Attention California SNFs: DHCS COVID-19 PHE Reporting Schedules are due

Update: Many California Skilled Nursing Facilities have questions about the DHCS Covid-19 PHE Reporting Schedule deadline. Here’s what we know:

• August 15, 2026 was the original DHCS deadline for CY 2023 PHE Reporting Schedules.

• Facilities that have not submitted are considered out of compliance with Medi-Cal program requirements. However, DHCS has stated that they will accept reports submitted by December 31, 2026.

• DHCS clarified the DHCS PHE Reporting compliance letters sent to facilities do not change the December 31, 2026 deadline, but they do represent the first step in the DHCS compliance process.

• DHCS has indicated that their goal is to ensure every provider submits a report as soon as possible, but retains authority to pursue enforcement actions, including recoupment under WIC section 14126.032(c).

• If your facility has not yet submitted, DHCS strongly suggests that you do not wait for the December deadline and submit the reporting as soon as possible.

We’ve completed thousands of DHCS submissions and are available to answer questions or help with preparation. If you'd like to talk through your situation, don't hesitate to reach out.

Learn more about the California Regulatory Requirements:

COVID-19 PHE Reporting Schedules Due August 15, 2026

DHCS has extended the Medi-Cal COVID-19 PHE reporting requirement to include calendar year 2023. Facilities that received the 10% Medi-Cal COVID-19 rate add-on must submit reporting schedules for PHE-related expenses and revenues from January 1 through December 31, 2023. The prior cycle covered March 2020 through December 2022.

Key requirements

• At least 85% of the rate add-on must be spent on qualifying labor costs (wage increases, retention bonuses, shift incentives, non-management overtime). The remaining balance may cover other qualifying COVID costs such as PPE, testing, and staff training.

• Federal PHE-related funds received during 2023 (HRSA, PRF, or other grants) must be reconciled against the COVID expense pool to avoid double-counting.

• Facilities with a Change of Ownership must disclose CHOW details on Schedule 2; the original recipient of the increased payments is responsible for filing.

The reporting schedules, instructions, and FAQ are available on the DHCS Medi-Cal COVID-19 PHE Audits webpage.

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