Month: June 2020

Schiff Client Update June 24, 2020 3:30 PM

PPP – Paycheck Protection Program Flexibility Act of 2020

On June 5, 2020, the “Flexibility” Act was signed into law. As a result, the covered period has been extended from 8 weeks to 24 weeks. In addition, the Payroll Costs have been reduced from 75% to 60% in order to gain maximum PPP Loan Forgiveness. As a result of the 24 week period, we are encouraging all clients to use the 24 week period as opposed to the 8 week period. Also, you should be able to obtain maximum PPP Loan Forgiveness just accounting for the payroll costs during this new and extended period.

PPE Tax Credits & PPE Equipment & Supplies

The ADA is working hard and encouraging Congress to allow Dental Practices to obtain a “tax credit” up to $25,000 for the cost of PPE. It is my understanding at this time, it will be a dollar for dollar credit. In other words, if you spend $1,000 on PPE, and if this Tax Bill is passed, you will receive a Tax Credit in the amount of $1,000. Speaking of PPE, if you are in need of PPE, please click here>>> https://www.crazydentalprices.com/schiff/    In order to use your Schiff coupon, please place “Schiff10” in the coupon section of your order.

Retention Tax Credit (RTC)

There is a possibility, Congress will revisit this Tax Credit (RTC) in the near future and allow you to take the “Tax Credit, even though you received a PPP Loan. This would be amazing! Why? Because the requirements for the Tax Credit are, your business would have to have suffered a loss, calculated by measuring the 2nd Quarter of 2019 vs. the 2nd Quarter of 2020 Collections. If your collections are down by 50% or more, you would qualify for this tax credit. For example,  Let’s assume you collected $100,000 per month for the months of April 2019, May 2019 and June of 2019 or $300,000 and you compare that to April 2020, May 2020 and June 2020 (Q2 2020) at $150,000 or less, you would qualify for the RTC. If so, the credit will be increased from 50% of the 1st $10,000 in wages per employee to 80%  of such wages, for wages paid during Q2 of 2020. So, as of now, if you received a PPP Loan, you do not qualify for the RTC. However, this could change in the future….please stay tuned!  :>)

Maryland Unemployment Update – You may have this question!

Question – As I understand it, the maximum weekly unemployment benefit for Maryland is $430.00 plus the Federal stimulus of $600.00 a week  Based on the formula, how much can an employee in Maryland earn on a weekly basis without impacting the above?

Answer – The amount a claimant can earn each week depends on a few things. The claimant must be working less than 35 hours per week and earning less than the Regular UI benefit amount.  For instance, if a claimant is eligible for $400 in Regular UI per week, is working 30 hours per week and earned $350 that week, they would still be eligible to receive a partial unemployment check along with the additional $600 in federal stimulus.  However, if the claimant earns more than their Regular UI weekly benefit amount, regardless of the number of hours worked, they are not eligible.  If they are working 35+ hours per week, regardless of their wages earned, they are not eligible.

EIDL Loan Update

As of the date of this writing, please hold onto your EIDL Loan. We will assess the situation this coming Fall. At that time, we will determine if we are going to payoff the EIDL Loan. Borrowers can obtain their EIDL loan payoff information by contacting the SBA Disaster Loan Servicing Center at (800) 736-6048.

Family First Coronavirus Response Act (FFCRA). 

Now that offices are starting to open, I wanted to provide additional guidance on the Family First Coronavirus Response Act (FFCRA).  The ADA lobbied and was successful with the under 50 employee limit. So, if your practice has less than 50 employees, you are exempt from providing the additional 10 weeks of FMLA leave.

However, under FFCRA, employers with under 50 employees are still required to provide their employees with paid sick leave for specified reasons related to COVID-19. This rule will impact most dental practices.

