HHS Clarifies Reporting Requirements for CARES Act Relief

HHS has issued a Post-Payment Notice of Reporting Requirements to clarify how recipients of more than $10,000 in Provider Relief Fund (PRF) dollars under the CARES Act need to report their spending.

The Notice outlines the data elements that must be reported by PRF recipients who accepted one or more payments exceeding $10,000 and thereby agreed to the Terms & Conditions of the program. It also clarifies the eligible uses of PRF funds.

Use of Funds
PRF funds may be used on:

  • Healthcare-related expenses attributable to COVID-19 that another source has not reimbursed and is not obligated to reimburse.
  • Amounts not fully expended on healthcare-related expenses attributable to COVID-19 that were applied to lost revenues, represented as a negative change in year-over-year net patient care operating, net of the healthcare-related expenses attributable to COVID-19.

If you do not spend all of the PRF funds by the end of 2020, you will have an additional six months to use them on the expenses listed above, and additional reporting will be required.

Data Elements
To assess if the funds were used properly, HRSA and HHS are requiring the following information in the reports:

Demographic information
Reporting entities must provide the entity that received the fund, its primary tax identification number (TIN), fiscal year-end date and federal tax classification. National provider identifier is optional.

2020 expenses attributable to Coronavirus not reimbursed by other sources:

  • Reporting entities that received between $10,000 and $499,999 must report these expenses net of other reimbursed sources in two categories: G&A expenses and other healthcare-related expenses.
  • Reporting entities that received $500,000 or more must provide more detailed information within the two categories:
    • G&A expenses attributable to Coronavirus and incurred above what has been reimbursed by other sources (i.e. mortgage/rent, insurance, personnel, fringe benefits, lease payments, utilities/operations and other overhead expenses)
    • Healthcare-related expenses attributable to Coronavirus and incurred above what has been reimbursed by other sources (i.e. supplies, equipment, IT, facilities and other healthcare-related expenses paid to prevent, prepare for or respond to COVID-19.)

Lost revenues attributable to Coronavirus
Revenues and expenses in this section of the report will include all lost patient care revenues and patient care related expenses attribute to Coronavirus. These losses will be represented as a negative change in year-over-year net operating income from patient care related sources.

This section will also require data on other assistance received in 2020, including Paycheck Protection Program funds; FEMA assistance; CARES Act testing relief; local, state and tribal government assistance, business insurance payouts and other federal and coronavirus-related assistance received by the TINs included in the report.

Additional non-financial data
The report must include non-financial data per quarter, such as personnel, patient and facility metrics; changes in ownership; and single audit status.

These requirements apply to all CARES Act PRF distributions except the Nursing Home Infection Control distribution or the Rural Health Clinic Testing distribution. HHS has announced the following timeline for compliance:

  • January 15, 2021: reporting system opens for providers
  • February 15, 2021: first reporting deadline for all providers on use of funds
  • July 31, 2021: final reporting deadline for providers who did not fully expend PRF funds prior to December 31, 2020

Learn More from Our Industry Advisors
Our advisors understand these guidelines and related calculations can be complicated and overwhelming. Join us on October 1, 2020 at 1:00 p.m. EDT for a live webinar presented by Joseph Tomaino, CEO of Grassi Healthcare Advisors, and David M. Rottkamp, Not-for-Profit Practice Leader, to learn more and get your reporting questions answered.

Click here to view the webinar recording.

David M. Rottkamp David M. Rottkamp, CPA, is an Audit Partner and Nonprofit Practice Leader, at Grassi. David has over 36 years of experience providing audit and advisory services to the not-for-profit and health care industries. David focuses on organizations serving individuals with special needs, religious organizations, educational institutions, membership associations, social service providers, healthcare providers, foundations, and the arts and culture world. David’s technical knowledge allows... Read full bio

Joseph Tomaino Joseph Tomaino is the Chief Executive Officer of Grassi Healthcare Advisors, LLC and has nearly 40 years of healthcare management experience working in the not-for-profit, for-profit and government-sponsored segments. As a chief executive officer, chief nursing officer, consultant, and educator, Joseph has worked with provider organizations and payers across the U.S. as an architect of value based care -- improving clinical effectiveness along with... Read full bio