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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 or 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 or 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.

We’ve been busy!

07/09/2020 06:00:00 AM

Have you been missing us? No worries, we’re still here and we’ve been busy! Not only are we preparing mountains of tax returns while still keeping up with all things related to Covid-19, we’ve been participating in conversations about reopening dental practices and practice management in general. Check out the latest blog brought to you by our friends at Surety Dental Solutions, written by our favorite practice management consultant, Dr. Sharon Tiger. Also listen to the latest edition of The Art of Dental Finance Podcast with Art Wiederman featuring both Sharon and Robert. You won’t be sorry you tuned in! 

When to File PPP Forgiveness Applications

06/24/2020 3:40:04 PM

We finally received a TINY bit of guidance on the PPP loans and when to file PPP forgiveness applications. 

It’s true! The details are below. BUT we are not recommending you be in any big hurry to file for forgiveness. Why?

  • We do NOT recommend using the 8-week covered period because of the complex application process. Only if you have extenuating circumstances would we recommend this path. For instance, if you are planning to sell your practice and need forgiveness first, or you know your FTE count will be too low at the later 24-week date, then this might be recommended. 
  • We are still HOPEFUL there will be blanket forgiveness for PPP loans under $150K. This would negate the application process entirely for many recipients. It could be wishful thinking certainly. Nonetheless, why spend energy on something that may turn out to be unnecessary?  

With that said, here are the updates…

Recent guidance released by the Treasury Department has clarified when PPP borrowers can apply for forgiveness.

Here are some scenarios:

  1. Submit your forgiveness application before the Covered Period ends.
    • If there are Salary/FTE reductions, you must account for those reductions for the full 8 or 24-week period. Borrowers are not allowed to prorate reductions when applying before the Covered Period ends.
    • The forgiveness amount requested must be spent or incurred in the period stated on the application. For instance, a borrower applying 2 weeks before the Covered Period ends cannot include anticipated costs for the remaining 2 weeks.
  2. Submit your forgiveness application as soon as the Covered Period ends. 
    • This option is ideal for borrowers who didn’t reduce wages or FTE during the Covered Period, and who don’t need to wait for the Safe Harbor date.
  3. Submit your forgiveness application within 10 months after the Covered Period ends.
    • This option gives borrowers a chance to restore wage and FTE amounts by 12/31/2020, thus limiting forgiveness reductions.
  4. Submit your forgiveness application after the 10-month deferral period.
    • If borrowers do not apply for forgiveness within 10 months after the Covered Period ends, payments on principal and interest will begin.
    • Even if payments have been made after the deferral period, borrowers can still apply for forgiveness before the loan matures.
  •  

Apply for HHS Provider Relief Now

06/24/2020 9:31:56 AM

The HHS Medicaid/CHIP Provider Relief Fund application deadline is a little less than a month away. But it’s vitally important to start the application process sooner rather than later! 

The first step in applying for payment is registering an account through the HHS Provider Relief Fund Portal. Once you create the account, you will have to provide necessary nonfinancial information to HHS to validate eligibility for the Fund. Validation can take up to 15 days per HHS, so starting soon is important. Submit validations no later than by July 5 to meet the July 20 deadline. 

Once validated, you will provide HHS the practice’s financial information needed to calculate your relief payment amount. After payment is received from the Fund, you will have 90 days to accept the payment by attesting to Terms and Conditions.

HHS Application Due 7/20/2020

06/19/2020 10:09:20 AM

Just a reminder!  If you are a Medicaid/CHIP provider, you should apply for the Relief Fund payment authorized by the CARES Act.  As we posted previously, round one of the distribution went primarily to physicians and hospitals, but it has now been opened up to dental providers.  PLEASE NOTE: Our original post, now revised, listed the due date for application as 7/3/2020, but the due date is actually 7/20/2020.  So you have more time! We don’t know if there was a change, or the 7/3 date was in error, BUT THE CORRECT DUE DATE IS 7/20/2020.

PPP Tracker Spreadsheet Updated

06/18/2020  7:20:31 PM

We have updated the PPP tracker spreadsheet, find it HERE. As a reminder, the revised PPP rules allow for a 24-week period versus the original 8-week period. The goal now is to use PPP funds exclusively on payroll over the 24 weeks.  This will allow for the easiest forgiveness application process!

Not Too Late for a PPP Loan

06/16/2020 2:02:38 PM

It’s not too late for a PPP loan, here’s why. As you may recall, the PPP program was modified from an 8-week covered period to a 24-week period covered period.  This change makes it very easy to use all PPP proceeds on payroll over a 24-week period and achieve 100% forgiveness of the loan.  It will require very little documentation and a relatively easy application process.  For these reasons, if you have not applied for a PPP loan yet, consider doing so now! The deadline for application is June 30, 2020.  There is currently over $1 billion still available in the SBA PPP fund.

