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COVID-19 Practice Financial Assistance
Last updated 4/21/2021
Practice Re-opening Resources
- ACP’s Clinician’s Guide includes some resources to help guide practices in plans for re-opening. Resources include guides, checklists, staffing and workflow modifications, and materials for communicating with patients.
- The CDC offers a framework for providing non-COVID-19 care during the pandemic.
- ACP offers clinical and public policy guidance on how to resume some economic, social and medical care activities to mitigate COVID-19 and allow expansion of healthcare capacity.
Provider Relief Fund Payments
Provider Relief Fund payments were intended to provide funds to hospitals, physicians, and other healthcare entities to cover COVID-related expenses and revenue losses. These are payments, not loans, so recipients do not need to pay them back, but there are reporting requirements and other restrictions. There have been several distributions of general allocation payments, plus one for Medicaid and CHIP providers, and several “targeted” allocations. For general information about the CARES Act Proeach distribution, click here.
- These FAQs offer clarification on various aspects of the PRF program.
- Each distribution has terms and conditions
- The IRS provided clarification that Provider Relief Fund payments are considered taxable income.
- Recipients of Provider Relief Funds (all distributions) will be required to submit detailed reports
- You must register through the Reporting Portal in order to report.
- This fact sheet provides summary and timeline of reporting requirements.
- This guidance provides more detailed reporting requirements for entities that received $10,000 or more, including general and COVID-related expenses and income loss.
- Key dates:
- January 15, 2021 – Reporting portal opens
- Feb 15, 2021 – First reporting deadline for all providers on use of funds
- July 31, 2021 – Final reporting deadline for providers who did not fully expend PRF funds prior to 12/31/2020.
- Regardless of which payments you have received, it is important to keep detailed records (receipts, payments, etc) of how you spend the money. You must retain the records for 3 yrs from the date of receipt.
- To request reimbursement for COVID-19 Testing and Treatment, go to the COVID-19 Uninsured Program Portal.
- To obtain reimbursement for COVID-19 Testing and Treatment for uninsured patients go here.
- The program is being administered by UnitedHealth Group through a contract with DHHS Health Resources and Services Administration (HRSA). You must sign up for Optum Pay Direct Deposit/ACH in order to be reimbursed.
- Only one individual per TIN can serve as program administrator. This is the person who will submit the provider roster (via Excel template) and patients (individually or as a batch file upload).
- Reimbursement is based on current year Medicare fee schedule rates. (However, vaccine administration is reimbursed based on date.)
- For more details regarding eligibility and payment, see the FAQs.
- To obtain reimbursement for COVID-19 Testing and Treatment for uninsured patients go here.
Small Business Administration Programs
The US Small Business Association was put in charge of several COVID-19 relief programs, including the Paycheck Protection Program (PPP) and the Economic Injury Disaster Loan (EIDL) emergency advance, which offer low-interest loans to small businesses to cover payroll, benefits, rent, mortgage, utilities, and other business expenses.
- The current tranche of PPP funding is set to expire March 31 and President Biden signed a bill on 3/25/2021 extending the PPP application deadline to May 31, 2021. (And the bill also gives the SBA an extra 30 days beyond May 31 to process those applications.) If there are further extensions, come back here to check.
- The COVID omnibus relief act (HR 133) passed on December 21, 2020, includes new flexibilities, additional eligible expenses, a simplified application process for PPP loans as well as additional EIDL grants to businesses in low-income communities. To know what is included in HR 133, see ACP’s summary here.
- The Paycheck Protection Program Flexibility Act of 2020 became law on June 5, 2020. The legislation lowers the amount required to be spent on payroll costs from 75% to 60%. It also extends the “covered period” to 24 weeks (through Dec. 31), allows PPP borrowers to defer payroll tax payments, establishes 5 years as the minimum maturity term for the balance remaining after forgiveness, and provides greater flexibility to rehire employees that would otherwise reduce the amount forgiven. Specifically, this law:
- Establishes a minimum maturity of five years for a paycheck protection loan with a remaining balance after forgiveness.
- Extends the covered period during which a loan recipient may use such funds for certain expenses while remaining eligible for forgiveness.
- Raises the non-payroll portion of a forgivable covered loan amount from the current 25% up to 40% (and lowers the payroll portion from 75% to 60%).
- Extends the period in which an employer may rehire or eliminate a reduction in employment, salary, or wages that would otherwise reduce the forgivable amount of a paycheck protection loan. However, the forgivable amount must be determined without regard to a reduction in the number of employees if the recipient is (1) unable to rehire former employees and is unable to to hire similarly qualified employees, or (2) unable to return to the same level of business activity due to compliance with federal requirements or guidance related to COVID-19.
- Revises the deferral period for paycheck protection loans, allowing recipients to defer payments until they receive compensation for forgiven amounts. Recipients who do not apply for forgiveness shall have 10 months from the program's expiration to begin making payments.
