Beyond Bitewings: Understanding New PPP Rules

 

Almost one year ago PPP was an acronym no one knew, and now it’s a source of everyday conversation. As 2021 offers hope for a new year, it also offers some new PPP rules for PPP loan forgiveness, payback, and a new opportunity to receive more help for businesses that suffered from losses in 2020. Could you use help understanding the new PPP rules?

In this episode of Beyond Bitewings we break down what dental business owners need to understand about the new rules, the new programs, how to know what’s available for them, and how to move forward with the new applications in addition to the PPP Loan Forgiveness Applications.

Before you try to get forgiveness from last year’s PPP loan or attempt to apply for new money in 2021, make sure you listen to this episode for help understanding the new PPP rules.

Have a question? Contact us to get your question answered and possibly featured in a future podcast, or contact any of our affiliates from the ADCPA.  

Like what you hear and want biweekly episodes auto downloaded to your listening device? Why not subscribe?

APPLE PODCASTS

SPOTIFY

Download the full transcript.

HHS PRF Reporting Update

HHS Reporting Deadline Coming Soon

If you received a Health and Human Services (HHS) Provider Relief Fund (PRF) payment, a reporting deadline is approaching. As you may recall, there were 3 phases of HHS Relief payments. You may have received relief payments from Phase 1 or Phase 2, and possibly from Phase 3. If your payments totaled more than $10K, you are required to report the use of those funds.

The original first reporting deadline was January 15, 2021, through February 15, 2021. The stimulus bill that passed in late December 2020 has pushed these dates. Updated dates are still not known.

HHS Reporting Portal Open for Registration

But the portal is open, and HHS is encouraging you to begin the registration process.  Home (hrsa.gov)  BE PREPARED before you start. According to the HHS website, “You cannot save a partially complete registration. Make sure you have all of the information required to register before you begin.”

Data Needed for Registration

What do you need? Here is the list directly from HHS. Note, especially the 3 items where we’ve added **. The payment amounts and dates are least likely to be at your fingertips. So be sure to look up that information in advance.

  • Tax ID Number (TIN) (or other number submitted during the application process (e.g., Social Security Number, Employer Identification Number (EIN))
  • Business name (as it appears on a W-9) of the reporting entity [This should be your legal business name.]
  • Contact information (name, phone number, email) of the person responsible for submitting the report
  • Address (street, city, state, five-digit zip code) of the reporting entity as it appears on a W-9)
  • TIN(s) of subsidiaries (if a provider is reporting on behalf of subsidiary(ies) – in a list delimited by commas, e.g.,123456789,987654321,135791357)
  • Payment information (for any of the payments received)
    • TIN of entity that received the payment
    • **Payment amount
    • **Mode of payment (check or direct deposit ACH)
    • **Check number or ACH settlement date 

You must report a second time if all your funds were not utilized by December 31, 2020. The second reporting deadline is scheduled for July 31, 2021, and will not likely change.

Specific reporting and supporting data requirements for the HHS PRF are here, but I wouldn’t try to read this too close to bedtime. 

EIDL Advances VS PPP Forgiveness

1/8/2021 9:20 PM

The latest Coronavirus relief bill passed on December 27, 2020.  As mentioned in our earlier post, one provision changed the treatment of EIDL advances as they relate to PPP forgiveness. Under the old rules, if you received an EIDL advance, it reduced your PPP forgiveness amount. But under the new rules, EIDL advances will not reduce your PPP forgiveness amount. 

So, what if you already received PPP forgiveness under the old rules?  Your EIDL advance reduced your forgiveness amount. If you otherwise achieved full forgiveness, you essentially were left with a small PPP loan to repay equal to your EIDL advance. “That’s not fair!” you say. After all, those who are just now applying for forgiveness have the opportunity to have their entire loan wiped away. The SBA issued a notice today rectifying this discrepancy. They will remit payment to your PPP lender for the amount of your EIDL advance, essentially allowing you the full PPP forgiveness for which you were eligible. In most cases, this will mean 100% forgiveness of your PPP loan. If you already made any PPP loan payments that have now become unnecessary, have no fear.  Your lender should refund them to you. 

Employee Retention Credit and PPP

1/9/2021 3:31 PM

The recent Coronavirus stimulus bill (overview here) signed on December 27, 2020, made a significant change that could affect you in a good way. The Employee Retention Credit (ERC) was a credit enacted in the early stimulus bills in Spring 2020. But under the original rules, it was off-limits to anyone that took a PPP loan. For that reason, it was rarely discussed since most dentists were not eligible to claim it.  

