Updates About COVID-19 (Coronavirus) - Learn More

Reingruber Alert: CARES Funds Attestations

5/12/2020 - By Claudia Reingruber, CPA, CHC

New Deadlines for Attestation & Submission of Required Data

  • General Distribution Attestations are Now Due within 45 Days of Receipt
    • Round #1 - $30 billion was paid between April 10 - 17, 2020
      • New Deadline is May 24, 2020 for most providers
    • Round #2 - Distributions from the $20 billion began 04/24/2020
      • New Deadline is June 7, 2020 for most providers
  • Attestation Must Be Supported by Specific Information Including: 
    • "Estimates of Lost Revenues in March and April of 2020"
    • Tax Return Data
      • Tax Identification Number (TIN)
      • TINs for subsidiary organizations without separate tax returns
      • Copy of most recent tax return filed
    • Data from CARES Funds Received
      • Amount of payments received (Tranches 1 and 2)
      • Relief Fund Payment Transaction Numbers and check numbers

Is Your Estimate of Lost Revenues in March & April 2020 Accurate?

HHS Offers Considerable Latitude with Lost Revenue Estimates

  • Estimates of lost revenue for March and April of 2020 are required
  • Examples from HHS of the types of data to consider include the following:
    • Comparison of year-over-year revenue
    • Comparison of budgeted revenues to actual revenues
    • Extrapolation from trends in earlier months
  • Carefully consider your unique circumstances in formulating estimates

Prepare Now for CARES Act Funds Quarterly Reporting

  • All providers that received CARES Funds must support their use
    • Providers that received more than $150,000 will be required to submit quarterly reports, with the first one due 07/10/2020
    • All providers, regardless of amount received, must maintain documentation on the use of funds and are subject to audit
    • Even though details for the quarterly reports have not been published, now is the time to prepare!
  • Providers must have internal accounting mechanisms in place now
    • Segregate CARES Fund receipts in separate G/L cash account
    • Provide department heads with expense tracking tools
    • Document personnel time attributable to COVID-19 tasks
    • Consider all aspects of COVID-19 efforts after January 31, 2020
  • HHS plans oversight and enforcement mechanisms to ensure providers:
    • Comply with relief fund terms and conditions
    • Document use of funds for increased healthcare-related expenses and lost revenue attributable to COVID-19
    • Separate expenses and losses from those reimbursed by other sources
  • HHS and OIG will undertake anti-fraud monitoring and oversight

The Healthcare Division at Saltmarsh can help you:

  • Establish cost accounting to track compliant use of grant funds
  • Assist with preparation of lost revenue estimates for March and April 2020
  • Identify other available COVID-19 relief programs you may have overlooked
  • Untangle complicated federal rules governing COVID-19 documentation
  • Help you benefit from available resources to meet ongoing challenges!


If you have questions about your particular circumstances, please contact our team or call (800) 477-7458.

Visit our COVID-19 RESOURCE HUB for ongoing updates and information. Due to the ever-changing nature of this event, you should always consult a professional.

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