- Eliminates a provision that makes a PPP loan recipient who has such indebtedness forgiven ineligible to defer payroll tax payments.
- Loan Forgiveness: Loan recipients may be eligible for loan forgiveness. For information about what information you need to provide and how to apply, go here.
- These FAQs from the Department of Treasury provide a lot of guidance and clarification on the PPP loan program.
- EIDL applicants who have already submitted their applications will continue to be processed on a first-come, first-served basis.
- These FAQs provide clarification about the difference between PPP loans and EIDL loans and what they can be used for. (Yes, you can get both but the funds must be used for different things.)
Medicare’s Accelerated and Advance Payment Program
The COVID-19 Accelerated and Advance Payment (CAAP) Program was intended to provide advance payments during the disruption of claims submission and processing during the shutdowns early in the PHE. A summary of the repayment terms are as follows:
- The deadline to begin repaying the loan is 365 days from receipt of the payment. (The balance would be due no later than September 2022.)
- The per-claim recoupment amount will be 25% for the first 11 months, and then 50% of claims withheld for an additional six months.
- If not repaid in full, the interest rate will be 4%.
- Clinicians will have 29 months to fully repay the loan.
Tax and Other Benefits
There are some tax benefits available to employers, including medical practices, designed to keep employees on the payroll. [Note: It is important to talk to your accountant or financial advisor about the different programs, as some do interact with or are contraindicated with the above PPP loans.]
- Employee Retention Credit - The Employee Retention Credit (ERC) is a fully refundable tax credit for employers equal to 50% of qualified wages (including allocable qualified health plan expenses) that Eligible Employers pay their employees. The American Rescue Plan Act (enacted March 11, 2021) extended the credit for the 3rd and 4th quarters of 2021.
- To qualify, there must have been a 50% decline in gross receipts (2020 compared to the same time period in 2019) and there had to have been a full or partial shutdown due to a governmental order. Thus most physician practices will qualify if their state shut down for any period of time in 2020.
- The Consolidated Appropriations Act of December 2020 eliminated the ban on ERC if the practice also received a PPP loan (as long as the PPP wages are excluded).
- However, you cannot “double dip” thus wages used for PPP loan forgiveness or wages reimbursed with FFCRA qualified sick/family leave reimbursement provisions. (Note: PPP had limitations where as ERC does not, thus ERC can be used for what PPP didn’t cover.)
- Qualified practices can request up to $5,000 per employee per year
- This is a retroactive refund opportunity. Employers can retroactively claim the 2020 ERC on Form 941-X for the relevant 2020 quarters.
- These and these IRS FAQs will be updated to reflect the recent changes. Your accountant should be up-to-date on changes to the regulations.
- 2021 ERC offers additional credits available but with slightly more complex eligibility rules (20% reduction in gross receipts and includes new employees, etc.). The credit amount for 2021 is up to $7,000/employee/quarter, including qualified health plan expenses.
- It is critical that you work with a qualified accountant. This information is provided to give you an overview.
- Payroll tax deferral - Allows employers to defer the deposit and payment of the employer's share of social security taxes and self-employed individuals to defer payment of certain self-employment taxes. This is now allowed based on the PPP Flexibilities Act (passed 6/5/2020).
- The CARES Act also includes provisions related to student loans. Under the law, no federal student loans are required between March 13 and September 30, 2020, and interest will drop to zero during that time period. In addition, employers can pay up to $5,250 toward an employee’s student loans tax-free through the end of the year. Normally, these payments are treated as wages, but until December 31, 2020, these payments can be excluded from income and payroll taxes – benefitting both the employer and those receiving the repayment assistance.
- COVID-19 Telehealth Program – The Consolidated Appropriations Act of 2021 included $250 million to re-fund an FCC reimbursement program. Physicians may submit an invoice and supporting documentation to receive reimbursement for eligible telemedicine and mobile health expenses and services.
- FCC will accept applications for the second round beginning Thursday, April 29, 2021 at 12:00pm, ET, and will close the following week on Thursday, May 6, 2021, at 12:00pm, ET.
- Examples of eligible expenses: Internet connectivity for providers or their patients; remote patient monitoring platforms; patient reported outcome platforms; store and forward services; platforms and services to provide video consultations; tablets, smart phones, or connected devices (such as broadband-enabled blood pressure or pulse oximetry monitors), or telemedicine kiosks/carts for healthcare provider sites. Note: personnel expenses (including IT staff or training) are not eligible.
- Costs of upgrades of existing services needed to respond to COVID-19 may be considered.
- This is a reimbursement program for expenses paid on or after March 13, 2020.
- Special attention will be paid to the hardest hit, low income areas, and those located in physician shortage areas and Tribal communities.
- Priority will also be given to applicants who were previously denied. New applications will be needed to re-submit those previously denied requests.
- Applications will be reviewed all at once and distributed in 2 phases. Approved projects will be funded quickly and the rest will have an opportunity to provide more information to qualify for the 2nd phase.
- More details can be found in these FAQs.