The HHS Provider Relief Fund (PRF) reporting portal was scheduled to open on 1/15/2021.  The PRF Reporting portal’s operability has been delayed; however, you can begin the registration process to access the portal.  Below are a few tips regarding the registration process: 

• The PRF reporting portal is accessible at https://PRFReporting.hrsa.gov.
• The PRF reporting portal is separate from the application portal.  You will not be able to use your Optum ID and password to access the site.  You must create a new registration for the PRF reporting portal.  You will create a username (in the form of an email) and a password as part of the registration process.  The email provided will be used for communications throughout the reporting process.
• You must use the most current versions of Edge, Chrome or Mozilla Firefox to access the portal.
• The registration process will take at least 20 minutes to complete and you must complete the registration process at one time.  You cannot save a partial registration.  Please note the site will timeout after 15 minutes of inactivity.
• To complete the registration process, you will need the following information:
  • Tax ID Number (TIN) (or other number submitted during the application process)
  • Business Name of the reporting entity
  • Contact information of the person responsible for submitting the report
  • Address of the reporting entity
  • TIN(s) of subsidiaries
  • Payment information for the payments received
    • TIN of the entity that received the payment
    • Payment amount ( check your bank statement for this number)
    • Mode of payment (most were ACH transactions directly to the bank account)
    • Check number or ACH Settlement date (the settlement date is the date of the deposit – check your bank statement)

Health Resources and Services Administration (HRSA) will announce the timeline for submission of the reports when the PRF reporting portal is available.

We will continue to provide updates on the reporting process as more details become available.

Dear Client,

As you may be aware, if you received more than $10,000 in HHS Provider Relief Funds (PRF), you will be required to submit reports about the use of those funds.  Preliminary details are as follows:

• The reporting system will become available to recipients for reporting on January 15, 2021.   
• All recipients must report within 45 days of the end of the calendar year 2020 on their expenditures through the period ending December 31, 2020.
• Recipients who have used their PRF in full prior to December 31, 2020 may submit a single final report at any time starting January 15, 2021, but no later than February 15, 2021.
• Recipients with funds not expended after December 31, 2020 must submit a second and final report no later than July 31, 2021.
• Recipients will report their use of PRF payments using their normal method of accounting (accrual or cash basis)

The Coronavirus Aid, Relief, and Economic Security (CARES) Act appropriated funds to reimburse eligible healthcare providers for healthcare related expenses or lost revenues attributable to the coronavirus.  The reporting guidelines require recipients to report various data elements for calendar years 2019 and 2020.  Much of the required information can be gathered from your financial statements and accounting records, but other required data will come from other sources.  While you are waiting for your December financial statements to be prepared, there are several items you can be working on to prepare for the reporting process:

Review your 2020 purchases and identify the following items:

• Supplies purchased to prevent, prepare, or respond to coronavirus.  Examples include personal protective equipment (PPE), hand sanitizer and supplies for patient screening.
• Equipment purchased to prevent, prepare, or respond to coronavirus.  Examples include air purifiers, suction devices added to reduce aerosols, updates to HVAC systems.
• Information Technology (IT) expenses paid for IT or systems to expand or preserve care delivery during the reporting period, such as electronic health record licensing fees, telehealth infrastructure, increased bandwidth, and teleworking to support remote workforce.
• Facilities expenses paid for facility-related costs used to prevent, prepare for, or response to the coronavirus during the reporting period, such as lease or purchase of permanent or temporary structures, or to modify facilities to accommodate patient treatment practices revised due to coronavirus such as plexiglass shields and other methods implemented to create separation needed for social distancing.
• Other Healthcare Related Expenses are any other actual expenses, not previously captured above, that were paid to prevent, prepare for, or respond to the coronavirus.

Gather Revenue from Patient Care Payer Mix (2019 and 2020 by calendar quarter) for the following categories: (for the dental clients, this information will come from your practice management software such as Dentrix, Eaglesoft, etc.)

• Medicare Part A+B
• Medicare Part C
• Medicaid
• Commercial Insurance
• Self-Pay (No Insurance)
• Other

Gather non-financial data to be reported by calendar quarter.

• Staffing  – report the number of full-time and part-time employees by quarter including the number of re-hires, new hires, and employee separations.
• Patient Visits – report the total number of patient visits (in-person or telehealth)

We will continue to provide updates on the reporting process as more details become available.

Thank you,

The Catalyst and DPA Team

Paycheck Protection Program Loans (PPPLs)

Previously, the CARES Act provided that forgiven loan proceeds used for qualifying expenses would be excluded from taxable income. Congress also intended that qualifying expenses paid for with PPP loans would be deductible, but this portion was not specified in the CARES Act.

New Law – The CAA, 2021 provides that qualifying expenses paid for with the proceeds of PPP loans are specifically tax deductible.This clarification applies to new and existing PPP Loans and has no additional limitations.

