Help Me File My Own Report

The Basics of Reporting:

Did you receive more than $10,000 or less than $10,000?

  • If you received less than $10,000 all you need to do is maintain your records. You do not need to file a report.

  • If you received more than $10,000 you will need to report your expenditures or have an audit depending on how much money you received. See What do I need to include in my report for more information LIVE LINK

No matter how much funding you received, you will need to maintain records. Here’s what you you need to do to maintain your records:

A. Maintaining your Records

  • You will need to document your costs and maintain your records for a certain period of time.

    In terms of documenting your costs. You should be able to provide evidence for the costs and lost revenues which are being reimbursed through the funds you are receiving. If you do this, the funds do not need to be paid back. You should be able to trace the funds you spend to qualified expenditures. In other words track what money is spent on what and be sure that what you are spending the funds on are qualified expenses. Document the amount and the qualified expense, and be able to show it in terms of which account it is coming from. If you have been awarded multiple funds, be sure your software documents which fund is paying for which expense and from what account. To make sure you are documenting which fund the money is coming from make sure to include the CFDA title and number, Federal award identification number and year, name of the HHS awarding agency, and name of the pass-through entity, if any for each funding program you are participating in.

  • You may generate your reports on a cash or accrual basis, whichever accounting basis you use normally.

  • Your financial management system may be able to generate such reports.

    If they cannot, we can help by gathering the data we need inside your current software and preparing your reports for you. Our reporting services, which are done by licensed CPAs are itself a qualified expense, and funding can be used to pay for it.

  • You must also have written procedures which can be used to guide those involved in purchases which may be qualified so that the expenses can be input into your financial management system in a way where the reports are generated properly. Your system may be able to automatically characterize what is qualified and what is not, and to what extent.

    Some key questions you need to ask:

    • Have your expenditures been accounted for with a different fund?

    • Having accepted the funds, have you exceeded the profitability threshold for the year?

    We can help you answer these questions and report your expenditures properly. We make sure that we differentiate between what is an allowable expense and what is not, and only assigns expenditures to a fund when it has not already been assigned to another fund. We also take into consideration what type of healthcare provider you are, what types of funds you received and therefore what kind of report you need to file.

  • You should always have a handle on how much funds have already been used and how much is left. This should be accessible through your payment management system.

  • You will need to keep your records for three years after the last day of the quarter after funding has stopped. This would be three years from when your last report is generated as using the allowable amount of funding. Documents which need to be kept include: financial records, supporting documents, statistical records, and all other records which are pertinent to this federal funding event. Here are some events which would change this 3 year requirement.

  1. If you are under litigation, claim, or audit, you would be required to keep your records until such litigation, claim or audit has ended and final action has been taken.

  2. If the funding agency asks you in writing to retain your records past 3 years.

  3. If you acquired real property and/or equipment, keep the records for those until 3 years after you have sold, donated or otherwise disposed of it.

  4. ‘When records are transferred to or maintained by the HHS awarding agency or pass-through entity, the 3-year retention requirement is not applicable to the non-Federal entity.

  5. You will need to maintain your records for three years after all the funding has been spent.  Three years after your fiscal year has ended.  For example if your fiscal year ends on December 31st, but you received a patient visit on January 15th, 2021 and were being supported by the funds you received, then you would need to maintain your records until December 31st 2024. Furthermore, you would have to document that visit as income which is supported by the funding.  Once your visits are no longer supported by the program funds, that would be the fiscal year end when the 3 year timer would begin.

  6. So long as the expense helps to prevent, reduce, x, y or z whether it is a direct or indirect cost, document it and keep it for 3 years after the last fiscal year has ended where you have received income by support of the fund money received or expended money from the fund.

  7. You may be requested to transfer your records at the request of HHS, or they may ask you to retain your records for longer if they feel that your records have a long term retention value or have a continuous joint use.

  • The format of your documents matter. The awarding agency prefers to have your documents in an open, machine readable format rather than closed. This means that you should use programs to store your data that they can easily read, not a closed format which requires getting that software to be able to view it. An example of an open format is an excel spreadsheet, as an employee of the government would be able to open this document and view its contents. A closed format would be a file that could not be accessed unless the issuing agent buys a software to view the file.

  • The awarding agency must have access to your documents on demand. Be ready to give access to your documents, papers or other records to the HHS awarding agency, Inspectors General, the Comptroller General of the United States, and the pass-through entity to which some of the funds went to.  This is to assist in any audits, examinations, transcripts or excerpts. 

    This includes access to company personnel for interviews and discussion related to such documents. 

    Only in rare cases would HHS awarding agency ask for the true names of victims in a crime, if ever applicable, if the information were court ordered or subpoenaed pursuant to a bona fide confidential investigation.  Measures must be taken to keep this confidential information protected.  

    Access to documents last for as long as records are retained.  So if you retain your records past the mandatory 3 years, then you must give access to those records if requested. 

    You will need to submit copies of your records and cooperate with audits if requested to do so.  This is a requirement of the terms and conditions when you accept the payments.

  • How much money you received can be publicly viewed on the HHS website by others. The HHS may not restrict you from sharing your documents, manuscripts, and data with the public unless the information is protected personally identifiable information (PII), other confidential information pursuant to the Freedom of Information Act or controlled unclassified information pursuant to Executive Order 13556. Nor will the awarding agency dictate that your records must be made public. Although, they will be subject to the Freedom of Information Act.

Complete information on cost documentation and maintenance of records can be found, as applicable, in 45 CFR § 75.302 (page 270-271)  – Financial management and 45 CFR § 75.361 through 75.365 (page 293-294): https://www.govinfo.gov/content/pkg/CFR-2017-title45-vol1/pdf/CFR-2017-title45-vol1.pdf.

B. How do I file my report?

The portal for submission of reports is not yet available.  Health and Human Services (HHS) plans to make the portal available on 1/15/2021.  When it is available you will be able to submit your report.

Would you like to know where to go to file your online report?

Provide your email address and we will email you where you need to go online to submit your report.