The new bill removed this prohibition. You will not all qualify for this credit. And for some of you that do qualify, it will not be significant enough to fool with. But for some of you, it could be major and it should be investigated.

What are the requirements to qualify for the Employee Retention Credit?

  • The full or partial suspension of operations due to a government order OR
  • A 50% or more decrease in gross receipts for a quarter in 2020 compared to the same calendar quarter in 2019.

Based on the statistics we have seen, some of you will qualify under the revenue reduction. And if you do, great! You don’t need to worry about the government shut-down issue. But we believe many others will qualify under the partial suspension of operations due to a government order. It probably seems obvious to you that you would.  But trust me. There is rarely anything obvious about these laws. Please allow us time to complete the research.  

We are working to provide you more details of the Employee Retention Credit (ERC). But until we can, we want to issue this warning: If you think you might qualify for the ERC, hold off on filing for forgiveness for your PPP1 Loan. This is especially true if you don’t qualify to use the new Simplified Forgiveness application. Why? Because you will need to strategize to maximize your ERC and still achieve full PPP forgiveness. That strategy could affect the documentation submitted with your PPP forgiveness application. It will affect the calculation of the ERC credit and an incorrect strategy will reduce your ERC.

There is no rush to file for PPP forgiveness yet.  So let patience be your motto a bit longer.  If you’re craving more information, our ADCPA affiliate in Boston has a great webinar on their preliminary ERC thoughts. 

 

PPP2 Applications Released

1/9/2021 9:34 AM

PPP2 applications have been released!  Find them here.  You can’t apply just yet.  Applications open on a limited basis beginning Wednesday.  But you can start preparing.

Among other items, you must demonstrate a 25% drop in revenue in any quarter of 2020 as compared to the same quarter of 2019.  For other PPP Round 2 requirements and details, see our previous blog.  

For entities not in business during 2019 but in operation on February 15, 2020, applicants must demonstrate that gross receipts in the second, third, or fourth quarter of 2020 were at least 25% lower than the first quarter of 2020.

You must apply for PPP2 by March 31, 2021. There are expected to be plenty of funds available for those that qualify and are in need.  But don’t procrastinate.  Funds are available on a first-come, first-served basis.  Reminder:  if you use the same bank for your PPP1 and PPP2 loans, and if you base your application on 2019 payroll costs, no new supporting documentation will be required.  You will only need to submit a new application.

PPP Round 2 Applications to Open 1/13/2021

1/9/2021 9:14 AM

We have received the following notification regarding PPP Round 2 applications from Megan Mortimer , Congressional Lobbyist for the ADA. 

Smaller lenders can start taking applications for PPP Round 2 loans beginning Wednesday, January 13, 2021.  Larger lenders will follow soon after.  The ability to accept these applications will vary lender to lender based on how prepared they are, and how willing they are to accept them.

For details on PPP Round 2 eligibility, click here.

Thanks to the Academy of Dental CPA’s for helping us keep you up to date with valuable contacts and timely information!

PPP Round 2: What you need to know

01/08/2021 8:44:57 AM

PPP Round 2: New Year Same Pandemic

I know. You’re eager for information about PPP Round 2! But it feels like Groundhog Day around here. Not the good kind of Groundhog Day where scenes get cuter and funnier until Bill Murray gets the girl. It’s more like a horror movie when the victim runs upstairs with nowhere to escape and you know the monster is lurking behind the door. Much like last spring, I can’t get a single blog written before a new topic pops up or new regulations come down. The year is starting in a whirlwind!  

So much for the editorial rant. Now to the topic at hand. We had a high-level overview of PPP Round 2 in the last post. Here’s a deeper dive as it pertains to the typical dentist.

BASICS

  • Date applications open: As soon as the banks are ready.
  • Deadline for applying: March 31, 2021.
  • Terms if not forgiven: 1% interest, repayment over 5 years.
  • PPP Round 1, which I will shortcut as PPP#1, is officially called the “First Draw PPP Loan.”
  • PPP Round 2’s official name is the “Second Draw PPP Loan.”

ELIGIBILITY

You must have:

  • 300 or fewer employees and
  • A drop in total revenue of at least 25% in any quarter of 2020 compared to the same quarter of 2019 and
  • Received PPP#1 funds and
  • Used ALL your PPP#1 funds on ELIGIBLE expenses.

A worksheet to help evaluate your quarterly revenue drop is available here.

LOAN AMOUNT

  • Calculated the same as last time at 2.5 times your average monthly 2019 payroll costs. You can choose to use 2020 payroll costs, but those will likely be lower, so less appealing.
  • If you are a partner or self-employed, your personal portion is based on net self-employment income, same as the first time around.

