The COVID-19 pandemic has caused immense financial strain on healthcare systems across the nation. As a result, Congress passed a $3 trillion stimulus package that includes $100 billion for hospitals and other healthcare providers. While this relief for healthcare organizations is much needed, it can also add confusion. What can organizations use these stimulus funds for? What are the risks and compliance requirements? Bobbi Brown, Senior Vice President of Professional Services, and Dan Orenstein, General Counsel at Health Catalyst, discuss answers to these questions and more. With over thirty years of experience in healthcare financial planning and analysis, Bobbi shares her unique perspective on the stimulus package and how providers can use these funds in their recovery planning. Dan has over two decades of legal experience in healthcare and discusses the specifics of compliance requirements. In this webinar, Bobbi and Dan address the following: -Explain significant sections of the four laws passed, including the CARES Act. -Review program details of the Provider Relief Fund. -Explore the use of the funds and compliance with terms and conditions. -Discuss policy changes to better prepare for healthcare emergencies.

1. Congress Gave Hospitals and Providers
$100B in the Coronavirus Stimulus Package:
What Now?
Bobbi Brown
Senior Vice President, Professional Services
Health Catalyst
June 11, 2020
Dan Orenstein
General Counsel
Health Catalyst

2. Explain major sections of four
laws passed including CARES act
Review the stimulus programs
Explore use of funds and
compliance with terms & conditions
Discuss impacts and
improvements for healthcare policy
Objectives

3. Stimulus Dollars
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Reading Regulations- Challenge
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H.R. 6074 Passed March 6, 2020 for
• Dollars for HHS, Dept of State, Small Business Admin
• Vaccines and other medicines
• Grants for state, local, and tribal public health agencies
• Loans for affected small businesses
• Evacuations and emergency preparedness activities at U.S.
embassies and other State Department facilities
• HHS can waive restrictions for telehealth
Coronavirus Preparedness & Response
Supplemental
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$8.3 B

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H.R. 6201 Passed March 18, 2020 for
• 😷 Paid sick leave
• Tax credits
• COVID-19 testing- reimburse cost for uninsured individuals
• Medicaid fund-FMAP 6.2% increase
• Expanding food assistance (SNAP)
Families First Coronavirus Response Act
(FFCRA)
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$3.5 B

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H.R. 748 Coronavirus Aid, Relief, and Economic Security
Passed March 27, 2020
• Purpose: Providing emergency assistance and health
care response for individuals, families and businesses
affected by the 2020 coronavirus pandemic.
CARES Act
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$2.2
Trillion
• Individual- unemployment
• Small Business
• Large Business- other industries
• Public Health
• Education
• Safety Net
• State and Local Government
• $100 Billion Distribution Providers
• $30B Grants
• $20B Grants
• $10B Grant- hard hit
• $10B Rural grants
• $.4 B Indian Services
• $29.6B SNF, future hot spots, uninsured

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H.R. 266 Continuation of CARES Act Signed on April 24, 2020
Paycheck Protection Program and Health Care
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• Set asides or carve outs established
– Clarifies eligibility
• Allocations changed for hospitals
– Net revenue
– Hardest-hit areas
• Carve out for rural, Indian Health
$484 Billion

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Continued Economic Stimulus
H.R. 7070 Paycheck Protection Program Flexibility Act of 2020
Passed on June 3, 2020
• Covers period up to 24 weeks (was 8 weeks)
• Maturity up to 5 years (was 2 years)
• Reduce minimum spend on payroll to 60% (was 75%)
• New safe harbors for forgiveness
Additional Stimulus-Bill Passed by House and Stalled in Senate
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For an additional amount for “Public Health and Social
Services Emergency Fund”, $100,000,000,000 to remain
available until expended, to prevent, prepare for, and
respond to coronavirus, domestically or internationally,
for necessary expenses to reimburse, through grants or
other mechanisms, eligible health care providers for health
care related expenses or lost revenue that are attributed
to coronavirus.
10
Language