As of 1/15/21 it has not been disclosed where to submit your report.

C. When do I need to file my report?

The deadline for report submission is February 15th, 2021.  This is the deadline for reporting all 2020 expenditures.  

Sign up for our email notifications here to be updated on report submission deadlines if they change.

If you have not spent all the money yet, you have until June 30th, 2021 to spend all your money on eligible expenses.  You will then report 2021 expenditures by July 31st, 2020.   

You must report your expenditures and they must be allowable in order for you to not have to pay HHS back.

D. What do I need to include in my report?

i. I received less than $10,000 in Provider Relief Funds

If you received under $10,000 in funding during 2020:

Although you will not have to submit your records.  You will need to have your documentation ready and retain and bear access to those documents as per the instructions above in case HHS asks you what you did with the money you received.   Furthermore, if asked for by HHS, your reports must be current, accurate and give complete disclosure of the use of the funds on an annual basis.
  
You will also need to follow the Terms and Conditions set forth in your award.  You can find Terms and Conditions for your program below. LIVE LINK

ii. I received between $10,000 and $499,999 in Provider Relief Funds

If you received between $10,000 to $499,999

General Guidelines

If you received funding greater than $10,000 but less than $500,000 between all your payment distributions, you will be responsible for reporting.  These general guidelines go over some key features of your reporting requirements as well as some important dates. This reporting is referred to as the post-payment-reporting process.

Here are some key dates:

  • Jan. 15, 2021: the reporting portal will become open to you

  • Feb. 15, 2021: this is the date of the first reporting deadline for use of the provider relief funds you used so far

  • July 31, 2021: this is the final reporting deadline and is only applicable to you if you did not spend all your funds before December 31st, 2020.

Here are some key guidelines for use of funds:

  • Your Provider Relief Funds should be applied as follows and int this particular order:

    1. Any expenses which are healthcare related and are traceable to COVID-19 which have not been reimbursed or are obligated to be reimbursed from other sources.

    2. Any patient care revenues which were lost in 2020 as compared to 2019 because of COVID-19. You are not able to recover lost costs beyond what you made in 2019.

Here are the required reporting data elements for $10,000- $499,999

  1. Revenues Lost:

    • Revenues or net charges from actual patient care

    • Revenue by patient care payor mix: medicare/medicaid, commercial, private, etc.

  2. Expenses traceable to COVID-19:

    • Your general and administrative (G&A) expenses

    • Your healthcare-related expenses

Specific Guidelines on Reporting:

Remember if you, as a Provider Relief Fund recipient, received one and/or two payments totalling more than $10,000 you are required to adhere to the post-payment reporting process.  

It is important to note that these guidelines for reporting do not apply to Nursing Home Infection Control distribution, the Rural Health Clinic Testing distribution or the Health and Resources and Services Administration Uninsured Program.  As stated earlier these reporting requirements will be given at a later date.

To sign up for our email newsletter for reporting requirement updates for your specific industry, sign up here.  

Overview

The funds you received were from a program called the CARES Act PRF program.  They consisted of funds which were designated for healthcare providers from the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136) and the Paycheck Protection Program (PPP) and Health Care Enhancement Act (P.L. 116-139).  They were administered through the Health Resources and Services Administration (HRSA), a department of Health and Human Services (HHS).   By virtue of taking the payment and not returning after 15 days of receiving it, regardless of if you attested to the payment, you have agreed to the Terms & Conditions.  These Terms & Conditions require that you report certain things to the HHS.  

This part of the brochure goes over in length what the latest developments are on reporting requirements.

Reporting will be required for 2019 and 2020.  You will need to report 2019 figures because they are used to determine eligibility on how much funding you can actually apply towards the category of lost revenues.

HRSA has announced that it will have Question & Answer Sessions via webinar before the reporting deadline of February 15th, 2021.  They will also keep updating frequently asked questions for reporting and other topics, which can be found here: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/FAQs/index.html.

You may use your normal method of accounting, cash or accrual, to report the use of your Provider Relief Funds.

Here is the information you will be required to submit:

  1. Part 1 Expenses: Any expenses which are either:

    • a.) healthcare related or

    • b.) General and Administrative (G&A)

      and are traceable to COVID-19 which have not been reimbursed or are obligated to be reimbursed from other sources. These expenses are detailed further below.

  2. Part 2 Expenses: After applying all healthcare and G&A expenses, you may begin to apply funding to any patient care revenues which were lost in 2020 because of COVID-19.  However, you may not apply funds which exceed your patient care revenues of 2019.  In other words, you are not permitted to recover lost costs beyond what you made in 2019.

In addition, if you have not spent your funds in their entirety by the end of 2020, you will have an extra 6 months to use your remaining funds in the same way as you did in 2020.  

You must compare the same reporting periods to their equivalent.  For instance you must compare the whole of 2019 patient revenues to all of 2020 patient revenue.  Similarly, if you are using funds to cover lost revenues in 2021, let’s say from January 2021 - June 30th, 2021, then you must compare those to patient revenues of 2019 from the same respective time frame.

Example

Here is a simple example to explain how you will apply your funding:

Joe is figuring out how to apply his funds for reporting purposes of his Healthcare Facility. He received $7,000 during the first round of general distribution and $4,000 in the second round.  He received a total of $11,000 between both distributions. Because he received more than $10,000 he is required to report.  He only services through Medicaid. Here is what he needs to consider:

Total Expenses for Part 1:
G&A Expenses = $6500
Healthcare Expenses = $1000

Therefore, he applies $7500 first towards the total he received.

G&A ($6500) + Healthcare Expenses ($1000) = $7500.  

For Part 2: 

To figure out the funds which are left to apply to lost revenues take the total funds ($11,000) and subtract from it your healthcare and G&A expenses ($7500).  In other words, Total Funds ($11,000) - Healthcare + G&A Expenses ($7500) = $3500 left over. This $3500 which is left over can be applied to lost patient revenues. 

