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Between April and December 2020, many eligible healthcare providers received or applied for payments from the $175 billion Coronavirus Aid, Relief, and Economic Security (CARES) Act Provider Relief Fund (PRF) through the U.S. Department of Health and Human Services (HHS). On Dec. 27, 2020, the Consolidated Appropriations Act, 2021 (the Appropriations Act) was signed into law, allocating an additional $3 billion for the CARES Act PRF and providing further guidance on the widely anticipated reporting process.
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March 2021In a previous CARES Act-related “Legal Update” column (see “Covering All Bases” in the November 2020 issue), the discussion focused on CARES Act PRF payment categories, best practices for maintenance and handling of funds prior to the reporting period, and the potential for provider audits based on HHS guidance. Healthcare providers who received and retained CARES Act PRF payments through the attestation process during 2020 must now turn their attention to ensuring adequate documentation, timely reporting, and continued preparation for potential audits or document requests for three years from the date of final PRF expenditure.
This article contains a high-level overview of the CARES Act PRF reporting requirements and other important considerations for healthcare providers who will be CARES Act PRF reporting entities. Providers should note that the current reporting requirements don’t apply to Health Resources and Services Administration Uninsured Program reimbursement; separate reporting requirements may be announced in the future for that program by HHS. In addition, for providers who didn’t fully expend CARES Act PRF payments prior to Dec. 31, 2020, the final reporting deadline is set for July 31, 2021.
Reporting Requirements
On Jan. 15, 2021, the PRF Reporting System opened for provider registration, and the first reporting deadline, previously set by HHS for Feb. 15, was announced as delayed. HHS also released an update to the General and Targeted Distribution Post-Payment Notice of Reporting Requirements from prior November guidance, with instructions on several options to calculate lost revenue and required reporting information under four main categories:
- Entity demographic information
- Expenses attributable to COVID-19
- Lost revenues attributable to COVID-19
- Non-financial information
Generally, recipients of CARES Act PRF payments exceeding $10,000 must report certain information, including their intent, their use of the funds, and other specific data. The primary data element categories for reporting entities are summarized below:
1. Entity Demographic Information. Providers are expected to submit standard business information such as the Taxpayer Identification Number (TIN) or an Employer Identification Number of the reporting entity, a National Provider Identifier (optional), the month that’s considered the provider’s fiscal year end date, and the provider’s federal tax classification status (sole proprietor, LLC, partnership, C Corporation, S Corporation, trust, or tax-exempt).
Reporting may also involve relevant changes in ownership, including whether a related entity TIN was transferred or changed as a result of a business transaction in 2020.
2. Expenses Attributable to the Coronavirus (Not Reimbursed by Other Sources). Expenses attributable to the coronavirus pandemic include general and administrative (G&A) expenses and healthcare-related expenses that another source has not reimbursed and is not obligated to reimburse. Healthcare-related expenses are limited to costs incurred to prevent, prepare for, and/or respond to COVID-19. The actual G&A expenses are attributable to COVID-19 costs that were incurred over and above what has been reimbursed by other sources. Reporting entities who received $500,000 or more in CARES Act PRF payments must provide further detail on their G&A expense breakdown, including: