Coronavirus (COVID-19) Provider Relief Fund Reporting
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Providers that received funds under the CARES Act are required to submit a report if they received one or more payments exceeding $10,000 in the aggregate.
The Coronavirus Aid, Relief, and Economic Security (CARES) Act (Public Law 116-136) and the Paycheck Protection Program (PPP) and Health Care Enhancement Act (Public Law 116-139) appropriated funds for health care providers for eligible healthcare related expenses or lost revenues attributable to COVID-19. The Department of Health and Human Services (HHS) released guidance on the reporting of COVID-19 expenses and lost revenues on September 19, 2020.
The report is due on February 15, 2021, if all funds were expended in 2019; if not, reports are due on February 15, 2021 and July 31, 2021.
The COVID-19 expense covered under the CARES Act is different than the expense that is covered under PPP. Correct reporting of these expenses can have a major impact on refund of grants or loan forgiveness.
The lost revenue calculation has confusing guidance that takes into consideration many factors: 2019 net income, 2020 net income, and changes in revenue between 2019 and 2020.
The language of the HHS guidance indicates that the requested COVID-19 expense and lost revenue must be reduced by other sources of revenue, including payments received from insurance and patients, and amounts received from federal, state, or local governments.