To find lost patient revenues, you will first need to find what your patient revenue totals were for 2019 and 2020.  For the purposes of Joe, here is what he had. 

  1. Patient Care Revenues in 2019 = $350,000

  2. Patient Care Revenues in 2020 = $347,000

This means his total lost patient care revenues from 2019 to 2020 are $350,000 (Patient Care Revenues in 2020) - $347,000 (Patient Care Revenues in 2019)  = $3,000.

So, Joe in this example is able to apply only $3,000 in lost revenues.  He has $500 left over.  He can spend that on healthcare and G&A expenses in the new year.  Again, he will spend first on healthcare and G&A expenses, and if there is any left, he will expend the remaining on lost revenues.  He has only until June 30th, 2020 to spend the remaining funds.  If he does not, or his patient care revenues exceed that of 2019 in the respective time frame, he would be required to give the money back as no other qualified expenses are allowed.

Other reporting requirements:

Data Elements

  1. Demographic Information

    • a. Name of your organization (Reporting Entity):

      Be sure this name corresponds with the Tax Identification Number that received one or more payments, or you may be an entity that meets the following three criteria.  If so, you will use the name of that entity as the reporting entity:

      1. If you are the parent of one or more subsidiary billing TINS which have gotten payment from the General Distribution, and;

      2. You have providers that were doing diagnoses, testing, caring for individuals who may have had COVID-19, or did have COVID-19 after January 31st, 2020, and

      3. Your entity can attest to the Terms and Conditions

        To note: If the subsidiary received Targeted Distribution payments (targeted distribution payments are for:Rural Distribution; COVID-19 High-Impact Distributions; Skilled Nursing Facilities Allocation and Distribution; Allocation for Tribal Hospitals, Clinics, and Urban Health Centers; Safety Net Hospitals Distributions; Certain Children’s Hospitals Distribution Link to Targeted Distribution Timeline), then the subsidiary reports, and the parent cannot also report on the same funds of this subsidiary. However for General Distribution payments that were payed to subsidiaries, the reporting entity parent can report on those payments and direct the usage of those funds. In other words, don’t claim funds twice on the use of the funds.

      b. Your Tax Identification Number (TIN): Again, this TIN must correspond to the reporting entity that received the payment and attested to it. This may be a social security number or an employer identification number for some.

      c. Your National Provider Identifier (NPI): Although this is optional, it is a good idea to provide it.  This is your unique 10 digit identifier for healthcare providers. 

      d. Your Fiscal Year-End Date and Month

      e. Your Federal Tax Classification: You will need to report what kind of business type you file your taxes under: Sole Proprietor, Limited Liability Corporation (LLC), Partnership, C Corporation, S Corporation, Trust or Estate, or a tax-exempt organization or entity.

  2. No matter how much you received, you will be reporting your expenses in 2020 which are traceable to COVID-19 like treating confirmed or suspected cases, preparing for cases and maintaining capacity which are not reimbursed or obligated to be reimbursed by other sources.   What exactly you report will depend on how much funding you received.

    You will also need to break down your expenses by quarter (Jan - Mar, April - Jun, Jul - Sep, Oct - Dec) for 2019 and 2020 (include 2021 if you did not spend all your funds as of December 31st, 2020).  This will show your losses as they relate to COVID-19 and will justify your extra expenses because of COVID-19, and in turn your use of the provider relief fund payments you received.

    These lists may not include other expenses which you experienced due to COVID-19 which can be included.  The list is meant to help clarify what could be included, but does not limit you to claim other expenses which have been experienced due to COVID-19.

    1. General and Administrative

      a. Mortgage/Rent of a facility where patient care takes place like a clinical setting or medical office building, etc.

      b. Finance Charges, insurance premiums or property taxes for those facilities

      c. Insurance premiums for property, malpractice, and business operations

      d. Personel training, staffing of nurses, temporary employees or contractors, overhead employees like those that cannot be directly related to the product or service but is needed none the less, a receptionist who checks people in, security personel, administrative staff, support personel.  

      Note: you are not allowed to pay executives more than $197,000 with the funds, this excludes fringe benefits below. 

      e. Fringe Benefits/Extra benefits which supplement your regular employee’s salary including: hazard pay, travel reimbursement, employee health insurance, child care assistance, overtime pay, hiring bonuses, retention payments, etc. 

      f. Lease Payments for new equipment or software lease like diagnostic equipment, cleincal care software. 

      g. Utilities/Operations for lighting, colling/ventilation, cleaning through third party vendors or through the hiring of an employee

      h. Any Other General and Administrative Expenses that are not above which are overhead expenses incurred and attributable to COVID-19 and that have not been reimbursed or obligated for reimbursement from other sources already like: third party vendors, consulting, legal fees, audit and accounting services, food preparations, nutrition  services and supplies, logistics and transport, debt financing.

    2. Healthcare Related Expenses Traceable to COVID-19

      Again, it is important to remember that the only expenses which should be included are those which are attributable to COVID-19 in its treatment or prevention, and the actual expenses should be above what has already been reimbursed or obligated to be reimbursed by other sources.

      a. Supplies including: N95 maks, personal protective equipment (PPE), surgical masks, gowns, hand sanitizer, or supplies required for screening patients like thermometers, cleaning agents.. 

      b. Equipment such as ventilators, updates to HVAC systems, improved filtration for infection control, lab or radiology diagnostic equipment, or any other equipment to increase capacity like beds, linens, etc.

      c. Information Technology (IT) or interoperability between systems.  One example of this is to be able to take information from one of your systems where the data is and turn it into a report which the fund is asking for.  We have a system that can do this, and track it in real time, so you always know where you are in terms of your funding, and when it comes time to report, you will have what you need with a push of a button. Other IT or software systems which can offer enhanced care delivery during the reporting period are inclusive of proper fund use including: electronic health record licensing fees, telehealth infrastructure, increased bandwidth, and teleworking solutions which cna support remote workforces. 

      d. Facility Expenses such as the lease or purchase of permanent or temporary structures, or to modify facilities to accommodate patient treatment practices revised due to coronavirus or outpatient clinic enhacements for improved infection control like the seperation of COVID-19 positive individuals from negative. 

      e. Other Healthcare Related Expenses not listed above.

