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On Oct. 6, the Federal Emergency Management Agency (FEMA) released a document outlining three options for offsetting eligible expenses for any payments received from third-party payers for patient care (a.k.a. “duplication of benefits” or DOB).
Option 1: Applicants are encouraged to provide their own data and description of the methods used to assess duplication and take reductions where needed. FEMA will assess the submitted methodologies’ reasonableness on a case-by-case basis.
Option 2: Applicants who do not provide their own method and data for addressing DOB, or if a method is determined to not be reasonable, and the project is less than $25 million, FEMA will use public data sources to assess duplication with patient care revenue using FEMA’s DOB method. Under this option, FEMA clarifies that it will focus on the likelihood that specific costs have DOB with patient care revenue. Costs with a low likelihood of duplication in a category are allowed and not limited by ceilings. High-likelihood items are limited by allowable ceilings. The methodology document includes a table describing the risk of DOB for each cost category.
Option 3: Applicants who do not provide their own reasonable method and supporting information for addressing DOB — and the project is greater than $25 million — must submit their operating expense and patient care revenue data, which FEMA will use to assess duplication using FEMA’s DOB method.