Nursing Home Provider Relief Fund Reporting: The Expense Was Already Paid

Nursing home Provider Relief Fund fraud involves knowingly false expense reports or lost-revenue calculations used to justify keeping pandemic relief money. In one nursing-facility audit finding, expenses remained on a relief-fund tracking sheet after other grants had paid them. In another, a facility reported lost revenue as a facilities expense. An employee who knows how those entries reached the report may hold the explanation the numbers alone cannot give. Keeping relief money through false reports cheats taxpayers who funded help for patient care.

What the Nursing Home Provider Relief Fund Audit Found

The HHS Office of Inspector General’s June 2025 audit found $2,256,504 in unallowable expenditures and lost revenues at eight of thirty selected nursing facilities. It separately identified $332,562 in potentially unallowable expenditures at three facilities. One facility appeared in both groups, leaving ten with findings.

The first group included duplicate expenses, costs already reimbursed elsewhere, missing invoices and an unsupported lost-revenue calculation. The second concerned mortgage and rent allocations that the facilities could not substantiate. The Inspector General recommended that the Health Resources and Services Administration require repayment or properly supported replacement of the unallowable uses, with further review of the potentially unallowable amounts.

What Provider Relief Fund Reporting Had to Connect

Provider Relief Fund reporting connected the recipient, the kind of payment, the permitted use, the reporting period and the records supporting that use. The money arrived while nursing facilities faced falling admissions and rising costs for staffing, protective equipment and testing. Relief could support eligible healthcare expenses or patient-care revenue lost because of COVID-19.

General payments and the original skilled nursing facility targeted payments could cover eligible expenses or lost revenue. Nursing Home Infection Control payments had a narrower purpose: infection-control expenses, including testing, staff and services tied to that work. Those payments could not cover lost revenue. A facility could receive money under more than one distribution, so a single undifferentiated relief-fund total could conceal the condition attached to a particular payment.

The initial general-distribution terms required recipients to certify that information in their applications and later reports was true, accurate and complete to the best of their knowledge. They also required records supporting the costs and barred reimbursement of expenses or losses already reimbursed, or owed reimbursement, by another source. The ledger and supporting documents were how the provider backed up its report.

The June 2021 reporting notice required reports when payments exceeded $10,000 in aggregate during a payment-received period. Reporting entities that received $500,000 or more in that period had to break expenses into detailed categories, including mortgage or rent, personnel, supplies and equipment. That detail connects a total to the kinds of costs an employee would recognize.

The Quality Incentive Payment program also made infection and mortality data part of the funding decision. To qualify, a facility had to meet infection-rate and mortality-rate tests, including infections below its county’s rate and deaths below a national performance threshold. An insider who knows those figures were changed to qualify for a payment has a reporting decision to discuss with us.

Which Company Reported the Money?

The reporting entity was identified by its taxpayer identification number. Under that notice, a parent could report its subsidiaries’ General Distribution payments. The original recipient of a Targeted Distribution remained responsible for reporting that payment, even after transferring it.

That distinction gives a finance employee a more precise question than which nursing home received relief. Which entity received this distribution, which entity used it, and which entity reported the expense? The reporting notice also called for subsidiary ownership changes and their effective dates.

Unsupported Expenses and Duplicate Support

An expense report can fail at several different points: the cost, the COVID connection, the funding source or the documentation. The nursing-facility audit makes each problem concrete.

The Grant Paid It, but the Tracking Sheet Kept It

The Inspector General found that one facility used relief payments for expenditures that other sources had reimbursed. The facility explained that it had failed to remove expenses covered by other grants from its relief-fund tracking sheet. The underlying expense could be real while the claim that relief money was needed to cover it was wrong.

Other facilities reported duplicate health care-related expenses. Those are separate comparisons: an expense entered more than once, and an expense already covered by a different payer. Both put the supporting ledger beside the reported total.

Nursing facilities could receive pandemic assistance from several sources. The audit considered reimbursement from emergency-management funding, Medicare, Medicaid, commercial insurance, the Paycheck Protection Program and state or local agencies. For an insider, the revealing connection may be between the grant ledger and the same invoice in the relief-fund file.

The Invoice and Payment Were Missing

The audit found facilities that lacked invoices, proof of payment or both for reported expenses. The report names bank statements and canceled checks as examples of payment support.