Paid Sick Leave

This leave is available to employees from the time you reopen the office.  The employees did not qualify for leave during the closure of your office due to Covid-19. The Act provides that covered employers must provide the following to all employees:

  • Two weeks (up to 80 hours) of paid sick leave at the employee’s regular rate of pay where the employee is unable to work because the employee is quarantined (pursuant to Federal, State, or local government order or advice of a health care provider), and/or experiencing COVID-19 symptoms and seeking a medical diagnosis; or
  • Two weeks (up to 80 hours) of paid sick leave at two-thirds (2/3) the employee’s regular rate of pay because the employee is unable to work because of a bona fide need to care for an individual subject to quarantine (pursuant to Federal, State, or local government order or advice of a health care provider), or care for a child (under 18 years of age) whose school or child care provider is closed or unavailable for reasons related to COVID-19, and/or the employee is experiencing a substantially similar condition as specified by the Secretary of Health and Human Services, in consultation with the Secretaries of the Treasury and Labor.

While full-time employees may receive up to 80 hours of paid sick leave (if they work 40 hours per week), part-time employees are entitled to a pro-rata number of hours based on hours worked over two workweeks. If, for example, a part-time employee works 15 hours per week, this team member would be eligible for up to 30 hours of paid sick leave.

Qualifying Reasons for Leave for paid sick time:

Here are the qualifying reasons for paid sick leave. Under the FFCRA, an employee qualifies for paid sick time if the employee is unable to work (or unable to telework) due to a need for leave because the employee:

  1. is subject to a Federal, State, or local quarantine or isolation order related to COVID-19;
  2. has been advised by a health care provider to self-quarantine related to COVID-19;
  3. is experiencing COVID-19 symptoms and is seeking a medical diagnosis;
  4. is caring for an individual subject to an order described in (1) or self-quarantine as described in (2);
  5. is caring for a child whose school or place of care is closed (or child care provider is unavailable) for reasons related to COVID-19.

There are dollar limits on how much can be paid for sick leave.  For reasons 1, 2, and 3 (above), the daily rate of pay is capped at $511. The two-week cap is $5,111 (10 days).  For reasons 4 and 5 (above), the daily cap is $200, and the total cap for the two-week period of leave is $2,000 (10 days). If, for example, you have a full-time employee who is unable to work because she is caring for a child due to a COVID-related daycare closure (reason 5), he/she is eligible for paid sick leave of up to $200 per day and $2,000 over the two-week period.

Can an Employee Take Intermittent Leave?

The Act does not permit intermittent leave unless there is a written agreement between the employer and employee. Intermittent leave can only be used for childcare (reason #5 above).  For example, you may have an employee who can return to work, but she can only work reduced hours because childcare is unavailable for reasons related to COVID-19. If the employer and employee have a written agreement that permits intermittent leave for this situation, the employee can receive paid sick leave for the missed hours of work.

What to Do When an Employee Requests Leave

If you have an employee request leave under FFCRA, we recommend you have them fill out a “leave form” located here >https://mcusercontent.com/0cd89d595f6ac2e6699fc9924/files/7d5b7b14-6002-4c7f-9ead-fc601c3c4f36/FFRCA_Leave_Request_Form.pdf

Payroll Tax Credits Offset the Cost

Covered employers qualify for dollar-for-dollar reimbursement through payroll tax credits for all qualifying wages paid under FFCRA. Qualifying wages are those paid to an employee who takes leave under the Act for a qualifying reason, up to the appropriate per diem and aggregate payment caps mentioned previously. Applicable tax credits also extend to amounts paid or incurred to maintain health insurance coverage. When reporting payroll to your payroll provider (ADP Payroll Services), please make sure to specify hours for FFCRA so they have that information for the tax credit.

Also, if you have not already done so, you should post a notice in your office regarding FFCRA. Here is the notice >https://mcusercontent.com/0cd89d595f6ac2e6699fc9924/files/78143208-5f6b-4084-909e-5f5d7e83ae60/FFCRA_Poster_WH1422_Non_Federal.01.pdf

Finally, this is my understanding of the Family First Coronavirus Response Act (FFCRA). I would suggest you consult with an HR Attorney for further guidance. If you need a referral for an HR Attorney, please e-mail us.

Towson MD Dental CPA | Manage Your Calendar to Balance Your Life

Appointments and continuing education consume most of your time. How do you manage to live a happy, well-adjusted, balanced life when you simply don’t have time? The key is in planning. Do you use a calendar to manage your time or do you simply make agreements and arrangements as they come up? Here is how you can balance your schedule by managing your calendar.