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Things are Dynamic
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June 2, 2020 Press release
HHS Provides Additional $250M to help
U.S. Healthcare systems respond to COVID-19
June 4, 2020 Press release
HHS Announces New Lab Data Reporting
Guidance for COVID-19

12. Specifics
Many sources of $
Various Federal Agencies
Funds distributed in many ways
Short and long term dollars

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Which COVID-19 program was most helpful for your organization?
• Provider Relief Fund – 40%
• Accelerated and Advance Payment – 12%
• FCC- COVID-19 Telehealth Program – 10%
• FEMA Public Assistance Program – 0%
• Not sure – 38%
Poll Question #1
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Provider Relief Fund: NOT A LOAN, GRANT
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https://www.hhs.gov/provider-relief/index.html
• Immediate infusion of $50B
• First round: $30B sent to provider accounts on April 10, 2020
• Second round: $20B distribution began April 26, 2020
Specific time period to sign-in and attest to terms and conditions
• 90 days from receipt of payment
Allocation Formula:
• First round: Your Medicare FFS revenue to Medicare FFS
($121,000,000/$484,000,000,000) x $30B = $7,500,000
• Second round: Revenue from tax reports or incurred losses (Tax Yr Rev x $50B)/$2.5T-
Initial funds from first round
Distribution data is public. For $30M: 318,168 providers attested/received an
allocation as of end of May

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Billed Medicare in 2019, Not excluded from participation
Payment used only to prevent, prepare for and respond to coronavirus.
Reimbursement for health care related expenses or lost revenue
Not used to reimburse expenses/losses from other sources.
No balance billing
Submit reports:
• >$150,000 no later than 10 days after end of quarter
• Amount of funds received, amount of funds expend
• Detail list of actions, projects, jobs created/retained,
subcontracts
• Agree to cooperate in audits
Terms and Conditions on Provider Relief Fund
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https://oig.hhs.gov/about-oig/strategic-plan/COVID-OIG-S
https://www.hhs.gov/provider-relief/index.html

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Dollars distributed to 395 hospitals
with highest proportion of COVID-19
inpatient cases (70% of cases)
Fact:
• 184,037 COVID-19 inpatient
cases thru April 10- each recipient
funding equal $76,975 per case
Distributed $10B based on IP
admissions and $2B on proportion of
disproportionate share
High Impact Hospitals Covid-19 Response $12B
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Source: High Impact Relief Fund CARES act website
$ # of Hospitals
NY 5,026B 90
NJ 1,708B 53
MI 900M 30
IL 694M 33
MA 495M 22
LA 399M 15
Top 6 States

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Dollars distributed May 22, 2020 to
13,237 facilities
Uses:
• Testing
• Staffing
• Lost revenue
• PPE
Distributed with base $50,000 + $2,500 per
bed (6 or more certified beds)
Must comply with audit and reporting rules
SNF Covid-19 Response $4.9B
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Source: SNF Relief Fund
CARES act website
$ Millions
NY 394
TX 392
CA 356
OH 314
IL 289
Top 5 States

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Dollars distributed 7,988 providers 13,237 facilities
• Rural acute care hospitals
• Critical Access Hospitals (CAH)
• Rural Health Clinics
• Community Health Centers in rural
Distributed with base payment + % of
annual expense
Must comply with audit and reporting rules
Rural Covid-19 Response $10B
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Source: Rural Relief Fund
CARES act website
$ Millions
TX 634
MN 385
IA 383
KS 382
KY 372
OH 368
WI 363
Top 7 States

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1. Fund primary health care- grants under HRSA Amount $100M
Average award $70,000 (base amount plus volume)
Health Centers
Currently serve 1 in 12 people nationwide
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Two separate grants – 1387 grants awarded as of April, no applications
2. Fund detection, prevention, treatment, diagnosis HRS
$1.32B Average award $950,000 (base amount plus volume)
Reporting requirements:
Quarterly progress reports required

