Category Archives: Practice Enhancement

Physician’s Recession Guide: How to Protect Your Practice During COVID-19

Medical practices managing patients during the COVID-19 pandemic are being confronted with new and unique operational challenges as many have turned to telemedicine, bringing their services online to continue patient care. Other providers may find it increasingly difficult to continue conducting business in light of wide-scale cancellations of elective procedures and recommendations against in-person office appointments. Unprecedented economic fallout related to the virus outbreak is proving to be another significant concern facing the healthcare system.

In response to this complex issue faced by clinicians across the country, the American Medical Association has compiled a set of recommendations and guidelines on handling the financial and operational repercussions of the outbreak for practice owners and office administrators.

To better adapt practices to current demands and protect them from adverse financial impact at this time, medical professionals should consider the following important variables and strategic responses:

Insurance Coverage 

A critical first step to securing the medical practice is to ensure it is protected against COVID-19 related liabilities under business insurance policies. Whether the protection is part of insurance policies will determine the associated risks and help providers make vital business and operational decisions. Experts urge practices to contact their insurance brokers to obtain a complete copy of all insurance policies, understand government emergency orders and decrees, as well as to track losses and expenses incurred during this time for future claims.

Further, practitioners are urged to consult legal counsel for explanations of how they can exercise existing policies and how government orders impact business operations in their state. “You may need to notify professional liability carriers in the event practice providers are called upon to assist with emergency care, including outside of their normal clinical service arrangements,” the AMA adds in its latest guidelines.

In addition, the U.S. Department of Health and Human Services has published a declaration of liability protection against certain medical countermeasures related to COVID-19 which can be accessed here. 

Financial Obligations and Contingency Planning

To minimize potential economic risk, practices are encouraged to revise financial plans at this time and ensure their ongoing liquidity; this will hopefully protect those businesses suffering from a loss of clinical revenue due to cancelled procedures, decreasing outpatient visits, and partial or whole closures. It is recommended practices develop a financial contingency plan based on minimum cash flows needed to remain in operation, review existing loan documents and financial covenants, and determine if slowdown of business could trigger a default situation.

Practices should prioritize managing cash to the best extent possible and consider delaying payments of discretionary bonuses as well as other such payments. They may also choose to consider requesting forbearance, forgiveness, or a standstill from lenders and other creditors. Proactive communication with these third-parties can help ensure accommodations are granted during revenue disruptions.

Additionally, clinicians are urged to monitor resources as they become available concerning economic relief packages for business and workers affected by the outbreak; the U.S. Small Business Administration has already begun introducing low-interest loans while other organizations – such as United Way – have created COVID-19 relief funds to provide additional funding.

Current and Future Supply Needs 

In light of global shortages of essential medical supplies, such as personal protective equipment and respirators, practices are encouraged to evaluate their current and future supply needs. While a reduction in in-person office visits may decrease the number of interactions requiring the use of such equipment, practices should determine how much cash flow can be devoted to stocking up on essential supplies for the forthcoming months.

“While your business may be interrupted, you may also be called upon to triage patients outside of your normal workflow, so contact your supply vendors and, if necessary, your state and local health authorities to ensure that you are in the queue to receive necessary supplies,” the AMA recommends.

Continuing Business Operations 

A growing number of “shelter in place” orders and their extensions may impact the ability of medical practices to continue business operations. However, many of these orders designate healthcare services as essential businesses but publicly available guidance may remain unclear. Practitioners are urged to consult with local counsel to determine the implications of executive orders and how to apply them to their practice.

To further assist clinicians, the AMA provides two non-jurisdiction specific template letters that can be modified to suit the needs of each practice in COVID-19 related circumstances. These templates aim to function as a resource for providers who may encounter questions from authorities or resistance from employees who may not report to work due to “shelter in place” orders.

Regular Communication with Patients

Whether a practice is operating normally or offering digital medical services, it is currently essential to maintain regular communication with patients – in particular, those who may be at-risk of adverse health outcomes as a result of the disruption in healthcare. Reports reveal a silent sub-epidemic caused by COVID-19, that of an increasing number of patients forgoing needed medical care out of fear of contracting the virus in a hospital or medical facility. Patients need to be made aware of the COVID-19 prevention and safety protocols enforced at a practice or other healthcare center and be encouraged to stay in contact with their physicians via telehealth and to come in for in-person care when needed.