  3. You will be able to report your lost Revenues Traceable to Coronavirus

    To do so, you will want to do a side by side comparison of patient care revenues, and patient care cost/expense impacts for each quarter of 2019 and its corresponding quarter of 2020.  This comparison will serve as a way to see year over year negative change in net revenues from patient care.  This is what can be replaced by funding, but not more than.

    Note, you should not include patient care revenues which were not collected, i.e. bad debts, as a part of your revenue calculation.

    If you have not used all of your funds by the end of December 31st, 2020, you will have six more months to use the funds.  Your first report will still be due on February 15th, 2021 for the period of January 1st, 2020 - December 31st, 2020.  Then you will submit a second report on July 31st, 2021 for the reporting period of January 1st, 2021 - June 30th, 2021.  

    Remember to compare Apples to Apples for respective periods when determining the lost patient care revenues, and always compare quarter to quarter.  Quarter 1 of 2020 should be compared to Quarter 1 of 2019.  Then Quarter 1 of 2021 should be compared to Quarter 1 of 2019 to find out how much net losses per quarter you have experienced as compared to 2019 which was pre-pandemic.  Quarter 2 of 2020 patient care revenues should be compared to Quarter 2 of 2019, and so on.

    A note about what qualifies as patient care.  Patient care are health care services which support and provide healthcare services in a medical setting, at home or in the community.  Do not include in your calculation for patient care revenues the following:

    • Insurance, retail or real estate values (unless it is allowable as a patient care cost for a skilled nursing facility)

    • Grants

    • Tuition

    Here are revenues from patient care payer mix you will want to compare to figure out lost revenues for 2019 and 2020 (and 2021 if you have left over funds to which you have not already applied G&A and healthcare expenses to).

    This patient care payor mix has been taken directly from:
    https://www.hhs.gov/sites/default/files/post-payment-notice-of-reporting-requirements-november-2020.pdf

    Page 4, section 3.a.

    ‘a. Medicare Part A+B: Actual revenues/net charges received from Medicare Part A+B for patient care for the calendar year. 

    b. Medicare Part C: Actual revenues/net charges received from Medicare Part C for patient care for the calendar year. 

    c. Medicaid: Actual revenues/net charges received from Medicaid/Children’s Health Insurance Program (CHIP) for patient care for the calendar year. 

    d. Commercial Insurance: Actual revenues/net charges from commercial payers for patient care for the calendar year. 

    e. Self-Pay (No Insurance): Actual revenues/net charges received from self-pay patients, including the uninsured or individuals without insurance who bear the burden of paying for healthcare themselves, for the calendar year. 

    f. Other: Actual gross revenues/net charges from other sources received for patient care services and not included in the list above for the calendar year.’

    Other Assistance

    After you have calculated your revenues per patient care payor mix, you will need to repot any other assistance you received in 2020.

    Listed below are other types of assistance you may have received and need to report.  These assistance programs may have offset the amount of expenses that you are able to apply to the provider relief funds you received.  This would be the case if funding from the programs below already paid for some of the expenses.  In this case you would not be able to report them again as expenses that were paid from the funding of the Provider Relief Fund payments you received.  

    a. Did you receive funding  for COVID-19 relief in 2020, as of the reporting period end date, from any or all of the following programs?Treasury, Small Business Administration (SBA) and the CARES Act/Paycheck Protection Program (PPP)FEMA CARES ActCARES Act TestingLocal, State, and Tribal Government Assistance

    b. Did you have any paid claims from your insurance due to business interruption in 2020, as of the reporting period end date?

    f. Did you receive any other assistance for COVID-19 in 2020 that is not listed above for any TINs that are included in your Provider Relief Fund payments as of the reporting period end date?

  4. You will need to provide this non-financial data by quarter as well:  

    This can be found in the following document on Page 5-6, Part 4:
    https://www.hhs.gov/sites/default/files/post-payment-notice-of-reporting-requirements-november-2020.pdf

    ‘Facility, Staffing and Patient Care

    a. Personnel Metrics: Total personnel by labor category (full-time, part-time, contract, other: recipient must define), total re-hires, total new hires, and total personnel separations by labor category.

    b. Patient Metrics: Total number of patient visits (in-person or telehealth), total number of patients admitted, and total number of resident patients.

    c. Facility Metrics: Total available staffed beds for medical/surgical, critical care, and other beds.

    Change in Ownership

    Reporting Entities that acquired or divested of related subsidiaries indicate the change in ownership, whether the related TIN was acquired or divested, providing the following data points for each relevant TIN:

    a. Date of acquisition/divestiture

    b. TIN(s) included in the acquisition/divestiture

    c. Percent of ownership for acquisition/divestiture

    d. Did/do you hold a controlling interest in this entity? (Y/N)

    Note: If the Reporting Entity itself was acquired or divested, it should self-report the change in ownership to HRSA.’

iii. I received between $499,999 and $750,000 in Provider Relief Funds

If you received between $500,000 - $750,000 in funding:

General Guidelines

If you received funding greater than $10,000 between all your payment distributions, you will be responsible for reporting.  These general guidelines go over some key features of your reporting requirements as well as some important dates. We will also go over the specific reporting details needed. This reporting is referred to as the post-payment-reporting process.

Here are some key dates:

  • Jan. 15, 2021: the reporting portal will become open to you

  • Feb. 15, 2021: this is the date of the first reporting deadline for use of the provider relief funds you used so far

  • July 31, 2021: this is the final reporting deadline and is only applicable to you if you did not spend all your funds before December 31st, 2020.

Here are some key guidelines for use of funds:

  • Your Provider Relief Funds should be applied as follows and int this particular order:

    1. Any expenses which are healthcare related and are traceable to COVID-19 which have not been reimbursed or are obligated to be reimbursed from other sources.