Schiff Dental CPA | Manage Your Calendar to Balance Your Life

Set Clear Boundaries

The first step to achieving a work-life balance is to consider your basic responsibilities and obligations. Set aside blocks of time in your calendar to meet with patients, hold team meetings, and attend organizational group meetings. Your calendar should be your primary time-management tool.

Time Off Means Time Off

You need to set aside time for activities unrelated to work. When you decide to take a day off, make sure it’s in your calendar. If it’s not in there, your time off is likely to be consumed by an emergency patient appointment, unexpected meeting, or other business-related expense. Make your scheduling priorities clear with your office team so they are not left with the burden of how to handle unexpected situations while you are away.

It’s Not Just for Work

Your calendar doesn’t need to be exclusive to work. In fact, it may be beneficial for you to regularly include your other commitments. From your children’s school activities to anniversaries and birthdays, seeing these events alongside your work schedule can help you make better scheduling choices. You’ll be more reluctant to accept an invitation to a meeting or convention when you know it will conflict with another occasion. By including other events on your calendar, you minimize the risk of dealing with a stressful schedule conflict between your work life and your personal life.

Never let your calendar run your day. You have the ability to schedule your day by using your calendar as a tool for time management. Start by setting clear scheduling boundaries by blocking the time you need for your main responsibilities. Don’t be afraid to take time off, but always make sure it is a part of your schedule.  Also, consider including other life events and activities in your calendar to better manage your schedule.

For more tips on effectively managing your work schedule, contact our team today.

Towson MD Dental CPA | Opportunity Called – Did You Answer?

The first step to growing your practice is attracting new patients. Your website, social media, and marketing are all geared toward the idea of getting people to call your office. To help convert this interest into new patient appointments, you have probably spent time selecting and training the team members who answer the phones during office hours. But have you considered what happens when a prospective patient calls when the practice is closed?

Towson MD Dental CPA

If a person calls your office for information about a service or comparison shopping, they may decide to call back within your business hours. Chances are, they were not ready to schedule an appointment at the time of the call, so they may accept the delay and still call back. However, a new or current patient who is experiencing a dental emergency is far more likely to hang up and try calling another dentist who has someone answering the phones and ready to help.

Many dental practices do not have any coverage for phone calls outside their hours of operation or during lunch hour. Others have an impersonal answering machine advising callers of the practice hours and perhaps offering to record a message. This can be extremely frustrating for your patients, both current and prospective.

If your patient discovers on Friday afternoon or evening that they will need to reschedule an appointment set for Monday morning, chances are that message will not be heard until it is too late to move another patient into the opening. If your phones are being answered outside working hours, this can be addressed much more promptly, leading to better scheduling and happier patients.

You may be wondering how to arrange to have 24/7 phone coverage. There are a few options available, but one of the most economical and most personal for your practice is to train some of your team members to share the responsibility. No one has better knowledge of your practice, your patients, and your schedule than your own team. You will want to decide on the best way to compensate them for the added time, such as paying them a set amount per weekend or evening day or an amount per call answered.

Once this is determined, arrange a rotation for the team members who will participate. Your main phone line can be forwarded to a practice-owned mobile phone during off-hours, which can be held by the team member on call. Be sure that each person has your after-hours contact information in case of an emergency, especially when you are first launching this system.

After a few months, hold a meeting with all the involved team members to review the number of after-hours calls you receive, what times are most common, and how many are converted into new appointments for your practice. This can help you value the ROI for this new plan of action and to determine whether your office benefits from full 24/7 coverage or if a more limited extension of hours is more cost-effective. Contact us today.

 

 

Schiff Client update, as of June 4, 2020 at 6:00 AM

Yesterday, at approximate 7:00 PM EST, the SENATE approved HR7010. We are expecting President Trump to sign the Bill today.

Here are the highlights of HR7010, Changes to the Small Business PPP Loan Programs

Below is a summary of the changes to the Small Business PPP Loan Program. These modifications to the program require a new strategy but provide significant flexibility for a practice to reopen and rehire its employees and still be able to obtain maximum PPP Loan forgiveness. It is very important to realize that this will require a new round of guidance to be issued by the Treasury and SBA but provides time for them to issue updated information we will need, due to the extension of the program from 8 weeks to 24 weeks.