Administrative Resources

Despite interruptions in operations, many practices will still operate remotely. To assist healthcare providers in meeting immediate care needs while working from home, office administrators are encouraged to compile essential resources outlining best telemedicine practices. This includes putting in place methods of maintaining documentation protocols to obtain payments, including processes for collection of accounts, claims submissions, and other activities. More information regarding medical codes and scenario planning has been made available as part of the AMA’s resource hub.

Workflow and Digital Health Tools 

To protect staff members, conserve valuable equipment and supplies, and reduce the safety and liability risk to your practice, providers are urged to follow the latest guidance issued by governmental agencies when reviewing scheduled visits and choosing which appointments to postpone, cancel, or proceed with as usual.

Digital tools can assist providers by allowing them to continue conducting business remotely via telehealth services and remote patient monitoring. Following the CMS’ telemedicine toolkit can help physicians and practices utilize these technologies during the COVID-19 outbreak and provide insight into emerging policy changes and practice flexibilities.

 Employee Management 

Keeping employees updated and informed is essential to managing concerns about health and safety. Practices are encouraged to institute interim guidelines that aim to educate their employees, including outlining circumstances under which they should not report to work, contact information for relevant resources, and specify leave policies related to COVID-19.

Depending on revenue and cash flow challenges, practices may need to furlough or terminate non-essential employees. In these cases, practices should seek legal counsel to understand their obligations, requirements regarding communication of employment status, and identify workflow changes which may be necessary at this time.

While all practices may not be able to sustain each of their employees, healthcare staff is urgently needed at medical facilities across the nation – as such, administrators should identify external opportunities for their furloughed or terminated staff members when possible.

The CDC has issued interim guidance to assist business and employers in navigating the evolving situation, while the U.S. Department of Labor also released resources pertaining to employee furloughs and unemployment benefits.

The COVID-19 pandemic has prompted unprecedented policy and regulatory changes affecting the healthcare system nationwide; it is essential for medical professionals to stay current on the latest developments in requirements and afforded flexibilities. As the COVID-19 outbreak continues to evolve, federal guidance and relief efforts are forecasted to offer further support for front-line workers as well as those physicians whose practice has been affected by the pandemic. To access the latest recommendations for practices and physicians navigating patient care at this time, visit our COVID-19 Resource Hub.

Emerging Theories That May Help Us Solve the COVID-19 Puzzle

Originally published at JillCarnahan.com

UPDATED 4-18-20

There is increasing evidence that COVID-19 isn’t your typical virus. Thankfully many researchers, scientists and doctors are observing trends that are changing the way we are treating it in hospitals and at home.

I should be writing this at the beginning of all my articles in the last month but due to the fact that we are all living in real time and the information coming out is changing moment by moment even the best scientist’s theories on how to combat this illness continue to evolve.  Although things could certainly change as larger studies come forth, for the moment I wanted to share with you some exciting new details that are emerging theories, which could affect future treatment development.

Current Theory and Treatment for Coronavirus

Currently COVID-19 is being treated as a dysfunction of the lower respiratory tract. It’s primary symptoms are:

  1. Fever
  2. Cough
  3. Shortness of breath

Interestingly, a large number of COVID-19 patients also report a loss of taste and smell. In mild cases of COVID-19, the virus will run its course and resolve on its own. But if this disease progresses to a critical level, patients spiral into a state of severe hypoxemia – where the body is unable to effectively deliver life-sustaining oxygen to the rest of the body. Without adequate oxygen delivery, vital organs and tissues are starved of oxygen and begin shutting down – which can eventually lead to death.

The current treatments assume that coronavirus is causing a build-up of liquid (instead of air) in the alveoli – making it difficult for oxygen to transfer through the fluid and make its way into the bloodstream. To counteract oxygen deprivation caused by this build up of fluid, COVID-19 is currently being treated as a case of acute respiratory distress, also known as ARDS. The standard treatment for ARDS is mechanical ventilation – which will force air into the alveoli in hopes of transferring oxygen into the blood.

The problem is, treating COVID-19 with ventilation isn’t working like it should. In fact, some doctors have observed that the use of ventilators may even be harming some patients. So that brings up the question – what if our current understanding of COVID-19 is wrong?