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Steps:
1. Enroll as provider participant
2. Check patient eligibility
3. Submit patient information
(submit claims electronically)
4. Receive payment via direct deposit
5. No balance bill to patient
6. Agree to audit
More for Providers –
Covid19 Claims Reimbursement
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Reimbursement for costs of COVID19 - testing, services to uninsured ASPR,
CMS $1B paid to provider through billing cycle for services after February 4th.
https://www.hrsa.gov/coviduninsuredclaim
Paid at Medicare rates,
Training held April 29, 2020

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As of April 26
• CMS received 21,000 hospital requests
• 24,000 for part B
As of May 20
• Payout documented at $92M Part A
• $8M Part B
More for Providers –
Accelerated and Advance Payment
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Loans: Accelerate Cash flow, Funds to prevent, prepare for and respond to
COVID-19 expenses and lost revenue-PPE, supplies, construction, surge
ASPR $100B Detail on next slide- program under evaluation.
Reporting,
Documentation and
audits- recipients required
to submit reports and
maintain documentation

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Accelerated and Advance Payment
for Providers
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https://www.cms.gov/newsroom/press-releases/cms-news-alert-april-9-2020
https://www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf
https://www.cms.gov/files/document/covid-dear-clinician-letter.pdf
Eligibility Process Recoupment
1. Billed Medicare claims
within last 180 days
1. MAC website and
submit form
1. Due after 120 days and
CMS will lower claims
payment to recoup
2. Not in bankruptcy/no
outstanding Medicare
delinquencies
2. Hospitals request up
to 100% of six months
of payments
2. Hospitals have one year to
repay, other providers 210
days
3. Not under active
medical review
3. Others request up to
100% of three months
of payments
April 26th CMS suspends
and reevaluating program.

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Hospital Medicare Payments Changes & Delays
Reimbursement through billing process
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• Suspend 2% sequestration (May-Dec 2020)
• Increase 20% MSDRG payment increase for patients diagnosed
with COVID19
– April 15th published waiver- use codes B97.29(prior to March 31)
U07.1 (COVID-19) (April 1, 2020)
• DSH reductions suspended until Dec 2020
• Pausing reductions for DME (Durable Medical Equipment)
• Stopping reductions in clinical lab test going to start in 2021
(delay to 2022)
• Flexibility to bill home and community-based services

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Physician/Small Providers
Small Business Association Loans < 500 Employees, via Banks
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https://www.uschamber.com/sites/default/files/023595_comm_corona_virus_smallbiz_loan_final.pdf
https://www.uschamber.com/sites/default/files/uscc_covid19_sb-economic-injury-disaster-loans.pdf
https://home.treasury.gov/system/files/136/SBA-Paycheck-Protection-Program-Loan-Report-Round2.pdf
Paycheck
Protection Program
(PPP)
• 2.5X monthly payroll
(max of $10M) at 4%
• No payment 12
months, then 10-year
loan
• Loan Forgiveness for
maintaining payroll
Economic Injury
Disaster Loan
(EIDL)
• Up to $2M at 3.75%
• 30 years repayment
• Cannot duplicate
funds used for PPP
As of May 23, 2020
4.4 loan count total
of $511B Average
loan $116K
64% of loan count
for loans $50K and
under

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As of May 25, FCC awarded $68.2M to 185 providers
Separate FCC pilot program Connected Care Pilot
• Over 3 years cover costs of eligible
services and equipment
• Target low income, veterans
• Application due in mid-May
FCC Covid-19 Telehealth Program
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Source: Sage Growth/Black Box market
Research: Evolving US Healthcare Needs
&Attitudes during Covid-19 April 9, 2020
Main program for providers
Application process on-line
Help providers provide telehealth services to
patients at their home or remote locations.
https://www.fcc.gov/covid-19-telehealth-program
https://docs.fcc.gov/public/attachments/FCC-20-44A1.pdf

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Example of FCC Grant (Public Information)
Program for equipment, devices not for personnel
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Applicants:
1. Monthly bill
with an invoice
to FCC
2. Attach
documentation
of actual
payment
3. Agree to audit