The Health Resources and Services Administration’s guidance required providers to retain supporting documentation even when they did not have to upload it with the report. A number reaching the reporting portal and a number backed by records were separate parts of the process.

An Expense During COVID Still Needed a COVID Purpose

The audit identified legal expenses from civil and administrative proceedings that were unrelated to COVID-19. It also rejected landscaping costs for an adjacent lot. The facility said the pandemic had left it without anyone to maintain the lot. The Inspector General found that expenditure was not attributable to COVID-19.

Other findings involved a salary above the applicable federal threshold and a reported payment amount greater than the actual expenses. These examples make the reporting question specific: what cost did the facility incur, what part was eligible, and what amount did it assign to relief money?

A Portion of the Building Became the Whole Rent Bill

The potentially unallowable mortgage and rent findings involved facilities that said they used part of their buildings for COVID-related or infection-control needs. They charged their entire monthly mortgage or rent to relief payments but could not document the space used for those purposes.

The rent existed before the pandemic and had not increased. The unresolved question was the allocation to the permitted use. A lease can show the monthly obligation. Documentation of how the space was used addresses a different part of the report.

Lost Revenue Needs a Baseline the Records Can Support

In a nursing home Provider Relief Fund audit, lost revenue documentation connects the claimed loss to patient-care revenue, the calculation method and the period covered.

The nursing-facility audit described three permitted methods for eligible payments. A facility could compare actual patient-care revenue with the corresponding period in 2019, compare actual revenue with an eligible budget, or use another reasonable method of estimating revenue. Each method required support for the number reported.

The Budget Had to Predate the Pandemic Calculation

The budget method required approval before March 27, 2020. The reporting notice called for the budget itself and an executive’s attestation that the exact budget submitted had been established and approved before that date.

The Inspector General found a facility that used the budget method for 2021 without a qualifying budget for that year.

An alternate method also needed a narrative explaining the calculation, why it was reasonable and how the loss arose from COVID-19. The calculation and that explanation belong together when we examine a reported loss with an insider.

Patient-Care Revenue and Facility Profit Measure Different Things

For the historical-revenue and budget methods, Provider Relief Fund reporting called for patient-care revenue before subtracting expenses, broken down by payer and quarter. The categories included Medicare, Medicare Advantage, Medicaid, commercial insurance and self-pay. Grants and investment gains or losses were outside the patient-care revenue calculation.

A nursing home’s overall financial results can combine different payers, other business lines, investment income and pandemic relief. A facility-wide profit figure answers a different question from the patient-care revenue comparison submitted for relief payments. We connect the reported revenue to the payer records and the entities included in the calculation.

Providers used their normal cash or accrual accounting, and the availability period depended on when they received the payment.

Infection-Control Money Became a Lost-Revenue Entry

One facility applied $517,214 of Nursing Home Infection Control payments to lost revenue and reported it as a facilities expense. The facility described an oversight during data entry. The Inspector General treated the use as unallowable because that distribution could not offset lost revenue.

This is why the name of the expense account cannot settle the question. The payment’s source, the underlying calculation and the reported category have to tell the same story.

What Evidence Is Needed to Prove Fraud?

Evidence of false Provider Relief Fund reporting connects the submitted representation to the underlying records and the people who understood the discrepancy. A direction to keep an already reimbursed expense in the report would tell us something the total alone cannot.

For an expense, that connection runs through the ledger, invoice, payment record and any other reimbursement. For lost revenue, it runs through patient-care revenue by payer and quarter, the chosen baseline, budget approval or alternate-method explanation. The entity map and ownership dates identify whose money and whose loss appeared in the report.

Operational records add another comparison. The reporting notice called for personnel counts, patient admissions and stays, and staffed-bed information. A finance report and the facility’s operating records describe different parts of the same period. An insider can explain who assembled the figures, who reviewed them and why a questioned entry remained.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

When You Know Why the Entry Stayed

If you worked on the relief-fund report and know an expense was already paid or a revenue calculation was changed to justify keeping the money, speak with our whistleblower experts about that reporting decision. We build the case with you around the payment, the supporting records and who knew the difference, bringing in Provider Relief Fund whistleblower lawyers who understand healthcare funding. Our whistleblower experts stay at your side from that first conversation through the case.