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Reporting on Parent-Subsidiary Relationships

Parent and Subsidiary Reporting Guidance for the Provider Relief Fund (PRF)

To determine whether an entity is the parent organization, the entity must follow the methodology used to determine a subsidiary in their financial statements. If the entity does not have such a methodology, then the entity (or individual) with a majority ownership (greater than 50%) will be considered the parent organization.

Definitions of Entities

Definitions per 45 CFR § 75.

Parent organization:

  • Has one or more subsidiary billing Tax Identification Numbers (TIN) that received General and/or Targeted Distribution payments in PRF Phases 1 to 4
  • Has associated providers that were providing diagnoses, testing, or treatment for individuals with possible or actual cases of COVID-19 on or after January 31, 2020

Subsidiary organization:

  • Defined as a provider associated with a filing TIN (the provider who submitted a PRF application) that provided diagnoses, testing, or treatment for individuals with possible or actual cases of COVID-19 on or after January 31, 2020.

General Distribution Payments

A parent TIN may (but is not required to) report on a subsidiary's General Distribution payments. This is true, even if:

  • The subsidiary or the parent originally attested to the payment’s Terms and Conditions.
  • The parent received these funds and transferred them to or between its subsidiaries.
  • The subsidiary transferred the funds to the parent.
  • The subsidiary was acquired or divested by the parent during the associated Period of Availability.

Additional guidance on General Distribution payments:

  • Transferring Funds: General Distribution payments may be transferred in either direction between a parent TIN and its subsidiary TIN(s).
  • Reporting Portal: At the time of registration and/or reporting, the following will be collected:
    • Information on any subsidiaries that are eligible health care providers.1
    • For each of those subsidiaries (if applicable), indication of whether the parent entity is reporting on the subsidiaries’ General Distribution payments. The system will pull in General Distribution payments of those subsidiaries, and the report will be completed in a consolidated manner for all payments indicated.
    • Information on any subsidiaries acquired or divested during the applicable Period of Availability.
    • Please refer to the October 27, 2022 Post-Payment Notice of Reporting Requirements (PDF - 170 KB) and the Reporting Portal User Guide (PDF - 2 MB) for more details on information that will be collected.
  • Reporting Portal: If a parent TIN has already reported on behalf of its subsidiary’s General Distribution payments and the subsidiary has only received those General Distribution funds, then the subsidiary should not register to report.

1As defined by statute, “eligible health care providers” are public entities, Medicare or Medicaid enrolled suppliers and providers, and such for- profit entities and not-for-profit entities not otherwise described as the Secretary may specify, within the United States (including territories), that provide diagnoses, testing, or care for individuals with possible or actual cases of COVID–19

Targeted Distribution Payments

A parent TIN cannot report on a subsidiary's Targeted Distribution payments. The original recipient of a Targeted Distribution payment must always be the Reporting Entity for that payment.

  • Transferring Funds: Parent entities may transfer and re-distribute Targeted Distribution payments to, between, and among its eligible health care provider subsidiaries. The Targeted Distribution payment allocation may not exceed the parent entity’s pro rata ownership share of the subsidiary. Further, transferred Targeted Distribution payments face an increased likelihood of HRSA audit.
  • Reporting Portal: In accordance with the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, while a parent entity may transfer a Targeted Distribution payment, the entity that originally received the payment must be the entity that reports on how the funds were used.
    • To report on a subsidiary's Targeted Distribution payments, the subsidiary TIN must register and report on the use of funds themselves.
    • To report on a parent’s Targeted Distribution payments, the parent TIN must register and report on the use of funds themselves.
  • Reporting Portal: The entity that ultimately receives the transferred Targeted Distribution funds should provide the original recipient with necessary information on its use of the funds. This information should be included in the reporting submission completed by the original recipient.
  • Reporting Portal: Reporting Entities must enter the total dollar amount of Targeted Distribution payment(s) transferred to/by the parent entity. In cases where more than one Targeted Distribution payment was transferred, the amount entered will be an aggregate of all payments transferred.

Parent and Subsidiary Reporting Guidance for American Rescue Plan (ARP) Rural Recipients

Parent TINs must allocate ARP Rural payments to eligible subsidiary TINs associated with their application, as required by the Terms and Conditions (PDF - 221 KB). A parent TIN is required to submit a consolidated report on behalf of each of its qualifying subsidiaries by the applicable reporting deadline. Subsidiary TINs should not submit a report on use of ARP Rural payments.

Reporting Portal Guidance

Please refer to the Registration User Guide (PDF - 1 MB) Subsidiary Information and Subsidiary/Payment Information for further details related to registering subsidiary information.

  • During registration, a parent entity reporting on behalf of many subsidiaries will only be required to submit payment data for one of the payments made to their own Tax Identification Number (TIN) or one of their subsidiaries. The payment information is only used for identity verification purposes during the first step of the reporting process: registration.
  • Parent TINs should not re-enter the TIN used for registration in the subsidiary table. The subsidiary table should only include subsidiary TINs.

Please refer to the Reporting User Guide (PDF - 2 MB) sections Subsidiary Questionnaire and Subsidiary Data for further details related to entering and reporting on subsidiary information. Providers are advised to carefully verify their answer choices to conditional questions before advancing through the PRF Reporting Portal, as answers will affect the content that appears in subsequent screens.

  • Reporting Entities may want to work with an accounting professional to determine the appropriate way to calculate lost revenues. Providers must maintain source documentation that fully supports the narrative and methodology for the record retention period of three years after the submission of the report. Please reference the Lost Revenues Guide resource for more information on calculating lost revenues.
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