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Lori Laubach, Partner, CPA, Moss Adams Aparna Venkateswaran, CPA, Moss Adams Georgia Green, MS, CHFP, Manager, Health Care Consulting Practice, Moss Adams

HHS Releases Updates: CARES Act Provider Relief Fund Reporting Requirements

By Lori Laubach, Partner, Health Care Consulting Practice, Moss Adams
By Aparna Venkateswaran, CPA, Senior Manager, Moss Adams
By Georgia Green, Manager, Health Care Consulting Practice, Moss Adams

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Original Publish Date: November 3, 2020

On October 22, 2020, the US Department of Health and Human Services (HHS) released an amendment to the General and Targeted Distribution Post-Payment Notice of Reporting Requirements for the Coronavirus Aid, Relief, and Economic Security (CARES) Act Provider Relief Fund (PRF).

The notice is a supporting document to the July 20, 2020, Post-Payment Notice of Reporting Requirements, and it changes how health care providers can treat payments toward lost revenue.

Key Changes

Patient Care Lost Revenues

In the October 22 notice—under the section titled Reporting Guidance on Use of Funds—HHS indicates that PRF payment amounts not fully expended on health care related expenses attributable to coronavirus can be applied to patient care lost revenues.

As a reminder, the health care related expenses attributable to coronavirus are those that another source hasn’t reimbursed and isn’t obligated to reimburse. These payments may be applied towards lost revenue, up to the amount of the difference between an organization’s 2019 and 2020 actual patient care revenue.

This is a significant reversal from the previously released Post-Payment Notice of Reporting Requirements, dated September 19, 2020, which defined lost revenues as a negative change in year-over-year patient care operating income.

Per a Reporting Requirements Policy Update, HHS decided to change the lost revenues calculation in the September 19 reporting requirements to “prohibit most providers from using PRF payments to become more profitable” during the pandemic and “to conserve resources to allocate to providers who were less profitable.”

Reporting Instructions

Based on significant feedback from stakeholders and members of US Congress, HHS amended the reporting instructions. Additionally, on October 22, 2020, HHS provided an update indicating that they’re amending how providers can apply PRF funds toward lost revenues to increase flexibility.

The new guidance also clarifies that “recipients will report their use of PRF payments using their normal method of accounting (cash or accrual basis).”

Elements that Aren’t Changing

The following elements are consistent between the September 19 and October 22 Post-Payment Notice of Reporting Requirements:

Reporting Deadlines

The following dates and deadlines will also continue to align with the September 19 release of reporting requirements:

Next Steps

To learn more about the amended reporting requirements, eligible expenses and lost revenues, steps to remain compliant with the terms and conditions, and how to prepare your report, contact your Moss Adams professional.

Our team can also support the General Distribution Phase 3 application process. Read our article about the new cost report guidance from the Centers for Medicare & Medicaid Services (CMS), which covers COVID-19 funding and how to report PRF, Paycheck Protection Program loans, and payroll tax deferral.

The information in this article is based on the latest guidance available as of the date of publication. We encourage you to visit the HHS Provider Relief Fund website for the most up-to-date information.

Lori Laubach has worked in health care consulting and public accounting since 1991. She helps private and not-for-profit health care organizations with regulatory compliance, revenue cycle assessments, and risk assessments. Lori can be reached at (253) 284-5256 or

Aparna Venkateswaran has been in public accounting since 2004. She provides assurance services primarily to the health care industry, including Knox-Keene-licensed health plans, hospital systems, medical groups, and others. She can be reached at (949) 517-9473 or

Georgia Green has worked in the health care industry since 2011. She provides strategic and operational consulting services to health care providers and payers and has extensive experience helping clients integrate value-based care models from start to finish. She can be reached at (916) 503-8251 or

Assurance, tax, and consulting offered through Moss Adams LLP. Investment advisory services offered through Moss Adams Wealth Advisors LLC. Investment banking offered through Moss Adams Capital LLC.