 Changes to the PPP loan program:

1)  8 week covered period extended to 24 weeks

Practice tip: The PPP loan was based on 2.5 months, approximately 11 weeks, of payroll and you now have 24 weeks to spend it. This eliminates most of the challenges of the program and allows employees to be rehired when the practice is ready to open up.

2)  75% rule reduced to 60%

Practice tip: Due to the 24 week covered period, the new 60% rule should not be a problem. We are recommending that you spend 100% of the loan amount on payroll over the 24 weeks as that will make the Loan Forgiveness application process go much easier, because you will only need to attach payroll reports to support your forgiveness. However, if you spend less than 60% of the loan on payroll, you will have $0 (NONE) “no” loan forgiveness which is a drastic change from the previous 75% rule.  So the takeaway here is, please spend at least 60% or more of your PPP Funds on payroll, so you can avoid this trap.

3)  Rehire date moved from 6/30/20 to 12/31/20

Practice tip: Your practice now has until 12/31/20 to rehire employees back to the 2/15/20 level.

4)  Required FTE goal for the rehire exemption is reduced if you are unable to rehire employees or business has declined due to HHS, CDC, or OSHA requirements regarding COVID-19

Practice tip: Continue to plan on rehiring your employees back by December 31, 2020. However, if guidelines (HHS, CDC and / or OSHA) are issued that restrict the number of employees you may have in the office, this should give the practice flexibility in adjusting staffing levels to a new normal. This exception is new and we will need new guidance to clarify it.

5)  New PPP loans will have a minimum maturity of 5 years

Practice tip: The goal of the program has shifted back to trying to get 100% forgiveness. However if you do not obtain this, we believe you will need to contact your bank to modify the terms to the allowable 5 years. We recommend trying to avoid doing this unless absolutely necessary. Current PPP Loans will mature over the original 2 year period.

Indirect changes to the PPP loan program:

1)  We still don’t know about:

  • payments to related parties
  • 2019 retirement plan contributions
  • misc. other payments but they may not matter.

2)  We assume the $15,385 per individual payroll limit will be increased to $46,154 but will need confirmation from the SBA. The $46,154 is the product of $100,000 / 52 weeks x 24 weeks = $46,154. We will need to confirm this.

3)  As we predicted, the Original SBA Loan forgiveness application will be completely changed, as a result of the above changes.

4)  Although utilities, health insurance, SUTA, and other small costs are still eligible, they become less important. Rather than worry about tracking small receipts (invoices / leases / canceled checks) , we are recommending focusing on the big items that are easy to show to the lender that will support the forgiveness application. Examples would be >>> payroll and rent.

5)  Due to the December 31, 2020 rehire date, practices typically won’t be filing forgiveness applications until January 2021 at the earliest.

Example of 24 Weeks

Out of all of our clients, the earliest a client received their PPP Funds was on April 13, 2020.

So, for example, if you received your PPP Loan proceeds on April 13, 2020, your 24 weeks began on April 13th and will end on September 28, 2020. This will be your “covered period” in order to meet the 60% / 40% Test as outlined above.

Maryland Unemployment Issues

If you need any additional help, for…….

Your own unemployment claims, please call 410-949-0022 or email     ui.inquiry@maryland.gov.

Employer related questions (not concerning your own claims) please email   dluisides‑dllr@maryland.gov

Please e-mail us any questions you may have. Hopefully, these are the final changes to the PPP Process, but as we have seen, it could change again!

 

We are here for you!
Please stay well!
My best to all,
Allen

Schiff Client Update as of Wednesday, June 3, 2020 , 9:00 AM

CARES ACT – Paycheck Protection Program Flexibility Act of 2020

Today, the SENATE will be voting on the major changes to the CARES ACT, especially within the PPP Loan process. Here are the major changes as we see them as of today. Please keep in mind, they are proposed and they have NOT passed as of now.