Emerging ideas on the virus…

There is mounting evidence suggesting that our initial understanding of exactly how coronavirus impacts the body may be incorrect.

Consider these mysteries of COVID-19:

  1. Patients are showing blood oxygen levels so low that they should be life-threatening, but without showing the typical signs of distress that are expected when the same levels are reached due to lung dysfunction.
  2. Doctors are saying that ventilators aren’t working as well as they should be and may even be harming some people.
  3. Many patients report a loss of taste and smell, typically associated with zinc deficiency, not respiratory disease.
  4. Researchers have noted that the pathological mechanism that causes the damage to the body remains a mystery.
  5. Twenty percent of COVID-19 patients have cardiac damage.
  6. Fatality rates, even among places with robust testing in place, are wildly different.

These discrepancies have hinted at a new culprit as well as new possible solutions. So, should we be treating COVID-19 differently? To answer that question, first let’s look at exactly how a healthy body is designed to deliver oxygen to your tissues.

How Our Cells Are Designed Carry Oxygen

As you inhale air, oxygen enters your lungs and reaches the alveoli which is lined with a layer of cells that creates the barrier between your lungs and your bloodstream. Oxygen molecules pass through this barrier and attach themselves to a protein called hemoglobin that is bound to your red blood cells. Once your red blood cells have picked up oxygen, they set off to begin delivering it to the rest of the tissues in your body.

Think of your red blood cells like little rafts that are responsible for picking up oxygen and carrying it to your tissues which rely on oxygen for survival. And think of hemoglobin like people on the raft working as a delivery crew – tasked with receiving, holding, and dropping off oxygen molecules. Without the “delivery crew” of hemoglobin proteins, the raft is useless.

It’s also important to understand a little more about the structure of hemoglobin. A vital component of hemoglobin proteins are heme groups – which are embedded in the hemoglobin and are responsible for binding and releasing oxygen molecules. These heme groups are a metal complex and contain iron as the central metal atom, with each iron molecule capable of carrying one oxygen molecule. These iron rich heme groups are critical – without them your cells are unable to transport the oxygen your tissues depend on.

This understanding the body carries oxygen has sparked speculation about how COVID-19 may be exerting it’s devastating effects by creating more reactive oxygen species causing tissue damage and hypoxia.

A New Theory on COVID-19’s Mechanism of Injury

One the most puzzling aspects of COVID-19, is that despite fitting most of the criteria under the definition of acute respiratory failure there is one glaring contradiction. With the coronavirus, there appears to be hypoxia or low oxygen saturation in the blood rather than respiratory distress as seen in classic respiratory failure. Meaning many patients present with severe hypoxia with nearly normal respiratory function. This remarkable combination is almost never seen in severe cases of ARDS.

Interestingly, it may be creating a clinical picture similar to someone suffering from severe malaria or altitude illness.

Could COVID-19 Be affecting Oxygen Carrying Capacity?

In COVID-19’s final and severe stages, the lungs are severely damaged. But new information on this virus’s cellular process in the body is revealing that the final condition of the lungs and accompanying respiratory failure may actually be more of a case of massive oxidative stress overload disrupting the capacity of hemoglobin to carry oxygen to tissues rather than an outright attack on the air sacs in the lungs.

The theory on coronavirus affecting the bloods oxygen carrying capacity is related to the fact that increased intracellular oxidative stress is at the core of all pathogenic infections.  This is often referred to as increase in reactive oxygen species or ROS.  This ROS production is at the core of much of the damage we are seeing not only to the blood’s ability to deliver oxygen to the tissues, causing severe hypoxia or low oxygen but also damaging all tissues they come in contact with.  As Integrative and functional medicine doctors, we often measure marker of oxidative stress in our patient’s urine to determine if this process is out of control.  One such marker is lipid peroxides.  According to Dr. Tom Levy the intracellular levels of Vitamin C, magnesium and glutathione largely affect the oxidative stress which could damage the tissues, one reason why you are seeing Vitamin C being used in hospitals to treat the virus.  Stay tuned as I will be writing more about Vitamin C in upcoming blog articles.

This cascade of events would explain:

  1. Why as many as one in five COVID-19 patients have cardiac damage.
  2. Why IV nutrients that target cardiovascular function are beneficial.
  3. Why many people experience a loss of taste and smell.
  4. Why anti-malarial medications are showing promising results.

