Hospitals across the country have been receiving emails from the Department of Health and Human Services (“HHS”) requesting hospitals to submit certain information about the number of COVID-19 patients admitted to the hospital through a portal established by an HHS vendor, TeleTracking.
HHS stated that submitting this data will inform the decisionmaking on future payments from the Public Health and Social Services Emergency Fund created by the CARES Act (“Relief Fund”). Presumably, the data will be used to identify certain COVID-19 “hot spots” in order to target additional Relief Fund payments to specific hospitals or regions based on the information reported. To date, HHS has distributed $30 billion from the $100 billion initially allocated to the Relief Fund (additional legislation is likely to add an additional $75 billion to the Relief Fund).
Although submitting the requested data is a prerequisite to receiving future payments, it is not a guarantee of eligibility to receive additional payments.
Hospitals were originally asked to submit the following data elements by 11:59 PM Pacific Time on Thursday, April 23, but that deadline was extended by HHS to noon on Saturday, April 25 (organizations can upload a data file to report multiple facilities at the same time):
- ICU Beds as of April 10, 2020 – The total number of ICU beds (occupied and non-occupied), which may include alternative care sites set up as part of the hospital’s COVID-19 response. This may not necessarily be limited to traditional federal or state ICU definitions.
- COVID-19 Confirmed Admissions Between January 1, 2020 and April 10, 2020 – The total number of patients with a positive diagnosis for COVID-19 admitted to the facility from January 1, 2020 to April 10, 2020. This data should include patients admitted to the facility even if a COVID-19 diagnosis was not confirmed until after the admission.
- Tax Identifier Number (“TIN”) – The TIN is the nine-digit tracking number issued by the IRS and used to bill Medicare by the facility. This field is automatically populated based on the latest information for each facility but should be updated if what appears is different than the TIN your facility uses to bill Medicare. Some TINs may operate several Medicare-certified hospitals.
- National Provider Identifier (“NPI”) – The NPI is a unique 10-digit identification number issued to health care providers in the United States by the Centers for Medicare and Medicaid Services. Hospitals may have multiple NPIs, but the portal only allows a hospital to enter a single NPI. So we recommend including the main NPI associated with the hospital’s Medicare enrollment.
While many types of providers and suppliers received distributions from the First Tranche of the Relief Fund, only hospitals are being asked to report at this time. Additional instructions for reporting are available here.
Hospital administrators should have received a general e-mail about the portal from TeleTracking on April 12, 2020, and again on April 21, 2020. If an organization has not already done so, it will be required to register for the portal before submitting the requested data. Note that the TeleTracking portal is also used as one of the options for submitting daily COVID-19 capacity and utilization data to HHS and Federal Emergency Management Agency, which was part of Vice President Pence’s efforts to support epidemiological surveillance and public health decision making for the COVID-19 pandemic (see HHS announcement).
These emails are coming from multiple sources, including individual HHS employees and TeleTracking, so hospital administrators may have inadvertently deleted them already. TeleTracking Technical Support may be reached at (877) 570-6903.
See our previous articles on the Relief Fund available here, here and here.
If you have questions or would like additional information about this topic, please contact:
- David Snow at (303) 801-3536 or dsnow@wp.hallrender.com;
- Lori Wink at (414) 721-0456 or lwink@wp.hallrender.com;
- Joseph Krause at (414) 721-0906 or jkrause@wp.hallrender.com;
- Elizabeth Elias at (317) 977-1468 or eelias@wp.hallrender.com;
- Benjamin Fee at (720) 282-2030 or bfee@wp.hallrender.com; or
- Your regular Hall Render attorney.
Hall Render’s attorneys and professionals continue to maintain the most up-to-date information and resources, which are available at our COVID-19 Resource page, through our 24/7 COVID‑19 Hotline at (317) 429-3900 or by contacting your regular Hall Render attorney.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
