HHS Releases COVID Relief Reporting Rules, Confirms Funds Can Be Spent into 2021

The federal government late last week released a more detailed set of reporting rules for health care providers that received COVID-19 relief through a variety of stimulus programs, while also affirming that leftover cash can be spent into the new year.

The Department of Health and Human Services (HHS) over this past weekend unveiled the Provider Relief Fund reporting requirements, which cover both distributions from the CARES Act and the Paycheck Protection Program (PPP).

In general, operators that received more than $10,000 in federal aid must submit information about two broad categories of coronavirus financial strain, according to HHS:

  1. Healthcare related expenses attributable to coronavirus that another source has not reimbursed and is not obligated to reimburse, which may include General and Administrative (G&A) or healthcare related operating expenses
  2. PRF payment amounts not fully expended on healthcare related expenses attributable to coronavirus are then applied to lost revenues, represented as a negative change in year-over-year net patient care operating income (i.e., patient care revenue less patient care related expenses for the Reporting Entity, defined below, that received funding), net of the healthcare related expenses attributable to coronavirus calculated under step 1. Recipients may apply PRF payments toward lost revenue, up to the amount of their 2019 net gain from healthcare related sources. Recipients that reported negative net operating income from patient care in 2019 may apply PRF amounts to lost revenues up to a net zero gain/loss in 2020.

The exact amount of data required depends on the total funds received, with stricter requirements for those who landed $500,000 or more; the reporting rules also do not apply to the most recent nursing home infection control distribution, though HHS noted that “additional reporting may be announced in the future for these payments.”

HHS additionally clarified that operators with leftover relief cash at the end of December will have until June 2021 to spend it.

“If recipients do not expend PRF funds in full by the end of calendar year 2020, they will have an additional six months in which to use remaining amounts toward expenses attributable to coronavirus but not reimbursed by other sources, or to apply toward lost revenues in an amount not to exceed the 2019 net gain,” HHS noted. “For example, the reporting period January – June 2021 will be compared to the same period in 2019.”