APPLICATION AND DOCUMENTS

  • Noteworthy:  IF you apply at the same bank, and you used 2019 for your PPP#1 application, and you use 2019 for your new PPP#2 application, THEN you don’t have to submit additional support for this new application. All the support would be the same, so if you use the same bank, you don’t have to resubmit anything. Otherwise, you must submit all the same support as last time (payroll registers, 941s, etc, etc.).
  • If your new loan is over $150K, you will have to provide evidence of your 25% required revenue drop.   
  • If your new loan is under $150K, you do not have to provide evidence of your 25% required revenue drop. The requirement isn’t gone. You just don’t have to prove it…yet. You will have to submit support with your PPP#2 Forgiveness application.

Although there was talk of an economic need test being one of the requirements, that doesn’t seem to be the case.  

Bottom line: If you qualify for PPP#2, your 2020 payroll costs are down from 2019, and you liked your PPP#1 bank, your most efficient route will be to go back to that bank and reapply. If you had difficulty with them, especially if they didn’t accept your personal self-employment income as part of payroll costs, consider a new bank. We have a couple of great ones we can recommend.

December 2020 Coronavirus Relief Bill

01/07/2021 7:52:15 AM

The latest Coronavirus relief bill

was signed into law on December 27, 2020, and many items could directly affect you. Below we will go through the 5000+ page bill line by line by line….

Or maybe let’s just do some bullet points!  

PPP Round 1 Loans

  • Covered Expenses paid with your PPP#1 Loan will now be tax-deductible. This is a biggie! Before this change, all the expenses you paid with PPP funds had to be tossed out, raising 2020 taxable income by the amount of your PPP loan. Extra YAY to this one! 
  • If you received an EIDL advance, it will no longer reduce the amount of your PPP forgiveness. Before this change, your PPP forgiveness amount would have been reduced by any EIDL advance payment you received. 
  • The forgiveness application process will be simplified for loans of $150K or less. We had high expectations this would come to fruition, so our patience has paid off! Previously, the process had been simplified for loans of $50K or less. Please continue to wait to apply for forgiveness. The banks are still waiting on updated guidance from the SBA and the US Treasury and then must update their portals.  

PPP Round 2 Loans 

  • A new round of PPP funding was authorized.  
  • $284.5 Billion in funds will be available in this round through March 31, 2021.
  • The SBA was given 10 days after enactment to establish regulations for PPP#2 funding. BUT as you recall, that’s the same timeline they were given on Round 1 and they didn’t even kind-of hit it.
  • To obtain this round of funding you must meet the following requirements. Be aware though—SBA’s regulations may alter or add to these.

Have fewer than 300 employees 

Have a 25% or greater reduction in collections in any quarter of 2020 when compared to the same quarter of 2019. For most of you, 2Q2020 will be the critical quarter that is most likely to show the necessary 25% drop.  

Other Key Tax Provisions for Dentistry

Employee Retention Tax Credit:

  • Extended through July 1, 2021.  
  • Previously you could not take advantage of this provision if you received PPP funds. That exclusion was eliminated.
  • BUT this credit is only triggered if you had a greater than 50% drop in revenues in a given quarter of 2020 or a 20% drop in revenues in a given quarter of 2021, as compared to 2019.. We certainly hope there will be no 2021 drop in revenue of 20%! 
  •  
  • If this is of any value to you, it will most likely be based again on the 2Q2020 drop in revenues.  
  • This is a complex issue and intertwined with the workings of PPP forgiveness. We will release a separate detailed blog. 

COVID-Related Pay Tax Credits: 

  • Extended to March 31, 2021. 
  • These are the refundable payroll tax credits for Emergency Paid Sick Leave and Emergency Family Medical Leave Pay that were set to expire on December 31. 
  • Again, more details need to be provided on this one. We will release a separate detailed blog.

Department of Health & Human Services (HHS) Payments

  • Many of you received Phase 2 and/or Phase 3 funding from the Department of Health & Human Services. Current regulations require you to report how you used those proceeds under the rules. Reporting is due in January 2021, and possibly again in July 2021. We expect HHS to provide further guidance as to what documents will need to be submitted. For now, please save all documentation (invoices, canceled checks, and credit card receipts) for any items you purchased that would qualify as PPE Equipment & Supplies. 

