Articles and Blogs

Visitation, residents leaving and returning, telephone surveys, hospitalized patients being discharged to a nursing home and other issues have been challenging for skilled nursing facilities (“SNFs”) and nursing facilities (“NFs”) (in this alert, SNFs and NFs are collectively Long‑Term Care Facilities “LTC Facilities”) as they navigate the evolving government guidance. On April 24, 2020,... READ MORE

HHS published a new Terms and Conditions document that is specific to payments that started being distributed on Friday, April 24 from the CARES Act Public Health and Social Services Emergency Fund’s (“Relief Fund”) second $20 billion tranche. Highlights New Terms and Conditions: A second Terms and Conditions document specific to the $20 billion Second... READ MORE

HHS launched a wide-ranging new CARES Act Provider Relief Fund Application User Guide website (“User Guide Website”) and nine‑page FAQ document to assist Providers with navigating the new Provider Relief Fund Payment Portal (“Payment Portal”) that went live on Friday, April 24. More information on the Payment Portal, the information Providers are required to... READ MORE

Friday, April 24 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ SBA Releases Guidance on the Paycheck Protection Program The Small Business Administration... READ MORE

As part of the CARES Act,[1] the Paycheck Protection Program (“PPP”) granted vulnerable small businesses the ability to seek forgivable loans from the federal government to help prevent closures during the COVID-19 crisis and to ensure employees remain on payroll. The Small Business Administration (“SBA”) and the Department of the Treasury have published and... READ MORE

Earlier today, the Small Business Administration (“SBA”) issued an updated Interim Final Rule (the “Rule”) that supplements and provides clarification on the types of businesses that are eligible for the Paycheck Protection Program (“PPP”) loans. Under the Rule, governmental hospitals that (a) have 500 or fewer FTEs, and (b) receive less than 50 percent... READ MORE

On April 21, 2020, CMS issued explanatory guidance clarifying the scope and application of the previously issued Stark blanket waivers related to COVID-19 physician arrangements (“Waivers”). Our previous alert on the Waivers can be found here. Action and Timing The Waivers can be relied upon retroactive to March 1, 2020 but will terminate upon the... READ MORE

Thursday, April 23 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ Congressional Outlook Today, the House approved an interim emergency spending measure that... READ MORE

On April 23, the Department of Health and Human Services (“HHS”) outlined the basic framework for a new program to reimburse hospitals and other providers and suppliers for services provided to uninsured COVID-19 patients (for purposes of this article we refer to both providers and suppliers as “providers”). The framework for the program is... READ MORE

The Coronavirus Aid, Relief, and Economic Security Act (H.R. 748) (“CARES Act”) contains numerous provisions aimed at the response to the Coronavirus or COVID-19 pandemic, including $100 billion in reimbursement to hospitals and other health care entities for COVID‑19-related expenses and lost revenue (“Fund”). The First Tranche of the Fund was distributed on April... READ MORE