• Recipients of Provider Relief Funds required to file reports quarterly, beginning June 30
    • Healthcare providers rapidly approaching May 24th deadline to accept funds and T&Cs
    • If lost revenues or COVID-19 expenses are less than funds received, HHS set to claw back
    • DSJCPA CRT well equipped to assist clients in preparing necessary documentation

Under the CARES Act passed in early April, Congress initially allocated $100 billion to the Providers Relief Fund, broken up into four different tranches of distribution channels. As part of the General Allocation payments, healthcare providers were allocated funds by the US Health and Human Services Department (HHS) if their records showed Medicare billings in the calendar year 2019. Payments were made twice from the General Allocation, once on April 10th and an additional one on April 24th, and were determined by the healthcare provider’s share of 2019 Medicare FFS revenues and its share of 2018 revenues across all payors, respectively. However, as recipients grapple with the rapidly approaching May 24th attestation deadline to accept these funds, many remain in the dark regarding what types of documents they will be required to file to prove that these funds were necessary.

Each healthcare provider that completes the required attestation also agrees to the Terms and Conditions (T&Cs) set forth by HHS, which states the following regarding reporting requirements:

“Not later than 10 days after the end of each calendar quarter, any Recipient that is an entity receiving more than $150,000 total in funds under the [CARES Act] or any other Act primarily making appropriations for the coronavirus response and related activities, shall submit to the Secretary and the Pandemic Response Accountability Committee a report.

This report shall contain:

    • the total amount of funds received from HHS under one of the foregoing enumerated Acts;
    • the amount of funds received that were expended or obligated for reach project or activity;
    • a detailed list of all projects or activities for which large covered funds were expended or obligated, including:
      • the name and description of the project or activity;
      • the estimated number of jobs created or retained by the project or activity, where applicable;
      • detailed information on any level of sub-contracts or sub-grants awarded by the covered recipient or its subcontractors or sub-grantees, to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 allowing aggregate reporting on awards below $50,000 or to individuals…”

These quarterly reporting requirements will assist HHS in ensuring that the funds provided under the CARES Act were used to reimburse each recipient “…only for healthcare-related expenses or lost revenues that are attributable to Coronavirus.” If these expenses or losses in revenue do not match and/or exceed the money received, HHS will look into clawing this money back from providers in the future. Healthcare providers now find themselves in between a rock and a hard place, in desperate need of these funds but with no clarity or confidence that they can compile the level of detailed information on a quarterly basis to submit to HHS.

Our dedicated, in-house Coronavirus Response Team (CRT) has extensive experience in both the healthcare industry as well as preparing reports/claims similar to the ones being required by HHS on a quarterly basis going forward. We are well equipped to assist in preparing the level of specificity and detailed reporting needed to remain in compliance with the HHS guidelines while you focus on doing what you do best: running your business.

Please visit our DSJCPA COVID-19 Information Center to Meet the Team and stay current on all updates as HHS rolls them out.


Stephen Jahelka
Chief Business Officer, Disaster Relief Consultant

516-541-6549 | Email