Latest on PPP Forgiveness

12/01/2020 2:17:14 PM

Recently the IRS solidified its position that expenses paid with PPP funds would not be deductible if you expect forgiveness on the loan. And we hadn’t heard any chatter from congress in months on this issue. We concluded that hope was fading on the issue. The same was true for PPP forgiveness applications. Many months ago there was optimism that loans under $150K would be easily forgiven under a streamlined process. Then the process was eased for PPP loans under $50K, and hope began to fade for loans between $50K and $150K.  

BUT all hope is not lost yet! At approximately 10:30 am, a bipartisan, bicameral group of Senators and Congressmen held a press conference to roll out a framework/outline for COVID emergency relief legislation.  

Will PPP expenses be deductible? Will the PPP forgiveness process for loans under $150K be simplified? It is still VERY uncertain how these 2 issues will ultimately conclude. But at least there are conversations taking place again. The intention is for something to be passed before the end of the year. Below is a chart of items being discussed for the current bill.  

 

2020 Yearend Tax Planning

It is that time of year again, time for 2020 Yearend Tax Planning!

What is Tax Planning Anyway?

 

Investopedia.com defines tax planning as “The analysis of a financial situation or plan from a tax perspective. The purpose of tax planning is to ensure tax efficiency.” They go on to say “Reduction of tax liability and maximizing the ability to contribute to retirement plans are crucial for success.”  Regularly participating in tax planning is a very valuable tool in planning for a stable future for you and your family.

With 2020 being such a strange year and amidst all of the Covid-19 chaos, are you wondering how your 2020 taxes will pan out? Are you thinking your taxes won’t be as high this year because your income is down? If you received any PPP or other relief, this actually may not be the case. Yearend tax planning can help flesh out the tax information you desire. And depending on your unique situation, we can most likely provide strategies to take before yearend to help minimize the 2020 tax hit.

Are you a current E&A client?  Then you should have already received your tax planning email with the information we need to get started. If you didn’t receive this email please reach out to Meka Edwards meka.e@eandassociates.com and ask her to resend it. Are you not yet engaged as an E&A client but you want or think you need tax planning?  Then please contact Kristi Smith kristis@eandassociates.com she will help you determine if yearend tax planning is right for you. 

The deadline to participate in 2020 Yearend Tax Planning is November 20th when we must have all of your information in our hands for processing. Let us help you end this crazy year with a little peace of mind. Still have questions? Please contact us.

Unemployment Fraud

10/22/2020 8:44:32 PM

Unexpected notification of benefits 

Throughout the pandemic, relief and stimulus funds have been vital to sustaining the business and individual sectors of our society.  Unfortunately, this has also created a breeding ground for new fraud.  This is especially coming to light currently in the area of unemployment fraud.  We’ve heard from several of you, as business owner-employers, with similar stories.  You’ve been unexpectedly approved for unemployment benefits!  Except…you didn’t apply for those benefits.  Some of you have even received unemployment checks out of the blue.  Your practices are up and running and generally thriving, so we’re past the time to apply for unemployment benefits.  This could be an error on the part of the State Unemployment Tax Associations.  But it is equally likely that someone has applied fraudulently under your information.

How to respond

There is no great answer to remedy the situation. As you can imagine, the SUTA offices are overwhelmed with claims.  They have not been able to devote much time to educate us on the protocol for the situation. But here are our best recommendations:

  • Respond to any questionnaires from your SUTA office, as requested, indicating that you are not unemployed.
  • Do not cash any unemployment checks received in error.
  • Retain copies of all correspondence and checks for future support for your SUTA office, if needed.
  • Report the possible fraud to your SUTA office.  For more information on unemployment fraud in Texas click here.  For a direct link to the fraud reporting page in Texas, click link. 

Simplified PPP Forgiveness App

10/09/2020 11:14:17 AM

GREAT NEWS! The SBA has released a simplified PPP forgiveness app for loans of $50K or less. There is now a simple 1-page form. The original application is complex. So, this simplified form will save you much time and money! You will still have to submit documentation to confirm the use of PPP money on qualified items. But gathering the required documentation will be the hardest part of the process! 

You can learn a lot by simply reading the new application, so take a look.  

We will post a list of the required documentation to submit with the application soon. In the interim, you can find the instructions here, which contains the list of required documentation.  

There was previously talk of a simplified application for loans under $150K. We now have the simplified PPP forgiveness app for PPP loans of $50K or less. We don’t know yet if there will be a further simplification for loans between $50K and $150K. We’ll keep you posted!

HHS Phase 3 Relief Announced

10/03/2020 12:43:45 PM

HHS Phase 3 Relief Announced

The Department of Health and Human Resources has announced a new round of relief funding. The portal will be open from October 5 through November 6, 2020. Apply early if you’re eligible!  

So, who’s eligible?