This would also explain why ventilators aren’t working quite like we’d expect. Ventilators work by forcing more air into the lungs, so more oxygen can be delivered to the blood. This is helpful when there’s liquid or inflammation in the lungs, and the blood is working normally – like in pneumonia. However, if there is an issue due to the fact that oxidative stress (ROS) has altered the blood’s ability to properly carry this oxygen, then a ventilator can’t do its job. Right now, the Journal of the American Medical Association indicates that COVID-19 patients are candidates for “early, invasive ventilation”. But if we’re ventilating patients who are struggling to keep their little oxygen boats afloat in the bloodstream due to massive oxidative stress, ventilation will do little good and could even cause damage.

This theory would also give us some more insight as to why certain populations may be more at risk of contracting COVID-19.

This Might Explain Why Anti-malarial Medications are Being Considered for Treatment.

Hydroxychloroquine, also known as Plaquenil, is an anti-malarial medication that is showing promise as a potential treatment for COVID-19. If coronavirus is in fact attacking red blood cells, similar to the way malaria does, then it would make sense why an anti-malarial drug would be beneficial for coronavirus patients. But how exactly could hydroxychloroquine be exerting these antiviral effects?

Research is finding that it might be due to hydroxychloroquine’s relationship with the mineral zinc. You see, hydroxychloroquine is a zinc ionophore – meaning it enhances your body’s ability to allow zinc into your cells.  When intracellular concentrations of zinc are increased, it displays broad spectrum antiviral activity in a few ways:

  1. Zinc inhibits the actions of certain proteins necessary for the completion of different phases of the virus’s life cycle – essentially halting its ability to reproduce10
  2. Zinc supports a robust immune response by aiding in the production of cytokines and the modulation of immune cells10
  3. Zinc acts as a powerful antioxidant and prooxidant – neutralizing the oxidative stress caused by toxic overload of iron that has been dumped into the blood from the burst cells

Interestingly, one of the initial symptoms reported by many coronavirus patients is a loss of taste and smell. This lack of taste and smell can be caused by a zinc deficiency. Perhaps the action of hydroxychloroquine helping zinc enter cells is part of the reason the drug has benefitted some COVID-19 patients. It’s important to note that in order for hydroxychloroquine to work, there must be adequate zinc levels available to allow into the cells – so hydroxychloroquine must be administered in conjunction with zinc to be most effective against COVID-19.

Hydroxychloroquine has shown promise (as well as a risk of severe cardiac arrhythmia in certain patients) but the way the drug functions has given us some powerful insights and may give us answers into how we can save more lives.

The Connection Between COVID-19 and Altitude Sickness

Another interesting connection is the fact that COVID-19’s clinical presentation is quite similar to another respiratory illness – high altitude pulmonary edema, also known as altitude sickness. In both COVID-19 and high altitude pulmonary edema clinical findings include:

  1. A decreased ratio of arterial oxygen levels to inspired oxygen
  2. Hypoxia (low oxygen levels) and tachypnea (abnormally rapid breathing)
  3. Low carbon dioxide levels
  4. A ground glass appearance in the lung tissues
  5. Elevated fibrinogen levels
  6. Diffuse alveolar damage

In altitude sickness, the lungs are functioning fine – there are just inadequate levels of oxygen to process to properly meet the needs of the body. Clinical findings similar to altitude sickness would make sense if COVID-19 is in fact causing a dysfunction of red blood cells through production of massive oxidative stress rather than a direct problem with the lungs.

So What Are Potential Options to Quench Oxidative Stress?

Even with all of the information that points to COVID-19 creating massive oxidative stress, there are still a lot of unknowns. The downside of this is of course the trial and error and continued research that needs to take place before we have real answers. The upside, is that this information gives us an array of new potential treatment options to consider:

High Dose Vitamin C:

High doses of vitamin C are garnering attention as a powerful way to potentially mitigate the effects of coronavirus. These ultra-high doses of vitamin C are speculated to fight the massive immune response and subsequent respiratory failure seen in coronavirus infection by:

  1. Suppressing the over-reactive inflammatory response in the lungs
  2. Minimizing the accumulation of immune cells in the tissues of the lungs
  3. Decreasing the release of cytokines (chemical messengers involved in the immune response)
  4. Slowing down the viruses ability to reproduce and spread
  5. Neutralizing the oxidative stress caused by the massive amounts of iron floating around in the bloodstream

Ideally, high dose vitamin C can be delivered intravenously, where it is more easily absorbed and utilized intracellularly. But oral vitamin C can also be beneficial if taken correctly. While regular over the counter oral vitamin C causes diarrhea, liposomal Vitamin C at frequent intervals does not, and is an effective way to increase intracellular levels. Several  New York hospitals have approved intravenous vitamin C as a therapy for the first time ever in studies being conducted on the virus.

