Updated Guidance for Reporting CARES Act Relief

HHS has issued updated guidance on reporting requirements for providers who received more than $10,000 in payments from the Provider Relief Fund (PRF).

While much of the guidance remains the same as Grassi reported last month, the updates affect the following areas:

Lost revenues attributable to Coronavirus

The PRF fund payments are allowed to be used on both Coronavirus-related expenses and lost revenues caused by the pandemic. The original guidance stipulated that lost revenues should be represented on the report as a negative change in year-over-year net operating income.

In this new guidance, the HHS dictates that lost revenues must be represented as a negative change in year-over-year actual revenue from patient care related sources.

Definition of reporting entity

The new guidance clarifies that if an entity does not directly receive PRF payments, it must comply with the reporting requirements if it meets the following criteria:

  • is the parent of one or more subsidiary billing TINs that received General Distribution payments,
  • has providers associated with it that were providing diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 on or after January 31, 2020, and
  • is an entity that can otherwise attest to the Terms and Conditions.

Reporting unused funds after December 31, 2020

If a provider does not use all of its PRF funds by December 31, 2020, it must submit a second and final report no later than July 31, 2021 that includes patient care related revenue amounts earned between January 1 and June 30, 2021.

The new guidance specifies that lost revenues during this time will be calculated by comparing 2021 actual revenue to the same quarter in 2019.

Next Steps

In light of the ongoing impact of COVID-19 and the new PRF reporting requirements, Grassi is recommending and helping PRF recipients complete the following To-Do list:

  • Consider applying for Phase 3 funds by November 6
  • Develop and maintain a spending plan for HHS funds
  • Keep track of monthly spending with supporting documentation
  • Track jobs created and saved
  • Prepare for a single audit if you received more than $750,000 in all phases of funding

If you need assistance with tracking, calculating and reporting your PRF expenses, please contact your Grassi Not-for-Profit advisor or Grassi Healthcare Advisors for a complimentary consultation.


David M. Rottkamp David M. Rottkamp, CPA, is an Audit Partner, Nonprofit Practice Leader, at Grassi. David has over 34 years of experience providing audit and advisory services to the nonprofit and health care industries.  David focuses on organizations serving individuals with special needs, religious organizations, educational institutions, membership associations, social service providers, healthcare providers, foundations, and the arts and culture world. David’s technical knowledge allows him... Read full bio

Joseph Tomaino Joseph Tomaino is the Chief Executive Officer of Grassi Healthcare Advisors, LLC and has nearly 40 years of healthcare management experience working in the nonprofit, for-profit and government-sponsored segments. As a chief executive officer, chief nursing officer, consultant, and educator, Joseph has worked with provider organizations and payers across the U.S. as an architect of value based care -- improving clinical effectiveness along with... Read full bio