    2. Any patient care revenues which were lost in 2020 as compared to 2019 because of COVID-19. You are not able to recover lost costs beyond what you made in 2019.

Here are the required reporting data elements for $10,000- $499,999

  1. Revenues Lost:

    • Revenues or net charges from actual patient care

    • Revenue by patient care payor mix: medicare/medicaid, commercial, private, etc.

  2. Expenses traceable to COVID-19:

    • Your general and administrative (G&A) expenses

    • Your healthcare-related expenses

If you had over $500,000 in total payments by HHS, then you must provide a further breakdown of required data elements. You will want to break down your G&A and other healthcare expenses into the following categories:

  • Mortgage/rent

  • Personnel

  • Utilities

  • Supplies

  • Equipment

  • …and other high-level expense categories

You will need to provide the following in regards to your basic organization information:

  • Taxpayer Identification Number

  • National Provider Identifier (optional)

  • Fiscal year end date

  • Federal tax classification

You will need to provide any other assistance or funding you received in 2020 from any of the following programs:

  • Paycheck Protection Program

  • FEMA CARES Act

  • CARES Act Testing

  • Local/State/Tribal Government assistance

  • Business insurance

  • Other assistance

You will need to provide any other assistance or funding you received in 2020 from any of the following programs:

  • Total Employees and Re-hires or any other relevant information regarding your employees as it relates to expenses and the preparations, prevention or treatment of COVID-19.

  • Total patients visits and admissions, what were they being seen for, what were the results if any from the visit.

  • Facility Information like how many staffed beds you have, or any other relevant facility information as it relates to the funding you received.

For more specific guidelines on reporting, see below.

Specific Guidelines on Reporting:

Remember if you, as a Provider Relief Fund recipient, received one and/or two payments totalling more than $10,000 you are required to adhere to the post-payment reporting process.  

It is important to note that these guidelines for reporting do not apply to Nursing Home Infection Control distribution, the Rural Health Clinic Testing distribution or the Health and Resources and Services Administration Uninsured Program.  As stated earlier these reporting requirements will be given at a later date.

To sign up for our email newsletter for reporting requirement updates for your specific industry, sign up here.  

Overview

The funds you received were from a program called the CARES Act PRF program.  They consisted of funds which were designated for healthcare providers from the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136) and the Paycheck Protection Program (PPP) and Health Care Enhancement Act (P.L. 116-139).  They were administered through the Health Resources and Services Administration (HRSA), a department of Health and Human Services (HHS).   By virtue of taking the payment and not returning after 15 days of receiving it, regardless of if you attested to the payment, you have agreed to the Terms & Conditions.  These Terms & Conditions require that you report certain things to the HHS.  

This part of the brochure goes over in length what the latest developments are on reporting requirements.

Reporting will be required for 2019 and 2020.  You will need to report 2019 figures because they are used to determine eligibility on how much funding you can actually apply towards the category of lost revenues.

HRSA has announced that it will have Question & Answer Sessions via webinar before the reporting deadline of February 15th, 2021.  They will also keep updating frequently asked questions for reporting and other topics, which can be found here: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/FAQs/index.html.

You may use your normal method of accounting, cash or accrual, to report the use of your Provider Relief Funds.

Here is the information you will be required to submit:

  1. Part 1 Expenses: Any expenses which are either:

    • a.) healthcare related or

    • b.) General and Administrative (G&A)

      and are traceable to COVID-19 which have not been reimbursed or are obligated to be reimbursed from other sources.  These expenses are detailed further below.

  2. Part 2 Expenses: After applying all healthcare and G&A expenses, you may begin to apply funding to any patient care revenues which were lost in 2020 because of COVID-19.  However, you may not apply funds which exceed your patient care revenues of 2019.  In other words, you are not permitted to recover lost costs beyond what you made in 2019.

In addition, if you have not spent your funds in their entirety by the end of 2020, you will have an extra 6 months to use your remaining funds in the same way as you did in 2020.  

You must compare the same reporting periods to their equivalent.  For instance you must compare the whole of 2019 patient revenues to all of 2020 patient revenue.  Similarly, if you are using funds to cover lost revenues in 2021, let’s say from January 2021 - June 30th, 2021, then you must compare those to patient revenues of 2019 from the same respective time frame.

Example

Here is a simple example to explain how you will apply your funding:

Joe is figuring out how to apply his funds for reporting purposes of his Healthcare Facility. He received $7,000 during the first round of general distribution and $4,000 in the second round.  He received a total of $11,000 between both distributions. Because he received more than $10,000 he is required to report.  He only services through Medicaid. Here is what he needs to consider:

Total Expenses for Part 1:

G&A Expenses = $6500

Healthcare Expenses = $1000

Therefore, he applies $7500 first towards the total he received.

G&A ($6500) + Healthcare Expenses ($1000) = $7500.  

For Part 2:

To figure out the funds which are left to apply to lost revenues take the total funds ($11,000) and subtract from it your healthcare and G&A expenses ($7500).  In other words, Total Funds ($11,000) - Healthcare + G&A Expenses ($7500) = $3500 left over. This $3500 which is left over can be applied to lost patient revenues. To find lost patient revenues, you will first need to find what your patient revenue totals were for 2019 and 2020.  For the purposes of Joe, here is what he had.

  1. Patient Care Revenues in 2019 = $350,000

  2. Patient Care Revenues in 2020 = $347,000

This means his total lost patient care revenues from 2019 to 2020 are $350,000 (Patient Care Revenues in 2020) - $347,000 (Patient Care Revenues in 2019)  = $3,000.

So, Joe in this example is able to apply only $3,000 in lost revenues.  He has $500 left over.  He can spend that on healthcare and G&A expenses in the new year.  Again, he will spend first on healthcare and G&A expenses, and if there is any left, he will expend the remaining on lost revenues.  He has only until June 30th, 2020 to spend the remaining funds.  If he does not, or his patient care revenues exceed that of 2019 in the respective time frame, he would be required to give the money back as no other qualified expenses are allowed.

