Inquiries About Attestation Requirements in the HHS Terms and Conditions Document
American Chiropractic Association


ACA has received several inquiries about attestation requirements in the U.S. Department of Health & Human Services (HHS) Terms and Conditions document related to the recent funds made available to Medicare providers, including chiropractors.

Specifically, some chiropractors have asked, while it may be likely most DCs treated a patient who may have had COVID-19, but are they going to have to prove that? Also, how do they illustrate the money was used to prevent, prepare for, and respond to coronavirus? Is just agreeing to the terms and conditions enough proof?

In addition to the “possible or actual” language in the terms and conditions , HHS language in which, among other things, states: ”If you ceased operation as a result of the COVID-19 pandemic, you are still eligible to receive funds so long as you provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19.” (emphasis added)

Therefore, there is no need to prove that the money was used to prevent, prepare for, and respond to coronavirus under the above HHS guideline. 

The above is designed to provide accurate and authoritative information with regard to the subject matter covered. It is presented with the understanding that the ACA is not engaged in the rendering of legal, accounting or other professional service(s).