As part of the 2.2 Trillion CARES Act signed by the President on March 27, $175 billion was allocated to the CARES Act Provider Relief Fund. This fund was intended to provide funds to healthcare providers to help them fight the COVID-19 virus for their patients. This fund was limited up until recently to physicians, hospitals and other healthcare providers other than dentists. As of last Friday, all Dentists are eligible.
Many of you that are ADA Members received an e-mail from the ADA (see below) this past Friday evening announcing that all Dentists are now eligible for the #175 Billion in HHS Payments. Initially when the program was first introduced, the HHS Program was only for those Dentists providing services to patients that are Medicaid eligible (Please see >> Schiff Client update, June 10, 2020 at 8:00 PM). This is not the case now as a result of the ADA’s advocacy. This Program is now available for all Dentists. Go ADA!
From my reading of the updates (please see below), it appears a dentist wouldn’t know if they were eligible until they start the application process. You will need your Federal Identification Number (TIN) along with your annual collections. You are eligible only if your Federal Identification Number matches a list approved by the HHS. There are steps in the FAQs to follow if your TIN is not on the approved list.
The amount of money you receive, if eligible is 2% of Gross Revenue on the most recently file tax return. Note that 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. As of now, the funds will be “taxable”. The ADA is lobbying to get these funds to a “non-taxable” state! Stay tuned!
HHS Announces Over $4 Billion in Additional Relief Payments to Healthcare Providers Impacted by the Coronavirus Pandemic
https://www.hhs.gov/about/news/2020/07/10/hhs-announces-over-4-billion-in-additional-relief-payments-to-providers-impacted-by-coronavirus-pandemic.html
The U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), is announcing approximately $3 billion in funding to hospitals serving a large percentage of vulnerable populations on thin margins and approximately $1 billion to specialty rural hospitals, urban hospitals with certain rural Medicare designations, and hospitals in small metropolitan areas. HHS is also opening the provider portal to allow dentists to apply for relief. HHS recognizes the urgent need these vital funds play in supporting safety net providers and those serving large rural populations facing financial devastation catalyzed by the pandemic.
Welcome to the CARES Act Provider Relief Fund Payment Attestation Portal.
The Department of Health and Human Services (HHS) has announced $175 billion in relief funds, including to hospitals and other healthcare providers on the front lines of the coronavirus response as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Paycheck Protection Program and Health Care Enhancement Act. This funding, along with additional relief funding outside of the CARES Act, supports healthcare-related expenses or lost revenue attributable to COVID-19 and ensures uninsured Americans can get treatment for COVID-19. This site is open to all providers who want to apply for a Provider Relief Fund payment, regardless of network affiliation or payer contract. HHS is contracting with UnitedHealth Group to facilitate delivery of the funds.
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.
When a dental provider applies, the first step of the application process is to validate that their 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.
To be eligible, a dental provider must meet all of the following requirements:
- Must not have received payment from the initial $50 billion Medicare-focused General Distribution
- Must not have received payment from the $15 billion Medicaid and CHIP Distribution
- Must have either (i) filed a federal income tax return for fiscal years 2017, 2018 or 2019 or (ii) be an entity exempt from the requirement to file a federal income tax return and have no beneficial owner that is required to file a federal income tax return. (e.g. a state-owned hospital or healthcare clinic)
- Must have provided patient dental care after January 31, 2020
- Must not have permanently ceased providing patient dental care directly, or indirectly through included subsidiaries
- If the applicant is an individual, have gross receipts or sales from providing patient dental care reported on Form 1040, Schedule C, Line 1, excluding income reported on a W-2 as a (statutory) employee.
https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/dental-distribution/index.html
The terms and conditions to the program.
PLEASE READ THESE CAREFULLY. There are a few of these terms and conditions which need clarification. Below are three of the terms and conditions to carefully review:
- A) The Recipient certifies that it provides or provided after January 31, 2020 diagnoses, testing, or care for individuals with possible or actual cases of COVID-19
- B) Recipient is not currently terminated from participation in Medicare or precluded from receiving payment through Medicare Advantage or Part D; is not currently excluded from participation in Medicare, Medicaid, and other Federal health care programs; and does not currently have Medicare billing privileges revoked.
- C) The Recipient certifies that it will not use the Payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse.
https://www.hhs.gov/sites/default/files/terms-and-conditions-medicaid-relief-fund.pdf
Portal to apply for HHS Funds >
https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html
The documents you will need to upload so you can be prepared when you start the process.
- Most recent business federal tax return for 2017, 2018 or 2019 (IRS Form #1120S Corporations, IRS Form#1040 Schedule C – LLC’s and Sole Proprietors, IRS Form #1065 for Partnerships / LLC’s). Please e-mail your Schiff Team Member if you need copies of your 2019 Income Tax Return.
- First Quarter 2020 Form 941, Form 940 Annual Federal Unemployment Tax Return (2019)
- Applicant’s FTE worksheet https://hhs.gov/sites/default/files/prf-fte-worksheet.xlsx
- Gross Revenue Worksheet https://hhs.gov/sites/default/files/prf-gross-revenues-worksheet.xlsx
Good luck with the application process! You have until July 24, 2020 to apply. I would start the application process now, in case there are “glitches” during the way!