Additionally, the CAA, 2021 renewed funding for another round of PPP loans to first- and second-time small business borrowers.

Second-time borrowers must meet the following three requirements:

• Employ fewer than 300 employees
• Has or will use the full amount of the first PPP loan (if applicable)
• Report at least a 25% reduction in gross receipts in any 2020 quarter compared to the same quarter in 2019

Finally, the CAA, 2021 creates a simplified PPPL forgiveness application process for loans up to $150,000. Eligible borrowers need to certify and provide the following information:

• Description of the number of employees the business was able to retain because of the covered loan
• The estimated amount of the covered loan amount spent on payroll costs and
• Total loan value

Emergency Economic Injury Disaster Loans (EIDLs)

The CARES Act provided various types of small businesses with access to Economic Injury Disaster Loans under Section 7(b)(2) of the Small Business Act. If a business applied for a disaster loan under this program during the covered period, they would receive an immediate advance, if requested, of up to $10,000. The CARES Act also stated that any EIDL Advance received would reduce PPPL forgiveness, essentially requiring the advance to be repaid.

New Law – The CAA, 2021 repeals the provision so that the receipt of an EIDL Advance will have no impact on PPPL forgiveness. The Act also provides that the EIDL is nontaxable and the deductions are allowed for otherwise deductible expenses paid with the amounts not included in income.

Borrowers that have already applied for and received forgiveness for the PPPL will soon be able to amend the application to request the EIDL Advance not reduce the forgiveness amount and request repayment.

**Note: Please watch for further communication once additional guidance has been released.

Subsidy for Certain Loan Payments

The CARES Act also provided benefits to businesses with current SBA Section 7(a) loans other than the new PPP Loans in the form of a government subsidy whereby the SBA will pay six months of principal, interest, and fees on qualifying loans. The payments were applied to the covered loan such that the borrower is relieved of the obligation to pay that amount at any future date.

New Law – The CAA, 2021 clarifies that the payments of principal, interest and fees on qualifying loans is tax-free and the related interest expense is deductible.

In addition to the original six-month forgiveness of payments, most entities are also eligible for an additional three months of payments beginning on February 1, 2021. Going forward these payments are capped at $9,000 per borrower per month.

Certain other entities are eligible for another eight months (vs. three months) beginning on February 1, 2021 and these payments are also capped at $9,000 per borrower per month. Eligible entities include the following:

• Most retail establishments
• Hotels
• Restaurants
• Personal care service providers (i.e., barber shops, beauty salons, funeral homes, and funeral services)
• Transportation
• News organizations

Employee Retention Credit (ERC)

The CARES Act provided an employee retention credit for employers that closed, suspended operations, or had a decline in gross receipts of greater than 50% due to COVID-19. This refundable credit is allowed against an eligible employer’s share of Social Security payroll taxes (6.2%). The CARES Act also stated recipients of PPP loan funds were not able to utilize this credit.

New Law – Beginning January 1, 2021 through June 30, 2021, the Act extends and expands the following CARES Act provisions:

• Increases the ERC rate from 50% to 70% of qualified wages which includes any qualified health plan expenses allocable to the wages (i.e., amounts paid to maintain a group health plan)
• Expands eligibility for credit by reducing the required year-over-year gross receipts decline from 50% to 20%
• Increases the limit on per-employee creditable wages from $10,000 for the year to $10,000 for each quarter

Retroactive to March 12, 2020, the CAA, 2021 allows employers who received PPP loan funds to potentially qualify for this credit.

**Note: Any wages used to determine the payroll tax credit for family medical or sick leave as part of the FFCRA that was passed may NOT be considered in determining qualified wages for this credit. Additionally, wages paid for with the PPP loan funds may NOT be considered in determining qualified wages for this credit.

Tax Provision Extenders & Other Tax Updates

Business Meals for 2021-2022

With the passage of this Act, taxpayers may deduct 100% of business meals (rather than the current 50%) if the expense is for food or beverages provided by a restaurantincluding carry-out or delivery meals. This benefit is effective for expenses incurred after Dec 31, 2020 and before January 1, 2023.

FFCRA Sick Pay & Emergency FMLA Credit Extended

The Families First Coronavirus Relief Act (FFCRA) passed earlier this year allowed employers subject to the EPSLA and the Expanded FMLA paid leave requirements a fully refundable tax credits to cover the cost of the leave wages related to COVID-19 from April 1, 2020 to December 31, 2020. These credits have been extended to March 31, 2021.

Other Extenders

• Work Opportunity Tax Credit extended through 2025
• Excise tax credits relating to alternative fuels extended through 2025 ($0.50-per gallon excise-tax credit)
• Exclusion for certain employer payments of student loans through 2025 – up to $5,250 annually (excluded from the individual’s income)

This email provides a summary of a few significant provisions in the Consolidated Appropriations Act of 2021 which was signed into law on December 27, 2020.  The details of the provisions are beyond the scope of this new blog.     

