptive or actual cases.” That definition indicates that HHS intends for the ban on balancing billing to be targeted at patients who have or likely have COVID-19 — not all patients.
Dentists who are doing routine care and appropriately screening out patients who present with symptoms are therefore not treating presumptive cases. Providers who are treating emergency patients in a COVID-19 “hot spot” or treating numerous patients diagnosed with COVID-19 will have to consider how their current balancing billing practices would be impacted by such a prohibition.
CDA reached out to the HRSA Provider Relief Team for further clarification on this matter and received the following response:
In answer to your question about how the balance billing prohibition affects dentists, the prohibition on balance billing applies to “all care for a presumptive or actual case of COVID-19.” A presumptive case of COVID-19 is a case where a patient’s medical record documentation supports a diagnosis of COVID-19, even if the patient does not have a positive in vitro diagnostic test result in his or her medical record. Dental providers who are not caring for patients with presumptive or actual cases of COVID-19 would not be subject to this provision.
Federal funding requires data disclosure
In order to comply with federal laws governing transparency of federal funding, recipients of all CARES Act grants and loans are required to disclose some data regarding how the money is spent. The Provider Relief Fund terms and conditions lay out general requirements of the required reports, but HHS has recently provided some additional documentation on how reporting will be defined. HHS also states that detailed instructions regarding these reports will be released by Aug. 17, 2020.
To apply or learn more, visit the Relief Fund Payment Attestation Portal. Find general information about the fund at the HHS’ Provider Relief Fund webpage.