COVID Positive Team Member: Steps to take

06/12/2020 9:40:06 AM

Practices are re-opening and getting used to new recommended and required safety precautions.  It’s a good time to think about this scenario—when a team member tests positive for COVID-19.  There are procedures in place to prevent potentially sick employees from coming to work or beginning a shift.  But there still exists the unfortunate possibility of an infected team member encountering patients.  The TDA and ADA have released guidelines in the event this happens in your practice.

A summary of steps to take:

  1. Mandate the infected employee quarantine for 14 days and follows all medical recommendations.
  2. Notify all patients who may have had close contact with the infected employee.
    • Recommend a 14-day self-quarantine and that they contact their physician if they experience symptoms.
    • “Close contact” is defined as 6 feet or less.
    • The CDC has provided a sample letter here.
    • Document your communication with the patient.
  3. Notify staff who were working with the infected employee.  Recommend a 14-day self-quarantine for any staff member who may have come into close contact with the infected employee.
  4. Clean and disinfect the facility according to CDC guidelines for Dental Practices.

Click here for an expanded 8-step guide from the ADA.

For more information, this TDA page explains how to handle a team member testing positive for COVID-19.  It includes protocols, helpful resources, and a script for communicating with patients.

Medicaid Dental Provider Relief

06/11/2020 6:50:08 PM

Yesterday the Department of Health and Human Services (HHS) announced that qualifying dentists are now eligible to receive payments under the Medicaid Provider Relief Fund authorized in April by the CARES Act.  This money is not a loan and will not have to be repaid.

Click here for eligibility requirements

You will need to submit these 3 items:

  1. Most recent federal income tax return for 2017, 2018 or 2019.
  2. Payroll tax return—one of the following
    1. Form 941 for Q1 2020
    2. Form 940 [we assume for 2019 but their site fails to specify] OR
    3. A statement explaining why the applicant is not required to submit either form (e.g. no employees).
  3. FTE Worksheet.

Additionally, you may need to submit:

  1. If required by Field 15, a Gross Revenue Worksheet . NOTE:  If you did not acquire or dispose of any subsidiaries between the beginning of your tax return date (based on #1 above) and now, this will not apply to you.  It will, frankly, not apply to most of you.

If you are eligible, submit your application as soon as possible.  The deadline for submission is July 20, 2020.

Access the portal here.

Access the application here.

Access the instructions here.

Access general information here.

Access FAQs here.

Production Survey Part 2

06/11/2020 12:00:28 PM

After reviewing the results of our 6/8/2020 survey, we were pleased and surprised to hear so many of you are back at 100% pre-COVID production levels!  BUT HOW are you accomplishing this?  With all the extra time to comfort patients and sterilize ops we feared production could not reach pre-COVID levels.  But we are thrilled to see the potential full recovery can be achieved for the dental community.  If you would give us just 2 more minutes of your time we would love to dive deeper.

TAKE THE SURVEY

Paying COVID Employees

06/10/2020 2:35:06 PM

A few of you have contacted us with employees who either have COVID, or have been exposed to COVID and are unable to work. Paying COVID employees involves following unique rules. Under the H.R.6201 – Families First Coronavirus Response Act, they are entitled to 10 days of federally mandated and subsidized Sick Pay.  

Here’s how paying COVID employees works:

  1. Pay them their normal hourly rate up to a maximum of $511 per day.
  2. Pay them for the hours they would be working according to the amount the practice is currently open.  For instance, if they previously worked 30 hours per week and the practice is now open only 20 hours per week, you must pay them 20 hours per week for 2 weeks.  If the practice is open as much as pre-COVID, pay them for their their normal working hours up to 40 hours per week.
  3. If you use a payroll provider (always recommended) be sure to enter this as Emergency Paid Sick Leave (or something to that affect—your payroll provider can help you identify the correct coding if needed).  Correct coding is important in this case.
  4. You are entitled to a credit for the total sick wages paid against your payroll tax deposits.  Example: If the employee is paid $2500 for the 10 days, you can short your payroll tax deposits for the remainder of 2nd quarter until you have recouped your $2500.  Your payroll provider may do this for you automatically.  If not, there is a form that can be filed to receive the refund back from the IRS for the amount of credit you are due.  In addition to wages paid, the credit should include any health insurance premiums the practice pays on their behalf.  (Note: Insurance deducted from the employees’ pay is not includable in the credit.) 
  5. No specific paperwork needs to be filed with any government agency to track this.

Production Survey Results

06/10/2020 10:28:10 AM

Our practice production survey results are coming in. So far things look promising. 30 days following reopening their practices, most respondents are reporting production levels at 70% and higher of pre-COVID production levels. We know 2020 will go down in history as a very tough year for small business owners, including dentists. However, maybe things aren’t as bad as they once seemed and maybe, just maybe, we can turn 2020 around before the end of the year. If you haven’t taken the survey, please take a minute and tell us about your practice.

SURVEY RESULTS

TAKE THE SURVEY