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COVID-19 Practice Financial Assistance

Last updated 9/30/2021

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 and each distribution, click here.

  • These FAQs offer clarification on various aspects of the PRF program.
  • For more details on reporting requirements, including how to calculate revenues and losses, see the complete PRF and ARP Rural Payment FAQs here.
  • Each distribution has terms and conditions
  • The IRS provided clarification that Provider Relief Fund payments are considered taxable income. 
  • The Post-Payment Notice of Reporting Requirements issued June 11, 2021, can be found here.
  • Recipients of Provider Relief Funds (all distributions) are required to submit detailed reports

Summary of Reporting Requirements

 

Payment Received Period (Payments Exceeding $10,000 in Aggregate Received)

Deadline to Use Funds

Reporting Time Period

Period 1

From April 10, 2020 to June 30, 2020

June 30, 2021

July 1 to September 30, 2021*

Period 2

From July 1, 2020 to December 31, 2020

December 31, 2021

January 1 to March 31, 2022

Period 3

From January 1, 2021 to June 30, 2021

June 30, 2022

July 1 to September 30, 2022

Period 4

From July 1, 2021 to December 31, 2021

December 31, 2022

January 1 to March 31, 2023

* A 60-day grace period (until Nov 30) will allow physicians extra time to report before collection activities or enforcement begin

 

  • On September 10, 2021, HHS, through the Health Resources and Services Administration (HRSA), announced new funding for health care providers affected by the COVID-19 pandemic. This funding comes from the American Rescue Plan (ARP) for providers who serve rural Medicaid, Children’s Health Insurance Program (CHIP), or Medicare patients, and from the Provider Relief Fund (PRF) Phase 4 for a broad range of providers who can document revenue loss and expenses associated with the pandemic. The application will open on September 29, 2021. In an effort to streamline the application process and minimize administrative burdens, providers apply for both programs in a single application and HRSA will use existing Medicaid/CHIP and Medicare claims data in calculating portions of these payments.
    • Phase 4 General Distribution — Based on lost revenues and changes in operating expenses from July 1, 2020 to March 31, 2021.
      • To promote equity and to support providers with the most need, HRSA will reimburse a higher percentage of lost revenues and expenses for smaller providers as compared to larger providers.
      • "Bonus" payments will be based on the amount of services provided to Medicaid, CHIP, and Medicare patients, priced at Medicare rates.
    • American Rescue Plan (ARP) Rural — Based on the amount of services providers furnish to Medicaid/CHIP and Medicare beneficiaries living in rural areas (as defined by the Federal Office of Rural Health Policy (FORHP).
      • To promote equity, HRSA will pay at Medicare rates for Medicaid/CHIP patients.
    • For more details go here.
  • You must register through the HRSA Reporting Portal in order to report.
    • This guidance provides more detailed reporting requirements for entities that received $10,000 or more, including general and COVID-related expenses and income loss.
  • To request reimbursement for COVID-19 Testing and Treatment, go to the COVID-19 Uninsured Program Portal.
    • 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.
  • 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.

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.  

  • On July 29, the Small Business Administration (SBA) is revising the forgiveness process for the Paycheck Protection Program (PPP) for borrowers with loans <$150,000.  Because the SBA has been overwhelmed with loan forgiveness applications, lenders have limited when applications are accepted, which creates uncertainty among borrowers that need to begin making principal and interest payments while waiting for a decision from their lender.  SBA will be issuing guidance, but the following summarizes the rule:
    • COVID Revenue Reduction Score – In lieu of documentation, lenders can apply a score based on a variety of inputs, including industry, geography, and business size, and uses current data on economic recovery and return of businesses to operational status.  Both lenders and borrowers will be able to see the score in the forgiveness application platform and applicants can use the score to meet the requirement or submit documentation directly to the lender.
    • Direct Borrower Forgiveness Process – This is an optional technology solution that lenders can use to integrate the streamlined forgiveness application.  Lenders can opt-in and borrowers will be able to view a list of participating lenders and submit their loan forgiveness application through the SBA system or directly with their lender.  The intent is to make it easier for lenders to process the applications before borrowers have to begin making payments.  Borrowers who have already submitted an application will not need to re-submit.
    • Deferment extension for appeals – If a borrower submitted a timely appeal, this rule extends the deferment period for the PPP loan until the SBA’s Office Hearings and Appeals issues a final decision.
  • The current tranche of PPP funding was set to expire March 31, but President Biden signed a bill on 3/25/2021 extending the PPP application deadline to May 31, 2021. (The bill also gave the SBA an extra 30 days beyond May 31 to process those applications.)  However, as of May 4, the program had run out of money and no new applications were being accepted.
  • 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.

For those who received payments through this program, this fact sheet and these FAQs provide more information regarding payback terms.

Tax 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. For more information, see How to Claim the ERC FAQs
    • 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 (3/12/2020-12/31/2020) and these (1/1/2021-6/30/2021) IRS FAQs reflect the most 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.  

Other Benefit Programs

  • COVID-19 Telehealth Program – The Consolidated Appropriations Act of 2021 included $250 million to re-fund an FCC reimbursement program. Non-profit and public health clinics (both rural and non-rural) and other providers were invited to submit invoices and supporting documentation to receive reimbursement for eligible telemedicine and mobile health expenses and services. Unfortunately small independent practices were denied, however ACP did advocate for expansion of the benefit to small independent practices.
    • FCC accepted applications for the second round from April 29 through May 6, 2021. Applications are now closed.
    • More details can be found in these FAQs.
  • The American Rescue Plan Act included 2 provisions that will benefit your patients who are struggling financially:
    • FEMA is providing financial assistance to families who lost loved ones due to COVID-19. Individuals can apply for up to $9,000 with proper documentation, such as the death certificate and proof of funeral expenses incurred. For more information on how to apply, go here.
    • COBRA premiums will be covered 100% for eligible patients between April 1 and September 30, 2021. During this time, employers pay premiums in full, and will receive quarterly payroll tax credits to offset the cost of the COBRA coverage. For more information, see these FAQs. For more information for physicians as employers, including sample notices, go here.
  • A new HHS COVID-19 Coverage Assistance Fund (CAF) will cover the costs of administering COVID-19 vaccines to underinsured patients with health plans who either do not cover vaccine administration fees, or require cost-sharing. Physician practices can submit claims for reimbursement consideration after the patient’s insurance has denied or only partially paid for the administration of the vaccine.  Click here for more information.