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HHS CARES Act Provider Relief Fund Reporting Requirements – Revised

By Robert Nasso, on October 26th, 2020

This article was written and produced by Robert Nasso, Partner, and Margaret Lally, Healthcare Consulting Manager. Looking to get in touch with Robert or Margaret? Reach out today:,

On October 22, HHS revised the lost revenue calculation used in the September 2019 guidance and announced expanded eligibility for the Phase 3 General Distribution.

Lost Revenue Calculation

In the September guidance, allowable lost revenue was calculated as the change in patient-related net income from 2019 to 2020 less healthcare-related expenses attributable to coronavirus. The new guidance shifts back to the calculation used in prior applications where allowable lost revenue is equal to the change in patient-related revenue from 2019 to 2020.

Lost Revenue = 2020 Patient Related Income – 2019 Patient Related Income

The current guidance still requires the expenses attributable to coronavirus to be netted with the above lost revenue calculation. This results in a worse outcome for providers who had a bigger loss in net income than inpatient revenue. As a result, we are anticipating that this new calculation may change such that lost revenue will be allowable in addition to expense attributable to coronavirus not net of it. As guidance changes frequently, we encourage all providers to regularly check the provider relief fund website.

Phase 3 Eligibility Expanded

HHS has expanded Phase 3 eligibility to include the below provider types regardless of whether they accept Medicaid or Medicare. The application due date is November 6, 2020.

  • Behavioral Health Providers
  • Allopathic & Osteopathic Physicians
  • Dental Providers
  • Assisted Living Facilities
  • Chiropractors
  • Nursing Service and Related Providers
  • Hospice Providers
  • Respiratory, Developmental, Rehabilitative and Restorative Service Providers
  • Emergency Medical Service Providers
  • Hospital Units
  • Residential Treatment Facilities
  • Laboratories
  • Ambulatory Health Care Facilities
  • Eye and Vision Services Providers
  • Physician Assistants & Advanced Practice Nursing Providers
  • Nursing & Custodial Care Facilities
  • Podiatric Medicine & Surgery Service Providers

If you have questions or need additional assistance, please feel free to reach out to us.

The information and advice we are providing for this matter relates to COVID-19 legislative relief measures. Because legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that could modify some of the advice and information provided to you, after the conclusion of our engagement. We, therefore, make no warranties, expressed or implied, on the services provided hereunder.

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Written By

Rob Nasso April 2020
Robert Nasso
Senior Counsel

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