The new round is primarily to benefit two groups that were previously excluded:

  • Practices that opened between January 1 and March 31, 2020.  You were not previously eligible to apply because you had no prior year patient fees.
  • Practices that received a small payment under the general distribution (phase 1).  Round 2 payments were much larger—2% of prior year revenues.  But if you received a phase 1 payment, you weren’t eligible for a phase 2 payment.  You missed out on the more substantial relief.  The new distribution supplements the first payment up to the 2%-of-revenue amount.

Add-on Payment

Also, practices that have already received benefits can apply for an add-on payment for lost revenue.  This is over and above the 2% payment described above, or that you’ve already received.  But approach this add-on with caution! 

Current HHS guidance indicates this may mean reduced net income rather than straight patient fees.  Using that definition, many practices will not ultimately show a decrease in net income for 2020 because expenses paid with PPP funds must be excluded from the calculation.  Many practices are also reporting patient fees trending over 2019.  But they’re reporting lower expenses.  They’re running leaner since the start of the pandemic.  Again, this results in higher net income, not lower.  And if the calculation is truly based on patient fees, and if your practice is one that is trending up from 2019, you won’t qualify for the relief even under the more relaxed definition. 

Consider whether you need it to operate your practice at this point before applying.  HHS relief not used according to the requirements must be returned.

When October 5 arrives and we can see the actual application, we hope to be more enlightened! Click here for the full news release.

HHS Reporting Requirements Finally Issued

09/28/2020 9:31:40 AM

HHS reporting requirements were finally issued on September 19, 2020.  The full disclosure is here.  Like we’ve seen with other Covid-19 related laws this year, the disclosure raised as many questions as answers.  This is a summary of what the requirements mean to most dental practices who received HHS relief funds, as we understand them to this point.

Dates

  • Reports must be submitted before 2/15/2021 for the calendar year 2020.
  • If you’ve used all your HHS funds on allowable items (discussed below) during 2020, no further reporting is required.
  • If you haven’t used all funds on allowable items by the end of 2020, you have until 6/30/2021 to do so, with a second report due by 7/31/2021.

Uses

Allowable use of funds is where the questions arise.  The reporting requirements indicate two permitted uses—healthcare related expenses and lost revenue.  Clarification is definitely needed!  Fortunately, they’ve already got it planned…for “sometime” before the reporting deadline.  In other words, who knows when.  But here’s how it appears:

Healthcare Related Expenses

  • Healthcare related expenses will cover the expenditures you made to comply with all the standards of care the pandemic demanded.  These include things like:

Plexiglas partitions                             UV lighting
Air filtering systems                            PPE—but not PPE that was reimbursed by patients or insurance
Suction machines for air particulates                 

But it also includes General and Administrative expenses that allowed you to “maintain healthcare delivery capacity.”  It lists examples such as:

Rent                                                      Insurance 
Nonclinical staff costs                           
Utilities

Again, these can’t include anything that was reimbursed by another source.  So some of your nonclinical staff costs paid with PPP funds, for example, will be tossed out.  But potentially the remainder of these costs for the period of approximately 3/15-12/31/20 will count.  Since these are all items you pay in a normal year, not just a pandemic year, we would expect there to be some limit on these—the amount above what you would normally spend, for instance.  But the guidance doesn’t indicate any limitation.

And that’s good because the second item is going to be surprisingly hard to meet:  lost revenue.

Lost Revenue

  • Lost revenue was originally announced as lost patient fees.  You were mostly closed for at least 6 weeks.  Easy peasy to prove lost patient fees, right?  But the new guidance changed the requirement to lost net income.  And so far, that is not materializing.  It’s true that in most cases total 2020 revenues will be down from 2019.  BUT the trend we’re seeing is that total expenses are even more down.  That makes net income actually higher than the prior year.  Additionally, expenses reimbursed by PPP costs must be excluded from the calculation.  Throwing out those expenses raises net income even higher.  If adjusted net income for 2020 ends up higher than 2019, there will be no lost revenue under this rule. 

Beyond those requirements, the actual reporting is looking as complex as bureaucracy can make it.  You will have to report specific expenses according to HHS rules which don’t line up with normal financial statement accounts.  In addition, you will have to report personnel metrics and patient metrics…and possibly promise your first-born child.  Hopefully, clarification will come soon.

RPC Senate Update on Coronavirus Response

07/30/2020 9:32:01 AM

RPC Senate Update on Coronavirus Response

As part of our membership in the Academy of Dental CPAs, we are in close contact with our friends at the American Dental Association. The latest RPC Senate paper dated July 28, 2020, was shared with us from Megan Mortimer, Congressional Lobbyist for the ADA.  

