HHS Reporting Requirements Finally Issued

09/28/2020 9:31:40 AM

HHS reporting requirements were finally issued on September 19, 2020.  The full disclosure is here.  Like we’ve seen with other Covid-19 related laws this year, the disclosure raised as many questions as answers.  This is a summary of what the requirements mean to most dental practices who received HHS relief funds, as we understand them to this point.


  • Reports must be submitted before 2/15/2021 for the calendar year 2020.
  • If you’ve used all your HHS funds on allowable items (discussed below) during 2020, no further reporting is required.
  • If you haven’t used all funds on allowable items by the end of 2020, you have until 6/30/2021 to do so, with a second report due by 7/31/2021.


Allowable use of funds is where the questions arise.  The reporting requirements indicate two permitted uses—healthcare related expenses and lost revenue.  Clarification is definitely needed!  Fortunately, they’ve already got it planned…for “sometime” before the reporting deadline.  In other words, who knows when.  But here’s how it appears:

Healthcare Related Expenses

  • Healthcare related expenses will cover the expenditures you made to comply with all the standards of care the pandemic demanded.  These include things like:

Plexiglas partitions                             UV lighting
Air filtering systems                            PPE—but not PPE that was reimbursed by patients or insurance
Suction machines for air particulates                 

But it also includes General and Administrative expenses that allowed you to “maintain healthcare delivery capacity.”  It lists examples such as:

Rent                                                      Insurance 
Nonclinical staff costs                           

Again, these can’t include anything that was reimbursed by another source.  So some of your nonclinical staff costs paid with PPP funds, for example, will be tossed out.  But potentially the remainder of these costs for the period of approximately 3/15-12/31/20 will count.  Since these are all items you pay in a normal year, not just a pandemic year, we would expect there to be some limit on these—the amount above what you would normally spend, for instance.  But the guidance doesn’t indicate any limitation.

And that’s good because the second item is going to be surprisingly hard to meet:  lost revenue.

Lost Revenue

  • Lost revenue was originally announced as lost patient fees.  You were mostly closed for at least 6 weeks.  Easy peasy to prove lost patient fees, right?  But the new guidance changed the requirement to lost net income.  And so far, that is not materializing.  It’s true that in most cases total 2020 revenues will be down from 2019.  BUT the trend we’re seeing is that total expenses are even more down.  That makes net income actually higher than the prior year.  Additionally, expenses reimbursed by PPP costs must be excluded from the calculation.  Throwing out those expenses raises net income even higher.  If adjusted net income for 2020 ends up higher than 2019, there will be no lost revenue under this rule. 

Beyond those requirements, the actual reporting is looking as complex as bureaucracy can make it.  You will have to report specific expenses according to HHS rules which don’t line up with normal financial statement accounts.  In addition, you will have to report personnel metrics and patient metrics…and possibly promise your first-born child.  Hopefully, clarification will come soon.