  • 75% / 25% current PPP Loan requirements to change to 60% to 40%
  • 8 week covered period could change to as many as 24 weeks, to 24 weeks or December 31, 2020, whichever is earlier
  • The June 30, 2020 rehire date could be changed to December 31, 2020
  • Expanding the two (2) year repayment of the PPP Loan to five (5) years
  • Allowing borrowers who receive the PPP Loan Forgiveness to also defer payroll taxes

Charging for PPE Equipment and Supplies

I have been actively involved with the MSDA, especially since their Friday e-mail of last week to its members over the issue, “Can you charge a Patient a PPE Fee”? It is my understanding you can only have “one fee schedule”. What this means is, you must charge all patients the same whether they are an insurance based patient or a fee for service patient. Some of you are charging a separate “PPE Fee”. It is my understanding, the PPE Fee varies between $15 to $25 a patient visit. This is your choice. I would recommend you just do a fee increase at this time, and not show the “PPE Fee”. By doing so, you can start to capture the new PPE costs that you are incurring as a result of the Covid-19 precautions.

As far as Dental Insurance is concerned, you can bill the Insurance Company for the PPE Fee. It is their choice as to whether they choose to reimburse you. If you practice like this, it is also my understanding you should charge the same PPE Fee to a FFS patient as well, thus only having one fee schedule.

Further and from my understanding, recently a Maryland Patient went to the Maryland Attorney General (Consumer Protection Division) and filed a complaint about a Maryland Dentist charging this PPE Fee, even though the Patient was an Insurance Based Patient. This is potentially a violation of your Dental Insurance Contract along with a violation of Maryland Consumer Protection laws, so my suggestion is, you should cease this practice immediately to further limit any liability you may have. This is true for any Medicaid Patients you are seeing along with any HMO Patients.

My advice, please consult with your Attorney for further guidance on this issue. Also , please reach out to Greg Buckler greg@msda.com , Executive Director of the MSDA for further guidance.

Maryland Unemployment Issues

I hope most of you have resolved your Maryland Unemployment issues. If you need any additional help, please reach out to

Your own unemployment claims, please call 410-949-0022 or email     ui.inquiry@maryland.gov.

Employer related questions (not concerning your own claims) please email      dluisides@maryland.gov.

2020 Schiff Client Mid-Year Meetings

As many of you are opening your offices and getting back to the “new normal”, we wanted to reach out to you about your 2020 mid-year consulting meetings.

This year we would like to schedule meetings upon your request. With the many challenges you have been faced with, we thought this would be most appropriate.

We can meet via ZOOM or in person, if the situation is safe for everyone. We are estimating 1.0 to 1.5 Hours per meeting. This year will be more challenging for Tax Planning due to the fact, we are still uncertain if the Internal Revenue Service (IRS) will change its position with respect to the expenses we are paying with our PPP Funds. Currently they are non-deductible. We are hoping Congress will put the necessary pressure on the IRS and reverse its decision.

Please contact your Schiff Team member if you would like to schedule a meeting and we will make it happen.

2020 Quarterly Tax Vouchers – 2020 Q1 and Q2

As a reminder, the 1st Quarter and 2nd Quarter Tax Vouchers are now due as of July 15, 2020. Please contact your Schiff Team Member if you need any guidance on these payments.

2019 Individual Tax Preparation

Also, for those of you that are still compiling your 2019 Tax Data, please send to us as soon as possible, so we can get started on its preparation. As a reminder, the 2019 Individual Tax Returns are now due July 15, 2020.

PNC Bank – SCAM UPDATE: Tax-related scams and government stimulus checks

As initially predicted, unfortunately, there are current scams over the Government issued “Stimulus Checks”. Please be careful with text messages, e-mails and phone calls. The IRS only communicates via US Mail and not through and of these other mediums. Please read PNC Bank’s detailed e-mail here. It is very informative.

Schiff Client Update as of Tuesday, May 26, 2020 at 7:30 AM

Employee’s hazard pay and Bonuses – Good News here!

Employee’s hazard pay and bonuses are eligible for PPP loan forgiveness. There is no guidance as to the amounts at this time. Please keep in mind, if the employee salary is already at $100,000+ annualized, the bonus paid to this employee will not help with Loan Forgiveness.