Full Update HERE

 

 

Forgiveness Applications on Hold

07/30/2020 8:42:56 AM

Forgiveness Applications on Hold Until at least August 10

 

The SBA is not accepting forgiveness applications until August 10, 2020, and this date will be subject to extension if any new legislative amendments to the forgiveness process necessitate changes to the system. Further, final Treasury guidance concerning PPP Forgiveness Applications, which was expected in early July, is now not expected until after related federal legislation is resolved.

PPP Forgiveness Update

07/28/2020 3:12:05 PM

Please see the following update regarding the PPP Forgiveness process from our friends at First Citizens Bank:

Legislative Developments:

There continues to be legislative developments, and a preliminary agreement has been reached on the Phase IV/CARES Act 2.0 Coronavirus package. A few provisions – which are subject to change because negotiations are ongoing – are:

  • The proposal includes a streamlined loan forgiveness process for small loans under $150,000 and an intermediate forgiveness process for loans under $1 million.
  • Loan forgiveness will be expanded to include certain supplier costs, operating expenses, and damage caused by rioting.
  • There will be a more generous PPP calculation for farmers and ranchers based on their 2019 gross income.

SBA Guidance on Forgiveness:

Procedures for Lender Submission of PPP Loan Forgiveness Decisions and SBA Forgiveness Loan Reviews were released Friday afternoon. We are currently reviewing these procedures to understand how they impact our process. The SBA’s PPP Forgiveness Platform is slated to go live and begin accepting Lender submissions on August 10, 2020. However, it was also noted in the guidance that based on the legislative developments above, if any new legislative amendments to the forgiveness process necessitate changes to their system, that this date would be subject to an extension.

As of now, August 10th is the earliest ‘target’ date for the SBA’s platform to go live however it is highly likely to get extended due to additional legislative changes. First Citizens is confident our submission system will be ready whenever the SBA platform does go live.

Several major news outlets have reported some discussions included in the Cares Act 2.0 package regarding the possibility of a second PPP loan for severely impacted businesses however nothing has been finalized as of yet so I don’t have any information on that program at this time.

REPOST: HHS Relief for All Qualifying Dentists

07/20/2020 4:59:51 PM

DEADLINE EXTENDED TO August 3, 2020

New Funds Available – CARES Act Provider Relief Fund Expanded to Include More Dentists/Doctors

As of July 10, 2020, the US Department of Health & Human Services (HHS) released a new Provider Relief Fund for Providers. We have been supplied with General Information and Frequently Asked Questions (FAQs). After a review of this information and collaboration over the weekend with the ADA and members from the ADCPA we believe that dentists, even if they have not billed Medicare/Medicaid/CHIP programs, in the past, may be eligible for this new HHS Stimulus funding. Based on the information we have, right now, we feel that it may be worthwhile for all dentists to initiate the application process to determine if they are eligible for this money. Be aware that the deadline for applying is now August 3, 2020. Details of what we know, now, are below.

  1. On June 10, 2020 HHS released a new stimulus funding and in it, they expanded eligibility to dentists who previously billed Medicaid and State Medicaid (CHIP) programs. Generally speaking, this expanded money to Pediatric dentists and Orthodontists. This money and all other, previous, HHS Stimulus money was all based on healthcare providers having billed Medicare/Medicaid/CHIP programs.

2. On July 10, 2020 the “Dental Distribution FAQs” section of the HHS website was updated. https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/dental-distribution/index.html

a. In this section, HHS seems to state that dentists who have not billed Medicare or Medicaid may be eligible if they are on a “curated list of providers” created by HHS. Their first FAQ states:

i. Many dental providers have already successfully applied for funding under the Medicaid-focused General Distribution. To support payments to dental providers who may not bill Medicare or Medicaid, HHS has developed a curated list of dental practice TINs from third party sources and HHS datasets. Providers with TINs on the curated list must meet other eligibility requirements including operating in good standing and not be excluded from receiving federal payments. As a next step, HHS will work with states and its vendors to authenticate dental providers not on the curated list.

b. Going through the rest of their FAQs, it seems clear that the only way to know if your dental practice is on their list of eligible providers is to start the application process. The fourth FAQ states:

i. When a dental provider applies, the first step of the application process is to validate that their Taxpayer Identification Number (TIN) is on a curated list of known dental providers. HHS will work to validate applicants that are not on that list. If you are concerned you were not on the curated provider list, please ensure you have an active, verifiable dental provider TIN and submit your information to the Provider Relief Fund application portal. You will be notified if you are permitted to continue your application for PRF payment. Any eligible dental providers not on the curated list will undergo additional review and if validated will be permitted to apply for funding.

