Did You Receive COVID-19 Relief? Here Are Reporting Considerations for 2021

by Steven M. Harris, Esq. •

  • Mortgage/rent
  • Personnel
  • Utilities/operations
  • Insurance
  • Fringe benefits
  • Other G&A overhead expenses

In addition, reporting entities must provide further detailed information for healthcare expenses to identify supplies, equipment, information technology, facility costs, and other healthcare expenses.

3. Lost Revenues Attributable to the Coronavirus. Reporting entities may apply CARES Act PRF payments toward lost revenue from 2020 patient care. This calculation includes the revenue or net charges from patient care and revenue from patient care payer mix, prior to net costs and expenses, and will separately account for the amount of other assistance received from federal, state, and other sources.

The recently passed Appropriations Act added flexibility for certain provider budgets established and approved before March 27, 2020, allowing applicable providers several options to calculate lost revenues. One of these options uses a budgeted-to-actual revenue comparison rather than an actual year-over-year calculation as required by prior HHS guidance.

CARES Act PRF reporting takes into consideration other assistance that eligible providers received during 2020, including, but not limited to, funds from the Paycheck Protection Program; CARES Act Testing relief; local, state, or other government assistance; and business insurance.

Reporting entities will need to provide additional revenue information, depending on which of the lost revenue calculation options they use.

CARES Act PRF reporting takes into consideration other assistance that eligible providers received during 2020, including, but not limited to, funds from the Paycheck Protection Program; CARES Act Testing relief; local, state, or other government assistance; and business insurance, among other things.

Providers should be aware that any monies received through a state program may include similar reporting and documentation requirements and may indicate a priority order of spending that cannot supersede the HHS CARES Act PRF terms and conditions. These other federal and state monies also may not overlap with HHS CARES Act PRF distributions to cover the same expenses or lost revenue.

It’s worth noting, for reporting entities that held CARES Act PRF payments in an interest-bearing account, that the value of interest earned on those PRF payments must also be reported. The reportable use of PRF distributions includes the interest earned on those distributions.

4. Non-Financial Information. Non-financial information for reporting includes a PRF recipient’s number of personnel (i.e., full time, part time, contract, other), total rehires, total new hires and total personnel by labor category, total number of patients and types of visits (i.e., in person or telehealth visits, admissions, residents), and information regarding the facility (i.e., total available staffed beds).