Retirement or health insurance contributions

No additional PPP Loan Forgiveness for retirement or health insurance contributions for self-employed individuals, including Schedule C filers and general partners. Your PPP Loan Forgiveness is limited to the $100,000 annual computation.

Payroll Costs Eligible for PPP Loan Forgiveness

When must payroll costs be incurred and/or paid to be eligible for forgiveness?

Payroll costs paid or incurred during the eight consecutive week (56 days) covered period are eligible for PPP Loan Forgiveness.  You can choose one of two periods:

  1. the date you received your PPP loan proceeds from your Bank (i.e., the start of the covered period);or
  2. the first day of your first payroll cycle in the covered period (the “alternative payroll covered period”).

Example:  You compensate your employees on a  bi-weekly payroll basis (every other week).  Let’s assume your eight-week covered period begins on June 1 and ends on July 26.  The 1st day of your first payroll cycle that starts in the covered period is June 7. You may elect an alternative payroll covered period for payroll cost purposes that starts on June 7 and ends 55 days later (for a total of 56 days) on August 1.  Payroll costs paid during this alternative payroll covered period are eligible for forgiveness.  Also, payroll costs incurred during this alternative payroll covered period are eligible for forgiveness as long as they are paid on or before the first regular payroll date occurring after August 1.

Nonpayroll Costs Eligible for PPP Loan Forgiveness

When must nonpayroll costs (Rent, Utilities & Mortgage Interest) be incurred and /or paid to be eligible for forgiveness?

A nonpayroll cost is eligible for forgiveness if it was:

  1. paid during the covered period; or
  2. incurred during the covered period and paid on or before the next regular billing date, even if the billing date is after the covered period.

Example:  Let’s assume your covered period begins on June 1 and ends on July 26.  You pay your May and June electricity bill during the covered period and you pay your July electricity bill on August 10, which is the next regular billing date.  You may seek loan forgiveness for your May and June electricity bills, because they were paid during the covered period.  In addition, you may seek loan forgiveness for the portion of your July electricity bill through July 26 (the end of the covered period), because it was incurred during the covered period and paid on the next regular billing date. Please maintain copies of invoices and canceled checks so we will have them when we file for PPP Loan Forgiveness.

Will a borrower’s loan forgiveness amount be reduced if the borrower laid-off or reduced the hours of an employee, then offered to rehire the same employee for the same salary and same number of hours, or restore the reduction in hours, but the employee declined the offer? 

No.  If you offered to rehire your employees, you are generally exempt from the PPP Loan Forgiveness reduction calculation. Here are the requirements:

  1. you made a good faith, written offer to rehire such employee (or, if applicable, restore the reduced hours of such employee) during the covered period or the alternative payroll covered period;
  2. the offer was for the same salary or wages and same number of hours as earned by such employee in the last pay period prior to the separation or reduction in hours;

iii. the offer was rejected by such employee;

  1. the borrower has maintained records documenting the offer and its rejection; and
  2. the borrower informed the applicable state unemployment insurance office of such employee’s rejected offer of reemployment within 30 days of the employee’s rejection of the offer. Further information regarding how you will report information concerning rejected rehire offers to state unemployment insurance offices will be provided on SBA’s website.

Will a borrower’s loan forgiveness amount be reduced if an employee is fired for cause, voluntarily resigns, or voluntarily requests a schedule reduction?

No.  When an employee of the borrower is fired for cause, voluntarily resigns, or voluntarily requests a reduced schedule during the covered period or the alternative payroll covered period , the client may count such employee at the same full-time equivalency level before the FTE reduction event.

Loan Forgiveness – Documentation Requirements What must borrowers submit for forgiveness of their PPP loans?

The loan forgiveness application form details the documentation requirements; specifically, documentation each borrower must submit with its Loan Forgiveness Application (SBA Form #3508), documentation each borrower is required to maintain and make available upon request, and documentation each borrower may voluntarily submit with its loan forgiveness application. Please be sure to maintain all payroll reports, along with invoices and canceled checks during your covered period.

When is your SBA Loan Forgiveness Form Due?

You have until October 31, 2020 to file your SBA Loan Forgiveness Form. The lender has 60 days from receipt of a complete application to issue a decision to SBA.

PPE Equipment ?

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