Glutathione:

Glutathione is a potent antioxidant naturally found in most of the cells in your body. Glutathione plays a few major roles in immune function including:

  1. Functioning as a signaling molecule – helping balance inflammation levels and modulating immune system response
  2. Reducing oxidative injury by neutralizing harmful toxins
  3. Regulating cellular proliferation and apoptosis

There is a growing mountain of evidence finding that the most effective way to take glutathione may be through inhalation. Inhaled glutathione (aerosolized or nebulized) is already being used in the treatment of a variety of respiratory-related conditions and has been garnering attention as a possible treatment option for COVID-19.

Inhaled Hydrogen:

The inhalation of concentrated hydrogen gas is another potential treatment option due to its powerful antioxidant properties. Inhaling hydrogen gas has been found to:

  1. Reduce oxidative-stress induced damage
  2. Reduce cellular apoptosis
  3. Improve gas exchange in the lungs
  4. Block the production of proinflammatory mediators
  5. Inhaled hydrogen gas may be particularly effective when paired with other anti-oxidative therapies such as IV vitamin C and inhaled glutathione.

Other Antiviral Drugs:

A number of other antiviral medications are being studied for their potential to treat COVID-19. These include:

  1. Methylene Blue: Methylene Blue is a medication that has been used in the treatment of malaria due to its powerful antiviral properties – killing the virus at an impressive speed. It’s also used in the treatment of a condition known as methemoglobinemia – a condition in which individuals have too much methemoglobin which is a form of hemoglobin that is much less effective at carrying oxygen. Methylene blue works by converting methemoglobin into a type of hemoglobin that can more effectively transport oxygen.
  2. Remdesivir: Remdesivir is another antiviral drug used for Ebola. Remdesivir is showing benefit in solid studies – a small but well-conducted study on severe cases in the US, Canada, Europe, and Japan concluded that Remdesvir caused clinical improvement in 68% of patients.
  3. Favipiravir: Favipiravir is a powerful anti-viral agent that inhibits the virus from replicating and spreading. It has been approved in China and Japan for the treatment of influenza and is undergoing research to determine its potential efficacy in treating COVID-19.
  4. Hyperbaric Treatment: Hyperbaric treatment works in two ways. First, inspired oxygen concentration is increased to nearly 100%. Secondly, ambient pressure is increased to about three times higher than the air pressure we normally breathe. This combination is designed to essential “hyper oxygenate” your blood – improving oxygen delivery to your tissues. Hyperbaric treatment may be an effective adjunct therapy to help COVID-19 patients recover, especially when administered early.

Could This Bring Us One Step Closer to Finding a Cure for COVID-19?

There are still many unknowns when it comes to coronavirus. The only thing we know for certain is that we are in a race against time. I hope we will continue to search for clues and change course when wrong.

I urge my fellow clinicians and researchers to examine this virus and its mechanism of action with fresh eyes. We entered into this field knowing we were signing up for being lifetime students. This current pandemic is calling us to rise to the occasion – the world is counting on us to find the answers it needs.

In my own practice, I will continue to give my patients and readers the most up-to-date tools they need to protect themselves amidst this pandemic. Until we have a solid understanding of this virus, I will continue to seek new information to do my part in fighting back against COVID-19 and update you when we find more information to help patients get well.

Give Your Immune System the Support It Needs  

Along with continued research to identify the root cause of COVID-19, I am also working on equipping our clinic to offer treatments to support your immune system during this time. Based on our current understanding we may consider offering some of the following options.