3. Key items to know before applying for the funds:

a. The money received is taxable income. The ADA is lobbying for this to be non-taxable but we recommend you assume it will be taxable and you will receive a 1099.

b. This is not a loan. You do not pay this money back to the government.

c. The amount of money you receive is 2% of Gross Revenue on the most recently filed tax return.

d. The funds you receive will be made public so if privacy is a concern to you then you may not want to apply for the Relief Funds. Anyone reading the list will be able to estimate your annual Collections. For example, if you Gross $1 million you are eligible for $20,000.

e. If you already received Relief Funds from HHS, you are not eligible for another round of Relief Funds.

f. It appears you will be required to attest to the fact that you have treated patients who either likely had Covid or you know had Covid at time of visit. We have addressed this attest statement in previous blogs. Some believe that any patient you see could likely have Covid and this does not have to be a confirmed case.

g. Currently the conditions of receipt of the funds state that you cannot use the money for the same expenses you used the EIDL and PPP money on and you cannot use it to pay yourself.

h. Before you apply PLEASE READ the terms and conditions to the program found in the below link. https://www.hhs.gov/sites/default/files/terms-and-conditions-medicaid-relief-fund.pdf

4. What you will need if you want to apply:

a. You will need an Optum ID. See link below. If you already have an Optum ID, you can click on “Sign In”. If you do not have already, please click on “Set Up Optum ID” and follow the prompts.

http://cares.linkhealth.com/#/

If you’d like assistance, contact support at 1(855)819-5909 or OptumSupport@optum.com.

b. There are 3 steps to the application process once you have your Optum ID. You cannot move to Step 2: Revenue and Tax Information until you have successfully completed Step 1: TIN verification (verification should come via email, usually within 24-48 hours)

i. Step 1: TIN verification

        1. You will need your organizational NPI number, Legal business name as reported on your tax return and your Taxpayer Identification number (TIN)

ii. Step 2: Revenue and Tax Information

        1. Please follow the instructions as laid out in the below link. These instructions are extremely helpful and will walk you through each “Field” of the application

https://www.hhs.gov/sites/default/files/medicaid-provider-distribution-instructions.pdf

2. You will need:

    1. Most recent business federal tax return filed
    2. First Quarter 2020 Form 941
    3. FTE Worksheet (link provided in the HHS instructions)
    4. Lost revenues due to COVID (please see explanation in HHS instructions)
    5. Total of increased expenses due to COVID
    6. Payer Mix (% of patients that are self-pay, commercial insurer, medicare, etc)
    7. Amount received on your PPP Loan, if applicable
    8. Business bank account information

3. After submitting the application & info, the link will still say “Get Started” in case you need to re-apply due to incorrect information on the initial application. This warning does not mean that your application was not submitted.

iii. Step 3: Attest to Payment and Terms

        1. This step will not be completed until you receive the funds. You will need the check number and the Relief Fund Payment Amount received.

Knowing that they have opened up eligibility to many more dental practices and that previously having billed Medicare/Medicaid now seems to not be a requirement, it seems as though all interested dental practices should start the application process to see if their TIN is on the curated list. Please remember the deadline if you want to apply is August 3, 2020 so you will want to start this application process right away.

We will continue to monitor the Relief Fund, as well as other opportunities, and share the latest news with you.

HHS Relief for All Qualifying Dentists

07/13/2020 4:45:58 PM

New Funds Available – CARES Act Provider Relief Fund Expanded to Include More Dentists

As of July 10, 2020, the US Department of Health & Human Services (HHS) released a new Provider Relief Fund for Providers. We have been supplied with General Information and Frequently Asked Questions (FAQs). After a review of this information and collaboration over the weekend with the ADA and members from the ADCPA we believe that dentists, even if they have not billed Medicare/Medicaid/CHIP programs, in the past, may be eligible for this new HHS Stimulus funding. Based on the information we have, right now, we feel that it may be worthwhile for all dentists to initiate the application process to determine if they are eligible for this money. Be aware that the deadline for applying is now July 24, 2020. Details of what we know, now, are below.

  1. On June 10, 2020 HHS released a new stimulus funding and in it, they expanded eligibility to dentists who previously billed Medicaid and State Medicaid (CHIP) programs. Generally speaking, this expanded money to Pediatric dentists and Orthodontists. This money and all other, previous, HHS Stimulus money was all based on healthcare providers having billed Medicare/Medicaid/CHIP programs.

