The reporting requirements for the Provider Relief Fund should not be a surprise to healthcare organizations, says Heather Macre, JD, director with Fennemore Craig in Phoenix. “Free” money usually comes with a lot of strings attached.

When providers took the funds, they promised the funds would only be used to prevent, prepare for, and respond to COVID-19 and will reimburse the recipient only for healthcare-related expenses or lost revenues that are attributable to COVID-19, she says.

Providers also agreed to comply with reporting requirements as specified by the Department of Health and Human Services (HHS) in program instructions. (The guidance is available at:

“This was a condition of funding, so failure to report could lead to an enforcement action and the inability to use other government funds programs,” Macre says.

Macre points out these noteworthy elements in the HHS guidance:

  • HHS modified the calculation of “lost revenues” attributable to the COVID-19 emergency, defining “lost revenues” as a year-over-year change in net patient care operating income, which is equal to patient care revenue for the year minus patient care-related expenses for the same year. This is a significant change from the previous FAQ, which was less definite, referring to “lost revenues” as any revenue a healthcare provider loses due to COVID-19, without incorporating expenses. Recipients who relied on this prior guidance need to review and evaluate the effect of the modified definition.
  • Eligible expenses should be reported, but only to the extent the expense is not reimbursed or obligated to be reimbursed by other sources.
  • Recipients of between $10,000 and $499,999 in aggregated Provider Relief Fund payments will report healthcare-related expenses attributable to coronavirus in two aggregated categories: General and administrative expenses, and other healthcare-related expenses. Those who received $500,000 or more in payments need to provide more detailed information.
  • Entities that received more than $750,000 in Provider Relief Fund payments are subject to audit requirements.

“Any sort of reporting program needs to take all of this into account. Providers may need to recalculate their lost revenues and need to be sure to document everything,” Macre says. “Audits are likely, especially if a larger amount of funds was taken. Accounting needs to be done carefully and in a well-documented manner.”