Podcast: Leadership in Uncertain Times

Leadership in Uncertain Times

HHS extended the application deadline to apply for the HHS Provider Relief Funds to September 13, 2020.  You must submit your TIN (tax identification number) for validation by the deadline in order to apply for funding.  In addition to extending the deadline, HHS also simplified the application process.  Please use this link to obtain an updated copy of the application for reference only:  https://www.hhs.gov/sites/default/files/provider-distribution-application-form.pdf?language=en

*Please note the application will still need to be completed via the online portal.  As part of this revised application process, the only document dentists will need to upload with the application will be your most recent federal tax return.

Practices receiving more than $10,000 in relief funds will be required to submit reports about the use of their provider relief funds.  Complete reporting details have not been released yet.  Here are a few things we do know from the HHS Provider Relief site and FAQ:

• The reporting system will become available to recipients for reporting on October 1, 2020.   
• All recipients must report within 45 days of the end of the calendar year 2020 on their expenditures through the period ending December 31, 2020.
• Recipients who have expended their funds in full prior to December 31, 2020 may submit a single final report at any time starting October 1, 2020, but no later than February 15, 2021
• Recipients with funds unexpended after December 31, 2020 must submit a second and final report no later than July 31, 2021.
• Providers may have incurred eligible health care related expenses attributable to coronavirus prior to the date on which they received their payment.  Providers can use their relief funds for such expenses incurred on any date, so long as those expenses were attributable to coronavirus and were used to prevent, prepare for and respond to coronavirus. 
• Funds can also be used to cover lost revenue due to the virus and to cover expenses that the lost revenue otherwise would have covered.  HHS encourages the use of funds to cover payments for the following:
  • Employee payroll or temp help
  • Employee health insurance
  • Rent or mortgage payments
  • Equipment lease payments

**As a reminder you cannot use the HHS Provider Relief Funds for the same expenses covered by the PPP Loan. 

Contact our office is you have questions or need assistance coming up with a plan for the use of all relief funding.

Dear Client, 

HHS announced some major updates on the Provider Relief Fund (PRF) including extending the application deadline to August 28.

Starting the week of Aug. 10, and through Aug. 28:

• Dentists who previously received small automatic payments from the General (Medicare) Distribution due to Medicare billings will be allowed to apply and receive additional funding.
• Dentists who experienced a recent change in ownership may submit their revenue information along with documentation proving a change in ownership for consideration for PRF payment.

On July 22^nd we sent an update listing some concerns related to the HHS Provider Relief Funds and also included a copy of the terms and conditions.  Some of those concerns were related to the balance billing language as well as the reporting requirements.  There have been recent updates as follows:

Term on Balance Billing (as clarified in the ADA hosted webinar on Tuesday 8/28)

• Qualifying for payment from the PRF has to do with past treatment earlier this year when HHS broadly viewed every patient as a possible case of COVID-19.
• Balance billing prohibitions apply only to treating current active COVID-19 patients with a medical record that supports a diagnosis of COVID-19.
• Presumptive and Possible cases are not defined the same way.
• Dental providers who are not caring for patients with presumptive or actual cases of COVID-19 are not subject to balance billing prohibitions.
• ‘Presumptive’ is defined as a case where a patient’s medical record supports a diagnosis of COVID-19.
• HHS thinks few, if any, dentists are performing dental work on active COVID patients, so there should be very few dental patients covered by this requirement.

Reporting Requirements (as clarified in the ADA hosted webinar on Tuesday 8/28)

• HHS posted a notice on 7/20 stating that detailed instructions regarding future reporting will be released on 8/17 and will apply to payments exceeding $10,000
• The reporting system will become available for reporting on 10/1 and will allow providers to demonstrate compliance with the terms and conditions including the use of funds for allowable purposes.
• Reports are due by 2/15/2021
• Recipients of PRF payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee.  HHS will handle these quarterly reports.

For more information, you are encouraged to watch the ADA recorded webinar from 8/28.  Use the link below to get to the ADA website page that has the link to the recorded video – it’s about an hour long.  You need to scroll down the page to the section titled “The Latest” and look for Webinar: Updates on the SBA Loans, Provider Relief Fund, Labor Issues and Congressional Action.

https://success.ada.org/en/practice-management/patients/infectious-diseases-2019-novel-coronavirus?utm_source=adaorg&utm_medium=globalheader&utm_content=coronavirus&utm_campaign=covid-19

Note: If you received an EIDL loan, per the EIDL loan agreement,  you need to report to the SBA any proceeds received from other government sources and they will determine if the funds are a duplication of benefits.  You will need to notify them via email at [email protected].  Be sure to include your loan and application numbers found at the top of your loan paperwork (SBA Form 1391)

Please feel free to contact our office if you have any questions about this program.