2. On July 10, 2020 the “Dental Distribution FAQs” section of the HHS website was updated. https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/dental-distribution/index.html

a. In this section, HHS seems to state that dentists who have not billed Medicare or Medicaid may be eligible if they are on a “curated list of providers” created by HHS. Their first FAQ states:

i. Many dental providers have already successfully applied for funding under the Medicaid-focused General Distribution. To support payments to dental providers who may not bill Medicare or Medicaid, HHS has developed a curated list of dental practice TINs from third party sources and HHS datasets. Providers with TINs on the curated list must meet other eligibility requirements including operating in good standing and not be excluded from receiving federal payments. As a next step, HHS will work with states and its vendors to authenticate dental providers not on the curated list.

b. Going through the rest of their FAQs, it seems clear that the only way to know if your dental practice is on their list of eligible providers is to start the application process. The fourth FAQ states:

i. When a dental provider applies, the first step of the application process is to validate that their Taxpayer Identification Number (TIN) is on a curated list of known dental providers. HHS will work to validate applicants that are not on that list. If you are concerned you were not on the curated provider list, please ensure you have an active, verifiable dental provider TIN and submit your information to the Provider Relief Fund application portal. You will be notified if you are permitted to continue your application for PRF payment. Any eligible dental providers not on the curated list will undergo additional review and if validated will be permitted to apply for funding.

3. Key items to know before applying for the funds:

a. The money received is taxable income. The ADA is lobbying for this to be non-taxable but we recommend you assume it will be taxable and you will receive a 1099.

b. This is not a loan. You do not pay this money back to the government.

c. The amount of money you receive is 2% of Gross Revenue on the most recently filed tax return.

d. The funds you receive will be made public so if privacy is a concern to you then you may not want to apply for the Relief Funds. Anyone reading the list will be able to estimate your annual Collections. For example, if you Gross $1 million you are eligible for $20,000.

e. If you already received Relief Funds from HHS, you are not eligible for another round of Relief Funds.

f. It appears you will be required to attest to the fact that you have treated patients who either likely had Covid or you know had Covid at time of visit. We have addressed this attest statement in previous blogs. Some believe that any patient you see could likely have Covid and this does not have to be a confirmed case.

g. Currently the conditions of receipt of the funds state that you cannot use the money for the same expenses you used the EIDL and PPP money on and you cannot use it to pay yourself.

h. Before you apply PLEASE READ the terms and conditions to the program found in the below link. https://www.hhs.gov/sites/default/files/terms-and-conditions-medicaid-relief-fund.pdf

4. What you will need if you want to apply:

a. You will need an Optum ID. See link below. If you already have an Optum ID, you can click on “Sign In”. If you do not have already, please click on “Set Up Optum ID” and follow the prompts.

http://cares.linkhealth.com/#/

If you’d like assistance, contact support at 1(855)819-5909 or OptumSupport@optum.com.

b. There are 3 steps to the application process once you have your Optum ID. You cannot move to Step 2: Revenue and Tax Information until you have successfully completed Step 1: TIN verification (verification should come via email, usually within 24-48 hours)

i. Step 1: TIN verification

        1. You will need your organizational NPI number, Legal business name as reported on your tax return and your Taxpayer Identification number (TIN)

ii. Step 2: Revenue and Tax Information

        1. Please follow the instructions as laid out in the below link. These instructions are extremely helpful and will walk you through each “Field” of the application

https://www.hhs.gov/sites/default/files/medicaid-provider-distribution-instructions.pdf

2. You will need:

    1. Most recent business federal tax return filed
    2. First Quarter 2020 Form 941
    3. FTE Worksheet (link provided in the HHS instructions)
    4. Lost revenues due to COVID (please see explanation in HHS instructions)
    5. Total of increased expenses due to COVID
    6. Payer Mix (% of patients that are self-pay, commercial insurer, medicare, etc)
    7. Amount received on your PPP Loan, if applicable
    8. Business bank account information

3. After submitting the application & info, the link will still say “Get Started” in case you need to re-apply due to incorrect information on the initial application. This warning does not mean that your application was not submitted.

iii. Step 3: Attest to Payment and Terms

        1. This step will not be completed until you receive the funds. You will need the check number and the Relief Fund Payment Amount received.

Knowing that they have opened up eligibility to many more dental practices and that previously having billed Medicare/Medicaid now seems to not be a requirement, it seems as though all interested dental practices should start the application process to see if their TIN is on the curated list. Please remember the deadline if you want to apply is July 24th so you will want to start this application process right away.

We will continue to monitor the Relief Fund, as well as other opportunities, and share the latest news with you.