Any entity that received $10,000 or more in the aggregate from the Provider Relief Fund will be subject to additional reporting requirements, which are intended to demonstrate compliance with the Terms & Conditions of the Provider Relief Fund.
On September 19, 2020, HHS published a Post-Payment Notice of Reporting Requirements, which was amended on October 22, 2020 and can be found here – https://www.hhs.gov/sites/default/files/post-payment-notice-of-reporting-requirements-october-2020.pdf. The notice provides further guidance for reporting and use of the funds.
Recipients of the Provider Relief Fund Payments will be required to report the following information.
- Reporting Entity: Entity (TIN) that received one of more provider relief payments, or an entity that meets the following criteria: (1) is the parent entity of one or more subsidiaries that received General Distribution payments, (2) has providers that were treating patients with possible or actual cases of COVID-19 on or after January 31, 2020, and (3) is an entity that can attest to the Terms and Conditions. If the entity has subsidiary TINs that received funds from the General Distribution, the Reporting Entity may report and direct the use of General Distribution payments. However, if a subsidiary TIN received a Targeted Distribution payment, those funds must be used by the TIN that received payment and cannot be allocated to other subsidiaries or the parent entity. The subsidiary TIN receiving the Targeted Distribution payment must also report use of funds for that payment.
- Tax Identification Number (TIN)
- National Provider Number (NPI) optional
- Fiscal Year-End Date
- Federal Tax Classification
Expenses attributable to Coronavirus not reimbursed by other sources (2020 only)
- A Reporting Entity that received between $10,000 and $499,999 in aggregated provider relief payments are required to report healthcare related expenses (as defined above) in two categories: G&A expenses and other healthcare related expenses
- A Reporting Entity that received more than $500,000 in aggregated provider relief payments must break out expenses into more detailed information within G&A expenses and healthcare related expenses as described below:
- General and administrative expenses
- Fringe Benefits
- Lease Payments
- Other General and Administrative Expenses
- Healthcare Related Expenses Attributable to Coronavirus
- Information Technology
- Other Healthcare Related Expenses
Lost revenue attributable to Coronavirus
- Total revenue (net of uncollectible bad debts) from patient care related sources (2019 and 2020). Calendar year actual revenues will be entered by quarters.
- Revenue from patient care payer mix (2019 and 2020)
- Other assistance received during 2020
- Treasury, Small Business Administration (SBA) and the CARES Act/Paycheck Protection Program (PPP)
- FEMA CARES Act
- CARES Act Testing
- Local, State, and Tribal government assistance
- Business insurance
- Other assistance
- Total calendar year expenses broken down into G&A and healthcare related expenses (2019 and 2020). Calendar year actual expenses will be entered by quarters.
Additional non-financial data (by quarter)
- Facility, staffing, and patient care
- Personnel metrics (including personnel by labor category, re-hires, new hires, and separations)
- Patient metrics (including total patient visits, admits, resident patients)
- Facility metrics (available staffed beds for medical/surgical, critical care, and other beds)
- Change in ownership
- Reporting Entities that acquired or divested of related subsidiaries must provide certain additional information related to the change in ownership
- Single Audit status
- Reporting entities must indicate if they are subject to Single Audit requirements (as described above), and indicate whether the auditors selected provider relief fund payments to be within the scope of the Single Audit (if known at time of reporting)
The reporting system is scheduled to open to providers on January 15, 2021. The first reporting deadline for all providers on use of funds is February 15, 2021. The final reporting deadline for providers who did not fully expend funds prior to December 31, 2020, is July 31, 2020.
These final reporting requirements do not apply to Nursing Home Infection Control distribution recipients, Rural Health Clinic Testing distribution recipients, or Health Resources and Services Administration (HRSA) Uninsured Program reimbursement recipients. Separate reporting requirements may be announced in the future.