Other reporting requirements:

Data Elements

  1. Demographic Information

    • a. Name of your organization (Reporting Entity):

      Be sure this name corresponds with the Tax Identification Number that received one or more payments, or you may be an entity that meets the following three criteria.  If so, you will use the name of that entity as the reporting entity:

      1. If you are the parent of one or more subsidiary billing TINS which have gotten payment from the General Distribution, and;

      2. You have providers that were doing diagnoses, testing, caring for individuals who may have had COVID-19, or did have COVID-19 after January 31st, 2020, and

      3. Your entity can attest to the Terms and Conditions

        To note: If the subsidiary received Targeted Distribution payments (targeted distribution payments are for:Rural Distribution; COVID-19 High-Impact Distributions; Skilled Nursing Facilities Allocation and Distribution; Allocation for Tribal Hospitals, Clinics, and Urban Health Centers; Safety Net Hospitals Distributions; Certain Children’s Hospitals Distribution Link to Targeted Distribution Timeline), then the subsidiary reports, and the parent cannot also report on the same funds of this subsidiary. However for General Distribution payments that were payed to subsidiaries, the reporting entity parent can report on those payments and direct the usage of those funds. In other words, don’t claim funds twice on the use of the funds.

      b. Your Tax Identification Number (TIN): Again, this TIN must correspond to the reporting entity that received the payment and attested to it. This may be a social security number or an employer identification number for some.

      c. Your National Provider Identifier (NPI): Although this is optional, it is a good idea to provide it.  This is your unique 10 digit identifier for healthcare providers. 

      d. Your Fiscal Year-End Date and Month

      e. Your Federal Tax Classification: You will need to report what kind of business type you file your taxes under: Sole Proprietor, Limited Liability Corporation (LLC), Partnership, C Corporation, S Corporation, Trust or Estate, or a tax-exempt organization or entity.

  2. No matter how much you received, you will be reporting your expenses in 2020 which are traceable to COVID-19 like treating confirmed or suspected cases, preparing for cases and maintaining capacity which are not reimbursed or obligated to be reimbursed by other sources.   What exactly you report will depend on how much funding you received.

    You will also need to break down your expenses by quarter (Jan - Mar, April - Jun, Jul - Sep, Oct - Dec) for 2019 and 2020 (include 2021 if you did not spend all your funds as of December 31st, 2020).  This will show your losses as they relate to COVID-19 and will justify your extra expenses because of COVID-19, and in turn your use of the provider relief fund payments you received.

    These lists may not include other expenses which you experienced due to COVID-19 which can be included.  The list is meant to help clarify what could be included, but does not limit you to claim other expenses which have been experienced due to COVID-19.

    1. General and Administrative

    2. Healthcare Expenses

      If you received $500,000 or more, you will need to be more specific and give a further breakdown of those categories. As always, be sure that you only include those that are above what others may have already covered and thatt they are attributable to COVID-19.

      Here are the subcategories which must be reported under each main category above.

    1. General and Administrative

      a. Mortgage/Rent of a facility where patient care takes place like a clinical setting or medical office building, etc.

      b. Finance Charges, insurance premiums or property taxes for those facilities

      c. Insurance premiums for property, malpractice, and business operations

      d. Personel training, staffing of nurses, temporary employees or contractors, overhead employees like those that cannot be directly related to the product or service but is needed none the less, a receptionist who checks people in, security personel, administrative staff, support personel.  

      Note: you are not allowed to pay executives more than $197,000 with the funds, this excludes fringe benefits below. 

      e. Fringe Benefits/Extra benefits which supplement your regular employee’s salary including: hazard pay, travel reimbursement, employee health insurance, child care assistance, overtime pay, hiring bonuses, retention payments, etc. 

      f. Lease Payments for new equipment or software lease like diagnostic equipment, cleincal care software. 

      g. Utilities/Operations for lighting, colling/ventilation, cleaning through third party vendors or through the hiring of an employee

      h. Any Other General and Administrative Expenses that are not above which are overhead expenses incurred and attributable to COVID-19 and that have not been reimbursed or obligated for reimbursement from other sources already like: third party vendors, consulting, legal fees, audit and accounting services, food preparations, nutrition  services and supplies, logistics and transport, debt financing.

    2. Healthcare Related Expenses Traceable to COVID-19

      Again, it is important to remember that the only expenses which should be included are those which are attributable to COVID-19 in its treatment or prevention, and the actual expenses should be above what has already been reimbursed or obligated to be reimbursed by other sources.

      a. Supplies including: N95 maks, personal protective equipment (PPE), surgical masks, gowns, hand sanitizer, or supplies required for screening patients like thermometers, cleaning agents.. 

      b. Equipment such as ventilators, updates to HVAC systems, improved filtration for infection control, lab or radiology diagnostic equipment, or any other equipment to increase capacity like beds, linens, etc.

      c. Information Technology (IT) or interoperability between systems.  One example of this is to be able to take information from one of your systems where the data is and turn it into a report which the fund is asking for.  We have a system that can do this, and track it in real time, so you always know where you are in terms of your funding, and when it comes time to report, you will have what you need with a push of a button. Other IT or software systems which can offer enhanced care delivery during the reporting period are inclusive of proper fund use including: electronic health record licensing fees, telehealth infrastructure, increased bandwidth, and teleworking solutions which cna support remote workforces. 

      d. Facility Expenses such as the lease or purchase of permanent or temporary structures, or to modify facilities to accommodate patient treatment practices revised due to coronavirus or outpatient clinic enhacements for improved infection control like the seperation of COVID-19 positive individuals from negative. 

      e. Other Healthcare Related Expenses not listed above.

  3. You will be able to report your lost Revenues Traceable to Coronavirus

    To do so, you will want to do a side by side comparison of patient care revenues, and patient care cost/expense impacts for each quarter of 2019 and its corresponding quarter of 2020.  This comparison will serve as a way to see year over year negative change in net revenues from patient care.  This is what can be replaced by funding, but not more than.

    Note, you should not include patient care revenues which were not collected, i.e. bad debts, as a part of your revenue calculation.

    If you have not used all of your funds by the end of December 31st, 2020, you will have six more months to use the funds.  Your first report will still be due on February 15th, 2021 for the period of January 1st, 2020 - December 31st, 2020.  Then you will submit a second report on July 31st, 2021 for the reporting period of January 1st, 2021 - June 30th, 2021.  

    Remember to compare Apples to Apples for respective periods when determining the lost patient care revenues, and always compare quarter to quarter.  Quarter 1 of 2020 should be compared to Quarter 1 of 2019.  Then Quarter 1 of 2021 should be compared to Quarter 1 of 2019 to find out how much net losses per quarter you have experienced as compared to 2019 which was pre-pandemic.  Quarter 2 of 2020 patient care revenues should be compared to Quarter 2 of 2019, and so on.

    A note about what qualifies as patient care.  Patient care are health care services which support and provide healthcare services in a medical setting, at home or in the community.  Do not include in your calculation for patient care revenues the following:

    • Insurance, retail or real estate values (unless it is allowable as a patient care cost for a skilled nursing facility)

    • Grants

    • Tuition

    Here are revenues from patient care payer mix you will want to compare to figure out lost revenues for 2019 and 2020 (and 2021 if you have left over funds to which you have not already applied G&A and healthcare expenses to).

    This patient care payor mix has been taken directly from:
    https://www.hhs.gov/sites/default/files/post-payment-notice-of-reporting-requirements-november-2020.pdf

    Page 4, section 3.a.

    ‘a. Medicare Part A+B: Actual revenues/net charges received from Medicare Part A+B for patient care for the calendar year. 

    b. Medicare Part C: Actual revenues/net charges received from Medicare Part C for patient care for the calendar year. 

    c. Medicaid: Actual revenues/net charges received from Medicaid/Children’s Health Insurance Program (CHIP) for patient care for the calendar year. 

    d. Commercial Insurance: Actual revenues/net charges from commercial payers for patient care for the calendar year. 

    e. Self-Pay (No Insurance): Actual revenues/net charges received from self-pay patients, including the uninsured or individuals without insurance who bear the burden of paying for healthcare themselves, for the calendar year. 

    f. Other: Actual gross revenues/net charges from other sources received for patient care services and not included in the list above for the calendar year.’

    Other Assistance

    After you have calculated your revenues per patient care payor mix, you will need to repot any other assistance you received in 2020.

    Listed below are other types of assistance you may have received and need to report.  These assistance programs may have offset the amount of expenses that you are able to apply to the provider relief funds you received.  This would be the case if funding from the programs below already paid for some of the expenses.  In this case you would not be able to report them again as expenses that were paid from the funding of the Provider Relief Fund payments you received.  

    a. Did you receive funding  for COVID-19 relief in 2020, as of the reporting period end date, from any or all of the following programs?Treasury, Small Business Administration (SBA) and the CARES Act/Paycheck Protection Program (PPP)FEMA CARES ActCARES Act TestingLocal, State, and Tribal Government Assistance

    b. Did you have any paid claims from your insurance due to business interruption in 2020, as of the reporting period end date?

    f. Did you receive any other assistance for COVID-19 in 2020 that is not listed above for any TINs that are included in your Provider Relief Fund payments as of the reporting period end date?

  4. You will need to provide this non-financial data by quarter as well:  

    This can be found in the following document on Page 5-6, Part 4:
    https://www.hhs.gov/sites/default/files/post-payment-notice-of-reporting-requirements-november-2020.pdf

    ‘Facility, Staffing and Patient Care

    a. Personnel Metrics: Total personnel by labor category (full-time, part-time, contract, other: recipient must define), total re-hires, total new hires, and total personnel separations by labor category.

    b. Patient Metrics: Total number of patient visits (in-person or telehealth), total number of patients admitted, and total number of resident patients.

    c. Facility Metrics: Total available staffed beds for medical/surgical, critical care, and other beds.

    Change in Ownership

    Reporting Entities that acquired or divested of related subsidiaries indicate the change in ownership, whether the related TIN was acquired or divested, providing the following data points for each relevant TIN:

    a. Date of acquisition/divestiture

    b. TIN(s) included in the acquisition/divestiture

    c. Percent of ownership for acquisition/divestiture

    d. Did/do you hold a controlling interest in this entity? (Y/N)

    Note: If the Reporting Entity itself was acquired or divested, it should self-report the change in ownership to HRSA.’

iv. I received more than $750,000 in Provider Relief Funds

If you received more than 750,000 in Provider Relief Fund payments you will be required to do a Single Audit as set forth in 45 CFR 75.501.

Reporting Entities which spent $750,000 or more in total funds from all sources combined are required to performa a single audit.  If you know at the time that you report, you must indicate that you are required to do so, and whether or not you would like your provider relief fund payments to be considered as a part of the single audit.

Here are some useful tipes which can get you started with the process if you are required to do a single audit:

You must get an auditor to do the single audit for you.  You are not allowed to do it yourself or have your own accounting firm perform the audit.  Here is an excerpt from regulation 45 CFR 75.509, page 354, in regards to finding an auditor:

‘(a) Auditor procurement. In procuring audit services, the auditee must follow the procurement standards prescribed by the Procurement Standards in §§75.326 through 75.335 of subpart D of this part or the FAR (48 CFR part 42), as applicable. When procuring audit services, the objective is to obtain high-quality audits. In requesting proposals for audit services, the objectives and scope of the audit must be made clear and the non-Federal entity must request a copy of the audit organization’s peer review report which the auditor is required to provide under GAGAS. Factors to be considered in evaluating each proposal for audit services include the responsiveness to the request for proposal, relevant experience, availability of staff with professional qualifications and technical abilities, the results of peer and external quality control reviews, and price. Whenever possible, the auditee must make positive efforts to utilize small businesses, minority-owned firms, and women’s business enterprises, in procuring audit services as stated in §75.330, or the FAR (48 CFR part 42), as applicable’

In terms of the cost of the audit.  Sometimes, you can use the cost of your audit as an allowable expense which can be paid for by your provider relief funds if the audit was done according to the requirements in the regulation in 45 CFR 75.425 and so long as a similar audit was not already done for another purpose.  If a similar audit was done but did not fully meet the requirements of the audit necessary for reporting of this fund’s expenditures, then you may proportionately allow the difference to be used as an allowable expense in the single audit that is required.  Your auditor should be able to help determine what is allowable and what is not in terms of your single audit expenses.  Here is the excerpt on page 309 of 45 CFR 75.425:

Ԥ 75.425

Audit services.

(a) A reasonably proportionate share of the costs of audits required by, and performed in accordance with, the Single Audit Act Amendments of 1996 (31 U.S.C. 7501–7507), as implemented by requirements of this part, are allowable. However, the following audit costs are unallowable:

(1) Any costs when audits required by the Single Audit Act and subpart F of this part—have not been conducted or have been conducted but not in accordance therewith; and…Your responsibilities in the audit itself are as follows, and can be found in 45 CFR 75.508, page 343:

Ԥ 75.508

Auditee responsibilities. The auditee must:

(a) Procure or otherwise arrange for the audit required by this part in accordance with §75.509, and ensure it is properly performed and submitted when due in accordance with §75.512.

(b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §75.510. (c) Promptly follow up and take corrective action on audit findings, including preparation of a summary schedule of prior audit findings and a corrective action plan in accordance with §75.511(b) and §75.511

(c), respectively.

(d) Provide the auditor with access to personnel, accounts, books, records, supporting documentation, and other information as needed for the auditor to perform the audit required by this part.’  

The entirety of audits and how they are carried out, what information is required, costs which are allowable and much more, you may read 309, 339-357:
https://www.govinfo.gov/content/pkg/CFR-2017-title45-vol1/pdf/CFR-2017-title45-vol1.pdf

E. Provider Relief Funds - Terms and Conditions

Terms and Conditions

Phase 3 - Targeted Distribution Terms and Conditions

If you have received payment through Phase 3 General Distribution, then these terms and conditions apply to you. Provided is a link: https://www.hhs.gov/sites/default/files/terms-and-conditions-phase-3-general-distribution-relief-fund.pdf to the complete terms and conditions.

Phase 2 General Distribution Relief Fund Payment Terms and Conditions

If you have received a payment under Phase 2 General distribution, then these terms and conditions are applicable to you.  Here is a link to the terms and conditions set forth in this Phase 2 General Distribution: https://www.hhs.gov/sites/default/files/terms-and-conditions-phase-2-general-distribution-relief-fund.pdf

Relief Fund Paymnet from $30 Billion General Distribution - Terms and Conditions

This distribution is made to you if you have billed medicaid. This $30 million dollar general distribution happens automatically, and these terms and conditions will apply to you once you receive this distribution. You may find the complete terms and conditions here: https://www.hhs.gov/sites/default/files/terms-and-conditions-provider-relief-30-b.pdf

Relief Fund Payment $20 Billion General Distribution - Terms and Conditions

If you received distribution from the $20 billion dollar general distribution, then these terms and conditions will apply to you.  The link can be found here: https://www.hhs.gov/sites/default/files/terms-and-conditions-provider-relief-20-b.pdf

High Impact Area Relief Fund Payment Terms and Conditions

If you have received payment from the High Impact Area Relief Fund, these terms and conditions will apply to you: https://www.hhs.gov/sites/default/files/terms-and-conditions-high-impact-relief-fund.pdf

Rural Targeted Distribution - Terms and Conditions

If you received payments from the Rural Targeted Distributions your terms and conditions can be found here: https://www.hhs.gov/sites/default/files/terms-and-conditions-rural-relief-fund.pdf

Rural Health Clinic (RHC) Testing Payment - Terms and Conditions

If you have received payment from the Rural Health Clinic (RHC) Testing, then these terms and conditions in this link are for you: https://www.hhs.gov/sites/default/files/terms-and-conditions-rural-testing-relief-fund.pdf

$4.9 Billion Skilled Nursing Facility Relief Fund Payment - Terms and Conditions

If you have received payment from the $4.9 Billion Skilled Nursing Facility Relief Fund, then these terms and conditions in this link are for you: https://www.hhs.gov/sites/default/files/terms-and-conditions-skilled-nursing-facility-relief-fund.pdf

$4.5 Billion Skilled Nursing Facility Relief Fund Payment - Terms and Conditions

If you have received payment from the $4.5 Billion Skilled Nursing Facility Relief Fund, then these terms and conditions in this link are for you: https://www.hhs.gov/sites/default/files/provider-relief-fund-nf-infection-control-payment-terms-and-conditions.pdf

Indian Health Service Relief Fund Payment - Terms and Conditions

If you have received payment from the Indian Health Service Relief Fund, then these terms and conditions in this link are for you: https://www.hhs.gov/sites/default/files/terms-and-conditions-indian-health-service-relief-fund.pdf

Safety Net Provider Relief Fund Payment - Terms and Conditions

If you have received payment from the Safety Net Provider Relief Fund, then these terms and conditions in this link are for you: 
https://www.hhs.gov/sites/default/files/terms-and-conditions-safety-net-relief-fund.pdf

FFCRA Relief Fund Payment - Terms and Conditions

If you have received payment from the FFCRA Relief Fund, then these terms and conditions in this link are for you: https://www.hhs.gov/sites/default/files/terms-and-conditions-ffcra-relief-fund.pdf

Uninsured Relief Fund Payment - Terms and Conditions

If you have received payment from the Uninsured Relief Fund, then these terms and conditions in this link are for you: https://www.hhs.gov/sites/default/files/terms-and-conditions-uninsured-relief-fund.pdf

To see the most up to date Terms and Conditions for your program distribution, go to: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html, and scroll down to the bottom of the page where you will find live links to terms and conditions.