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Updates to Reporting Requirements for Provider Relief Funds

The Provider Relief Funds support American families, workers, and the heroic healthcare providers in the battle against the COVID-19 outbreak. The U.S. Department of Health and Human Services (HHS) has distributed most of the $175 billion to hospitals and healthcare providers on the front lines of the coronavirus response. For many healthcare organizations, these funds were simply deposited into their bank accounts. The healthcare organization then must meet certain requirements in order to retain these funds. These funds have been distributed in 3 phases as well as certain targeted distributions to rural providers and providers requesting reimbursement for the treatment of uninsured Americans.

In order to retain these funds, there are several eligibility and reporting requirements that must be met. The funds must first be applied to fiscal year 2020 healthcare related expenses attributable to COVID-19, net of items reimbursed by other funding. These types of expenses are expenses incurred in treating confirmed or suspected cases of coronavirus, preparing for possible or actual coronavirus cases, maintaining healthcare delivery capacity, and various other acceptable expenses. After funding is used for this purpose, remaining funds can then be used in order to compensate the organization for lost revenue. If the organization cannot spend all of the funds by December 31, 2020, an additional 6 months is permitted to use the remainder of the funding based upon the criteria.

On October 22, 2020, HHS issued a “Post-Payment Notice of Reporting Requirements.” The notice is to inform Provider Relief Fund (PRF) recipients who received one or more payments exceeding $10,000 in the aggregate that they will be required to report as part of the post-payment reporting process. This notice clarified that the reporting requirements will include a lost revenue calculation that compares the current “calendar year” revenue to the prior “calendar year” revenue, on a quarter by quarter basis. This calculation will be based upon the full calendar year 2019 revenue as compared to calendar year 2020 revenue and may delay the ability of certain providers to recognize this revenue until the entity can prove that there was lost revenue year over year.

For the complete “Post-Payment Notice of Reporting Requirements”, see the following:

If you have any questions, please reach out to Janice Snyder, McKonly & Asbury Partner and Leader of our firm’s Healthcare Practice at

About the Author

Janice Snyder

Janice is Partner and Director of Assurance Services at McKonly & Asbury. With over 20 years’ experience in public accounting, she spent 11 of those years at an international accounting firm. Janice has specialized in serving… Read more

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