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Volume 20.24

The Health Group, LLC never thought that the U.S. Department of Health and Human Services (“HHS”) would be able to develop a format for reporting use of Provider Relief Funds in time to meet the initially scheduled July 10, 2020 reporting date. Yesterday, the Department of Health and Human Services (HHS) updated its Provider Relief Fund frequently asked questions (FAQs) to clarify that recipients are not required to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee.

While Provider Relief Fund recipients are not required to submit a quarterly report, the Terms and Conditions also require recipients to submit any reports that are requested by the HHS Secretary to ensure compliance with the Terms and Conditions. In the coming weeks, the agency notes that it will be requiring recipients to submit reports detailing the use of Provider Relief Funds.

The agency is also collaborating with the Department of Treasury to report the aggregate total of each recipient’s attested to Provider Relief Fund payments on USAspending.gov. HHS states that these public reporting activities satisfy the Provider Relief Fund reporting requirements under the Coronavirus Aid, Relief, and Economic Security (CARES) Act.

Further information is available here.

Providers need to continue to identify COVID-19 PHE expenses in their accounting records in a sufficient manner to identify those expenses to facilitate support for the use of those funds and develop records supporting calculations of lost revenues, also in support of the use of those funds. Remember, the accounting records will need to accommodate the completion of cost reports encompassing the COVIDE-19 PHE period, regardless of how those expenses are incorporated into the provider’s cost reports.

The Health Group, LLC will be providing a separate release on cost reporting for COVID-19 PHE in the next few days. We have been waiting for anything that HHS or CMS may release regarding this reporting; however, providers should be accumulating the information in a manner to facilitate completing the cost report regardless of the potential approaches that may be taken by CMS or the respective MACs.


The Health Group, LLC has offered live programming annually for many years. As a NASBA-approved sponsor, we are now approved for CPE offerings in formats other than live programming. Many of our former program attendees have inquired about any programs that may be offered later in 2020; however, due to the COVID-19 PHE, we have suspended planning for any live programming through the end of 2020. However, we are currently planning for other program formats which would allow CPA attendees CPE credit. We will continue to keep you informed regarding any programs in planning.