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States and Local Government Plus Pnp
PNP is Private Non-Profit
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Public health emergency management activities for prevention and
response to COVID-19
Emergency work such as labor (OT, premium), supplies, equipment
Work must be documented and reasonable in nature and amount
Public assistance grants under FEMA $100M
Applications accepted-duration of public health emergency
https://www.aha.org/advisory/2020-03-25-coronavirus-update-fema-public-assistance-application-information

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CMS
• Reporting requirements- delay in due date
• Cost report filing- delay in due dates
• Telehealth services
• Inpatients in temporary expansion sites
• Critical Access Hospitals (CAH) ability to go above 25 beds
and 96 hr. LOS
• Distinct units
• Discharge planning
• Stark and Anti-kickback
Office for Civil Rights- No penalties for HIPAA violations if
operating in good faith during pandemic.
Flexibilities and Waivers
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As funds are distributed, healthcare organizations now need to comply
with terms and conditions.
Which one program has you most concerned for compliance/audits?
• Provider Relief Fund – 35%
• Accelerated and Advance Payment – 17%
• PPP Paycheck Protection Program – 30%
• FCC- COVID-19 Telehealth – 11%
• FEMA-Public Assistance Grant – 7%
Poll Question #2
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Summary of Stimulus Bills
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Added note: CARES act includes section 3854 Treatment of Sunscreen
Innovation Act
Many programs
and sources of
money
waivers of
regulations
helpful
Need to
prepare and
plan
Documentation
of use of funds
is critical

31. Provider Relief

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Provider Relief Fund - Recap
Terms and Conditions
Practical Considerations for the Use of Provider Relief Funds
Reporting, Compliance, and Audit
Policy Changes to Better Prepare for Public Health Emergencies
Disclaimer: This presentation is for information purposes only. It is not legal or
compliance advice. For legal and compliance advice, you should consult your legal
and compliance advisors.
Contents
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Eligibility and Payment Formula Under
the General Distribution
Eligibility –
• Provider must have billed Medicare on a fee-for-service basis in 2019.
• Provide or provided after January 31, 2020 diagnoses, testing, or care for
individuals with possible* or actual cases of COVID-19. *”HHS broadly
views every patient as a possible case of COVID-19.”
Calculation – Lesser of 2% of a provider’s 2018 net patient revenue
or the sum of incurred losses for March and April, 2020.
• Estimate of payment:
(Individual Provider Revenues/$2.5 Trillion) X $50 Billion
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Eligibility and Payment for the Rural
Targeted Distribution
Eligibility –
• Provider must be a rural acute care general hospital, Critical Access Hospital (CAH),
Rural Health Clinic (RHC) or Community Health Center in a rural area.
• Provide or provided after January 31, 200 diagnoses, testing, or care for individuals
with possible* or actual cases of COVID-19. *”HHS broadly views every patient as a
possible case of COVID-19.”
Calculation – Minimum base payment plus a percent of annual expenses.
• Minimum amount of $100,000 covers RHCs with no reported Medicare claims, such
as pediatric RHCs, and CHCs lacking expense data.
• Minimum amount of $1M for rural acute care general hospitals and CAHs.
• Rural hospitals received a graduated base payment plus approx. 2% of total
operating expenses reported on most recent, publicly available cost reports.
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Eligibility and Payment for the High-Impact
Area Targeted Distribution
Eligibility –
• Hospitals and health systems that provided inpatient care for 100 or more
COVID-19 patients through April 10, 2020.
• 336 payments made to 395 hospitals and health systems.
Calculation –
• $10 billion allocated based on a fixed amount per COVID-19 admission.
• Remaining $2 billion distributed based on each hospital’s portion of
Medicare’s Disproportionate Share Hospital (DSH) payments and
Medicare uncompensated Care payments (UCP).
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Provider Relief Funds Showed up
in Your Account…
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There Are a Few Things You Need to Do in
Connection With the Provider Relief Fund
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• Use the funds in accordance with statutory requirements
and terms and conditions
• Attest to terms and conditions
• Report on a regular basis on use of funds
• Prepare for audits and ongoing compliance

