Provider Relief Fund: Reporting requirements clarified by Health and Human Services


Update: After receiving feedback from providers and members of Congress about its reporting guidance released Sept. 19, the U.S. Department of Health and Human Services (HHS) issued a policy change on Oct. 22.

Per the initial notice, payments applied to lost revenues were to be reported as a negative change in year-over-year net patient care operating income. However, in response to concerns expressed by providers and members of Congress, HHS issued the policy change to include amended reporting requirements. Now, lost revenue will be measured as a negative change in year-over-year actual revenue from patient care related sources. This no longer requires a net income approach, which will increase flexibility around how providers can apply the funds they received.

The full notice and policy change announcement can be found here.

After much anticipation surrounding the reporting requirements of the Health and Human Services (HHS) Provider Relief funds, which many providers started to receive back in April, HHS has released guidance on the process.

The notice, issued Sept. 19, applies to any provider who received over $10,000 from the general and targeted distributions from the Provider Relief Fund.

The reporting system will open for providers on Jan. 15, 2021 with a deadline to report by Feb. 15, 2021. Recipients of the funds will be required to report the use of their payments by submitting information in two main categories:

  1. Healthcare-related expenses attributable to coronavirus that have not been reimbursed from another source. This includes expenses such as: personal protective equipment; hand sanitizer; patient-screening supplies; ventilators; updates to HVAC systems; IT expenses to expand virtual care; and facility modification to accommodate social distancing, etc.
  2. Payments applied to lost revenues which will be reported as a negative change in year-over-year net patient care operating income, net of the healthcare related expenses attributable to coronavirus from step 1. Providers may apply payments toward lost revenue, up to their 2019 gain from healthcare-related sources.

If providers do not spend their provider relief funds in full by the end of 2020, they will have until June 2021 to apply the remaining amount toward the two categories above. For lost revenues, the reporting period of January - June 2021 will be compared to January - June 2019 to determine the negative change.

Providers will also be required to provide additional data elements such as their tax identification number, national provider identification, fiscal year-end, and federal tax classification. Additional non-financial data will also be collected per quarter including personnel, patient, and facility metrics.

HHS plans to hold Q&A webinars in advance of the reporting deadline. They will also be issuing FAQs to aid providers with the reporting process.

The full notice can be found here.

If you would like to talk through the Provider Relief Fund reporting requirements and how we can help your practice or facility with this process, please reach out to your Rehmann advisor. You also may contact us at

Rehmann is focused on providing practical guidance and insights to help empower organizations and individuals as we navigate through the uncertainty and complexity of this pandemic, together. Find resources and guidance at our COVID-19 Knowledge Center. Please click here to subscribe to our communications to ensure you remain up to date during these uncertain times.

Published in Business Wisdom

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