fbpx

< Back to Thought Leadership

New Changes to Lost Revenues Calculation

Two important events happened this past Friday morning regarding the Provider Relief Fund.

First, the reporting portal did not open as previously announced and providers do not need to begin reporting on the use of their funds yet.

Second, additional reporting requirements and documents were released by HHS to incorporate the December 22, 2020 COVID Relief Bill updates with a focus on changes to the lost revenues calculation.

Weekly Insights

Expanded definitions on lost revenues calculations were provided and HHS has offered three choices. We’ve also included the full reporting requirements from HHS below.

Option 1 – Report on calendar year 2020 actual patient revenue vs 2019 actual patient revenue

Option 2 – Report on calendar year 2020 actual patient revenue vs 2020 budgeted revenue. The budget must have been approved by March 27, 2020 and provided to HHS. Additionally, the CEO or CFO must sign an attestation “that the exact budget being submitted was established and approved prior to March 27, 2020.”

Option 3 – An alternate methodology using “any reasonable method of estimating revenue” may be used. Detailed descriptions of the methodology used and why the methodology is reasonable are required. Additionally, an explanation of why the methodology is reasonable, and establish how the identified lost revenues were in fact a loss attributable to coronavirus, as opposed to another source.

Finally, in the reporting requirements, HHS mentions that any provider using option 3 will be under increased likelihood of an audit and they will review if the alternate method is reasonable. If your organization is considering using the “any reasonable method” for calculation lost revenues, we recommend you prepare all three calculations and be prepared for a detailed review by HHS.

To download this blog post as a pdf, click here. To read more about what HHS has recently put out: HHS Provider Post Payment Notice of Reporting Requirements.

Got questions? Join us for our Provider Relief Fund Weekly Webinar Series.

Join us on Thursday, January 21, we will be hosting a webinar from noon to 1 p.m. EST to go over the recent reporting changes from HHS, provide any update on the reporting portal that we have, and answer any of your questions submitted through the registration page form. Click here to register for this event.

Share this article

CMS Finalizes 2026 OPPS Rule: Preparing for Market-Driven MS-DRG Reporting

CMS Finalizes 2026 OPPS Rule: Preparing for Market-Driven MS-DRG Reporting

In our last thought leadership, we gave an update on new pricing transparency rules.  Within the same rule, CMS requires a new cost report worksheet that utilizes the new pricing […]

Learn More
SNFs in 2026: Preparing for Audits, Surveys, and Value-Based Care

SNFs in 2026: Preparing for Audits, Surveys, and Value-Based Care

What to Expect from CMS in 2026 As we close out 2025 after a year of regulatory challenges, Skilled Nursing Facilities (SNFs) enter 2026 amid evolving CMS rules, heightened compliance […]

Learn More
Blue & Co., LLC Appoints New Leaders to Head Key Niches and Service Lines | Mike Fleetwood, CPA, Dale Skaggs, CPA, Shannon Borden, CPA, Eric Jaske, CPA, CEPA, Brad Minor, CPA/ABV/CFF, ASA, CVA, CMEA, CM&AA

Blue & Co., LLC Appoints New Leaders to Head Key Niches and Service Lines

CARMEL, Ind. (December 17, 2025) – Blue & Co., LLC is proud to announce the appointment of five firm leaders to head key industry niches and service lines, strengthening the […]

Learn More
Share this article
Share this article