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Can your organization use Provider Relief Funds for operational
expenses other than direct COVID-19 healthcare expenses?
• Yes – 71%
• No – 29%
Poll Question #3
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“The Recipient certifies that the Payment will only be used to prevent,
prepare for, and respond to coronavirus, and shall reimburse the
Recipient only for health care related expenses or lost revenues that are
attributable to coronavirus.”
Key terms to discuss:
• “Health care related expenses” – How should providers think about the
statutory enumerated list?
• “Lost revenues” – Operational costs that are included
Documentation is critical to showing appropriate use of funds
• Mechanism to track expenses should be used. Tracking should include the
use of funds by the billing entity that received the funds.
Terms and Conditions – Use of Funds
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“The term ‘healthcare related expenses attributable to coronavirus’ is a broad term that may
cover a range of items and services purchased to prevent, prepare for, and respond to
coronavirus, including:
• supplies used to provide healthcare services for possible or actual COVID-19 patients;
• equipment used to provide healthcare services for possible or actual COVID-19 patients;
• workforce training;
• developing and staffing emergency operation centers;
• reporting COVID-19 test results to federal, state, or local governments;
• building or constructing temporary structures to expand capacity for COVID-19 patient care or to
provide healthcare services to non-COVID-19 patients in a separate area from where COVID-19
patients are being treated; and
• acquiring additional resources, including facilities, equipment, supplies, healthcare
practices, staffing, and technology to expand or preserve care delivery.”
See “CARES Act Provider Relief Fund FAQs,” https://www.hhs.gov/sites/default/files/provider-relief-
fund-general-distribution-faqs.pdf
Use of Funds – “Health care related expenses”
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“Providers can use Provider Relief Fund payments to cover any cost that the lost revenue
otherwise would have covered, so long as that cost prevents, prepares for, or responds to
coronavirus. Thus, these costs do not need to be specific to providing care for possible
or actual coronavirus patients, but the lost revenue that the Provider Relief Fund payment
covers must have been lost due to coronavirus. HHS encourages the use of funds to cover
lost revenue so that providers can respond to the coronavirus public health emergency by
maintaining healthcare delivery capacity, such as using Provider Relief Fund payments to
cover:
• Employee or contractor payroll
• Employee health insurance
• Rent or mortgage payments
• Equipment lease payments
• Electronic health record licensing fees”
The above are examples only. Other operating expenses will also constitute a qualifying use of funds
if the above requirements are met.
Use of Funds – “Lost Revenue”
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• Recipient will not use the funds to reimburse expenses or
losses that have been, or can be, reimbursed from other
sources.
• General Provisions: Prohibits use of funds for various items,
including excessive executive pay, gun control advocacy,
lobbying, abortion funding, embryonic research, unpaid
federal tax liability.
• 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.
Terms and Conditions – Other terms
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• A recipient of funds must confirm agreement with
the terms and conditions by written attestation.
• The deadline for attestation has been extended to
90 days from the date of receipt of payment.
– E.g., Attestation due July 11 for April 10 payment, July 23
for April 24 payment
• Reporting - Providers receiving more than $150k
of funds must provide quarterly reports containing
a detailed list of all projects or activities for which
the funds were used.
Attestation and Reporting
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• Total amount of funds received from HHS
• Amount of expenditures
• Detailed list of all projects or activities for which
covered funds were expended:
– Name and description of project/activity
– Estimated number of jobs created or retained, where
applicable
– Detailed information on any sub-contracts or
subgrants awarded.
Reporting – What Needs to Be Included
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• Providers must maintain appropriate records
and cost documentation to substantiate
compliance with the terms and conditions.
• Providers must agree to submit copies of
records upon request and comply with all audits
by HHS and OIG.
– The CARES Act authorizes OIG to audit both interim
and final payments made under the program.
– OIG is required to report to Congress on its audit
activity.
– There is likely to be a high level of auditing and
oversight going forward.
Records Requirements and Audits
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We Continue to See Heroic Efforts:
But COVID-19 exposed many ways in which our public health
infrastructure was unprepared for the crisis.
46 Photo source: PBS Utah, https://www.pbs.org/newshour/health/for-health-care-workers-fighting-covid-19-crisis-spurred-innovation

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Policy Changes :
Data Use – Expand data use rights to enable use and disclosure
by business associates of covered entities of limited data sets and
de-identified information during the COVID-19 emergency.
• This will enable accelerated research on effective clinical
interventions and treatment pathways, and will help expand
patient monitoring and help with contact tracing efforts.
Testing and Contact Tracing – Expand immediate funding to states,
localities, and health systems to support their testing and contact
tracing efforts.
That can help to be better prepared at the health system, local, state,
and national levels in the near term
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Policy Changes :
Hospital and Health Systems Public Health
Response Infrastructure – Provide funding to hospitals and health
systems to build out their epidemic response data systems,
including registries, reporting, surveillance, dashboards
Funding to States and Localities for Public Health
Response Infrastructure – Provide funding to States to build out
their public health response data systems, including registries,
reporting, surveillance, dashboards
That can help to be better prepared at the health system, local, state,
and national levels in the intermediate term
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Policy Changes :
National Public Health Response Infrastructure – Provide funding for
the development of a national Epidemic/Pandemic Information Network.
• Overhaul CDC’s data aggregation and reporting system
• Expand the mission of PCORI and National Patient-Centered
Clinical Research Network (PCORNET)
• Mandate healthcare data vocabulary standards in EHRs
That can help to be better prepared at the health system, local, state,
and national levels in the intermediate term
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Policy Changes :
National Patient Identifier – Establish a national patient identifier. This will be critical
in public health emergencies to (a) enable healthcare organizations to link patients across
providers and across HIEs, and (b) for surveillance and contact tracing efforts.
HIPAA – Modify HIPAA to:
• In an emergency, grant waivers, and enable data aggregation, and use and
disclosure of limited data sets and de-identified information for public health
purposes and research.
• Implement systems to enable full transparency to patients and to support greater
control of uses and disclosures of their data when there is no emergency.
Interoperability – Continue to support interoperability across the healthcare industry,
and enforce against information blocking practices.
That can help to be better prepared at the health system, local, state,
and national levels in the intermediate term
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51. © 2020
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Sept. 1 – 3, 2020
• Transformative Role of Data and Analytics in the New Normal
• Unique and Innovative Virtual Experience
• Nationally Recognized Keynotes
• Educational, Case Study, and Technical Breakouts
• Virtual Analytics Walkabout Projects
• Virtual Machine Learning Marketplace
• Digital Innovation Showcase
• Virtual Networking (”Braindate”)
• CME Accreditation for Clinicians
The Healthcare Analytics Summit 2020 - Virtual
51
Cost : $99 per registrant
Register here: https://hasummit.com
Eric Topol, MD
Author, AI expert and
healthcare futurist
Vice Admiral Raquel C. Bono, MD
Former CEO and Director of the U.S.
Defense Health Agency and Head of
Washington state’s COVID-19 healthcare
response team
Yonantan Adiri
CEO and founder, Healthy.IO,
former CTO to Israeli
President Shimon Peres
Ari Robicsek, MD
Chief Medical Analytics Officer at
Providence St. Joseph Health and
a specialist in infectious disease
More keynotes to be announced soon!

52. © 2020
Health
Catalyst
Would you like to be considered for a complimentary pass to attend the
Virtual Healthcare Analytics Summit?
• Yes
• No
Poll Question #4
52

53. Q&A
53
Bobbi Brown
Senior Vice President Professional Services
Health Catalyst
Dan Orenstein
General Counsel
Health Catalyst

54. Thank you!