  1. IV Vitamin C and Glutathione: A powerful combination of two of the most potent antioxidants delivered intravenously so they can be immediately used by the cells to combat oxidative damage.
  2. Inhaled Glutathione: Inhaling glutathione delivers it directly to your lung cells – replenishing their antioxidant stores that are quickly used up when fighting inflammation.
  3. Inhaled Hydrogen: Pairing inhaled hydrogen’s impressive anti-inflammatory effects with Vitamin C and glutathione makes for a robust and powerful trio of antioxidant therapies.
  4. Nasal Ozone: Ozone gas held in the sinuses helps your body more effectively uptake oxygen and activates a healthy immune response.  Ozone should not be inhaled as may damage the lungs.

And fortunately, Flatiron Functional Medicine is certainly not the only place that you may be able to receive these powerful therapies to support the immune system. Many other providers have the resources and training to deliver them as well – so please seek out a reputable and trusted clinician in your area to learn more about these options.

References:
  1. https://www.cdc.gov/coronavirus/2019-ncov/about/symptoms.html
  2. https://www.statnews.com/2020/04/08/doctors-say-ventilators-overused-for-covid-19/
  3. https://chemrxiv.org/articles/COVID-19_Disease_ORF8_and_Surface_Glycoprotein_Inhibit_Heme_Metabolism_by_Binding_to_Porphyrin/11938173
  4. https://khn.org/news/mysterious-heart-damage-not-just-lung-troubles-befalling-covid-19-patients/
  5. http://www.chemistry.wustl.edu/~edudev/LabTutorials/hemoglobin.htm
  6. https://www.esicm.org/wp-content/uploads/2020/04/684_author-proof.pdf
  7. https://link.springer.com/article/10.1007/s00109-008-0368-5
  8. https://jamanetwork.com/journals/jama/fullarticle/2762996
  9. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4182877/
  10. https://www.researchgate.net/post/Is_a_combo_of_chloroquine_and_Zinc_a_cure_for_coronavirus
  11. https://www.hindawi.com/journals/omcl/2018/9156285/
  12. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5488004/
  13. https://link.springer.com/chapter/10.1007/978-4-431-68120-5_2
  14. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7096066/
  15. https://clinicaltrials.gov/ct2/show/NCT04264533
  16. https://www.sciencedirect.com/science/article/pii/S0033062020300372?fbclid=IwAR0UMWXFiQvxpIBxCOvg8zpFQLBgq8zTUmI5LOc-HDd0G32SzeBbcv9cFz0#bb0070
  17. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3048347/
  18. https://www.ncbi.nlm.nih.gov/pubmed/19393193
  19. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4684116/4
  20. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2249747/
  21. https://www.researchgate.net/publication/47676317_Inhaled_Hydrogen_Gas_Therapy_for_Prevention_of_Lung_Transplant-Induced_IschemiaReperfusion_Injury_in_Rats
  22. https://www.ncbi.nlm.nih.gov/pubmed/23852510
  23. https://www.sciencedaily.com/releases/2018/02/180205195624.htm
  24. https://www.drugs.com/mtm/methylene-blue-injection.html
  25. https://www.nejm.org/doi/full/10.1056/NEJMoa2007016
  26. https://www.ncbi.nlm.nih.gov/pubmed/28769016
  27. https://www.jwatch.org/na51293/2020/04/09/favipiravir-potential-antiviral-covid-19
  28. https://www.hopkinsmedicine.org/health/treatment-tests-and-therapies/hyperbaric-oxygen-therapy

What Private Practices Need to Know About the U.S. Relief Package

There is a dire need for financial support of healthcare providers and facilities as they continue to battle the COVID-19 pandemic, now affecting the United States the most drastically. In response, the President signed the bipartisan CARES Act on March 27, 2020, providing much-needed relief funds to hospitals and other healthcare providers on the frontlines of the fight against coronavirus. As part of the recently announced CARES Act, $100 billion will be appropriated to create a Public Health Social Service Emergency Fund with an ultimate goal of preventing, preparing for, and responding to the coronavirus outbreak both domestically and on an international scale.

Per the Act, funding will be dedicated to reimbursing healthcare-related expenses or lost revenue attributable to COVID-19 to alleviate some of the financial burden many providers are experiencing. Part of this relief payment will focus on ensuring that uninsured Americans have access to testing and treatment, and that medical professionals providing the care are reimbursed for their work. The Department of Health and Human Services has published detailed criteria for the process of distribution of funds under the Act as well as information about eligibility requirements, outlined below.

Immediate Relief Funding

Recognizing the urgent need for the delivery of financial relief, the HHS immediately infused $30 billion into the American healthcare system. Payments are slated to arrive via direct deposit beginning April 10, 2020 to eligible providers throughout the system. Note, these are direct payments, not loans and will not need to be repaid, the HHS emphasizes.

Eligibility for Immediate Relief Payments

Per guidance from the HHS, all facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible to receive payments from this initial rapid distribution. Payments to practices that are part of larger medical groups will be sent to the group’s central billing office, while all relief payments will be made to the billing organization according to its Taxpayer Identification Number (TIN).

In order to be eligible to receive these funds, providers must not seek to collect of out-of-pocket payments from a COVID-19 patient that are greater than what they would be otherwise had the care been provided by an in-network practitioner. If a practice had to halt business operations as a result of the COVID-19 outbreak, providers may still be eligible to receive funds if they provided diagnoses, testing, or care for patients with possible or confirmed cases of COVID-19. Per the HHS, “Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19.”

The immediate relief payments hope to alleviate providers in hard-hit COVID-19 areas and those who are struggling to keep their practice open due to delayed care and widespread cancellations of elective procedures.

Payment Distributions 

Payment distributions will be based on the provider’s or practice’s share of total Medicare FFS reimbursements for the year 2019; that year, the total FFS payments were approximately $484 billion. Providers can estimate their anticipated payment by dividing their 2019 Medicare FFS (excluding Medicare Advantage) payments – which can be obtained from their organization’s revenue management system – by $484 billion and multiplying that ratio by $30 billion. 

Receiving Payments

In partnership with UnitedHealth Group (UHG), the HHS will provide rapid payments to eligible providers, as described above, to distribute the initial round of funding. Providers will be paid via their Automated Clearing House account information on file with UHG or the Centers for Medicare & Medicaid Services (CMS) and can expect to receive payments via Optum Bank with “HHSPAYMENT” as the payment description. Providers who receive reimbursements from CMS via paper check can expect to receive a paper check in the mail within the next few weeks.

Providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment within 30 days of receipt. The Terms and Conditions of the funding can be found on the CMS website. If the payment is not returned within 30 days, the HHS will view this as an acceptance of the Terms and Conditions. However, if a provider does not wish to comply with the Terms and Conditions, they must contact HHS within 30 days of receipt of payment and then return the full payment to HHS.

Different Types of Providers

All relief payments are being made to providers according to their tax identification number (TIN). Large organizations will receive payments for each of their billing TINs that bill Medicare, and should look to the part of their organization that handles Medicare billing to identify details on Medicare payments for 2019. Employed physicians should not expect to receive an individual payment directly; instead, their employer’s organization will receive the relief payment as the billing organization. Similarly, individual physicians and providers in a group practice are unlikely to receive individual payments directly; the group practice will receive the relief fund payment as the billing organization. Solo practitioners who bill Medicare will receive a payment under the TIN they use to bill Medicare.

The Remaining $70 Billion 

As part of the $100 billion guaranteed by the CARES Act, the remaining $70 billion will be comprised of targeted distributions focused on providers in areas particularly impacted by the virus, rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, as well as providers requesting reimbursement for the treatment of uninsured Americans. More guidance is expected on the structure of these payments in the coming weeks.

COVID-19 Medical Expenses

The federal government is taking measures to ensure Americans are not surprised by medical expenses and are protected against financial obstacles that might prevent them from seeking care or getting tested and treated for COVID-19. A portion of the Provider Relief Fund will be used to reimburse healthcare providers at Medicare rates for COVID-related treatment of the uninsured. However, providers are prohibited from “balance billing” any patient for COVID-related treatment in order to be eligible.

In addition, the Families First Coronavirus Response Act requires private insurers to cover an insurance plan member’s cost-sharing payments for COVID-19 testing. Further, the government has secured commitments from private insurers – such as Humana, Cigna, UnitedHealthGroup, and the Blue Cross Blue Shield system – to waive cost-sharing payments for treatment related to COVID-19 for its members and make medical care more accessible.

Heavily anticipated by providers across the nation, the latest guidance helps to clarify eligibility, distribution, and payment concerns regarding the Provider Relief Fund. Eligible practices and providers may soon expect to receive payments from the immediate round of funding. In the meantime, medical professionals can access more information about and the latest developments concerning the CARES Act Provider Relief Fund here.