The document summarizes key provisions of the CARES Act for healthcare organizations, including:
1) Medicare advance payments of up to 100% of prior payments, to be recouped starting 120 days later over a period of 210 days, with interest charged after 90 days for any remaining balance.
2) $100 billion in funding for healthcare providers through the Provider Relief Fund, with an initial $30 billion distributed based on 2019 Medicare fee-for-service billings.
3) Terms and conditions for the Provider Relief Fund distribution including certifying that funds will be used for COVID-19 related expenses and losses, not balance billing patients, and reporting requirements for recipients of over $150,000.
You’ve Received COVID-19 Related Federal Assistance – Now What?Citrin Cooperman
In this webinar, we discussed the complex web of audit and reporting considerations that organizations who received COVID-19 related federal assistance must consider as they approach year-end planning and look forward to 2021.
You’ve Received COVID-19 Related Federal Assistance – Now What?Citrin Cooperman
In this webinar, we discussed the complex web of audit and reporting considerations that organizations who received COVID-19 related federal assistance must consider as they approach year-end planning and look forward to 2021.
CARES Act Update - What you Need to Know Heading into 2021Citrin Cooperman
During this webinar we focused on the interplay between the different CARES Act provisions, in particular PPP loans, Provider Relief Funds, and Medicare Advanced Payments, and how they may impact 2020 year-end planning and 2021 forecasting.
Coronavirus emergency loans via cares act -small business guide & che...Mark Weber
Banks are still waiting for guidance from the regulatory agencies as to how these loans are to be administered and which banks will be able to provide the loan. It may take up to two weeks before they can begin accepting applications. The recommendation is to make contact with your banking relationships ASAP since there will be a lot of asks coming in short order. You should tell the bank that you plan to apply and ask for updates as they learn more.
C-Suite Snacks Webinar Series: There’s No Vaccine for This - State and Local ...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
The pandemic has affected everything in our lives, all the way down to how we run our businesses and our personal finances. In this session, State and Local Tax Partner Eugene Ruvere covered business and personal income tax considerations connected to the pandemic.
High Net Worth Webinar Series - Estate Planning Strategies and UpdatesCitrin Cooperman
There’s much uncertainty in the world of estate planning for high net worth individuals and their families. With numerous legislative proposals that would drastically alter the current estate planning landscape, listen in as our Trust and Estate Services Practice team discusses: various proposals, including those in Congress and the Biden Administration’s Green Book, estate and gift planning strategies for the remainder of tax year 2021, and more.
Payroll Webinar: A to Z of Garnishments Part 1Ascentis
In this three part series on the proper handling and processing of garnishments we will discussed the rules, regulations and requirements as they apply to withholding and paying child support, tax levies, creditor garnishments and others.
In Part 1 we focus on Child Support. Payroll departments must know both the federal laws and the state laws and must determine which one applies to the child support withholding order. In addition to these laws and regulations, the federal rules now require that a standard Income Withholding Order (IWO) be used for all child support withholding garnishments. This webinar will review this form and its requirements. And although the IWO can include all the information necessary to comply with the order, employers must familiarize themselves with both federal and state regulations to avoid penalties and liabilities. Withholding monies for child support is not the only requirement that applies to providing for a child, medical support orders are required to be process by payroll as well. And these orders have their own rules and regulations on both the federal and state level.
C-Suite Snacks Webinar Series: Tax Structures to Reduce Cost and Improve Comp...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
Running a business can be quite difficult, and the process of getting things up and running often overshadows other considerations, such as what type of business tax structure you should operate under. During this session, we covered how to structure your business for optimal tax benefits. Key takeaways included:
- Best tax structure for your business
- New insights on tax structure
- Tips to avoid tax traps based on the type of structure
PYA hosted a complimentary one-hour webinar aimed at helping independent medical group owners, partners and practice executives, law firms, and financial advisors by offering strategies for physician practice survival. Practices are exploring every avenue to remain solvent while health systems express concerns about the survival of the independent groups in their communities.
PYA Principals Lori Foley and Jeff Bushong, along with Consultant Katie Ray, discussed:
Cash flow support, including the CARES Act Paycheck Protection Program and Medicare Advance Payments.
Staffing considerations, including the Families First Coronavirus Response Act (FFCRA), pay reductions, and furloughs.
Operations during crisis management, including topline revenue preservation and expense reductions.
The webinar took place Monday April 6, 2020, at 11:00 am EDT.
In this webinar, CARES Act Funding and Single Audit Update, Withum’s Devin Desmond and Jennifer Stewart discuss recent developments related to Coronavirus Aid, Relief and Economic Security (CARES) Act funding in addition to revisions to Uniform Guidance and Single Audit implications. Viewers are able to identify recent developments related to CARES Act funding and better understand revisions to Uniform Guidance and impact on Single Audits.
PPP Loan Forgiveness and Re-opening Guidance for the Restaurant IndustryWithum
In the midst of COVID-19, restaurants have been forced to change their business model quickly. Withum is partnering with New Jersey Restaurant and Hospitality Association to provide insight on PPP Loan forgiveness and how to prepare for re–opening your restaurant.
PPP Loan Forgiveness and Tax Considerations For the Construction IndustryWithum
Withum’s Construction Services Team is partnered up with New Jersey Subcontractors Association and New Jersey Land Improvement Contractors of America to host a forum regarding Paycheck Protection Program (PPP) Loan Forgiveness and Tax Considerations for the Construction Industry.
Practical Steps for Managing Provider Relief Fund DistributionsCitrin Cooperman
Our Healthcare Practice professionals participated in a webinar discussion, "Practical Steps for Managing Provider Relief Fund Distributions," for healthcare organizations.
Topics included: Provider Relief Fund Overview Managing Provider Relief Funds Eligibility Fund Usage & Risk Management Tracking, Documentation, and Reporting Tax and Audit Considerations Sector-Specific Considerations Post-Acute Providers Dental Providers
Webinar: “Provider Relief Fund Payments – What We Know, What We Don’t Know, W...PYA, P.C.
The federal government is now making CARES Act Relief Fund payments to Medicare providers. These payments are not loans—they do not have to be repaid or forgiven. However, this money comes with strings attached.
During PYA’s 30-minute webinar, Provider Relief Fund Payments—What We Know, What We Don’t Know, What To Do Now, PYA Principals Martie Ross and Lori Foley discussed:
The source of the funds.
The required attestation process.
Compliance, tax, and audit concerns.
The webinar took place Friday April 17, 2020.
CARES Act Update - What you Need to Know Heading into 2021Citrin Cooperman
During this webinar we focused on the interplay between the different CARES Act provisions, in particular PPP loans, Provider Relief Funds, and Medicare Advanced Payments, and how they may impact 2020 year-end planning and 2021 forecasting.
Coronavirus emergency loans via cares act -small business guide & che...Mark Weber
Banks are still waiting for guidance from the regulatory agencies as to how these loans are to be administered and which banks will be able to provide the loan. It may take up to two weeks before they can begin accepting applications. The recommendation is to make contact with your banking relationships ASAP since there will be a lot of asks coming in short order. You should tell the bank that you plan to apply and ask for updates as they learn more.
C-Suite Snacks Webinar Series: There’s No Vaccine for This - State and Local ...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
The pandemic has affected everything in our lives, all the way down to how we run our businesses and our personal finances. In this session, State and Local Tax Partner Eugene Ruvere covered business and personal income tax considerations connected to the pandemic.
High Net Worth Webinar Series - Estate Planning Strategies and UpdatesCitrin Cooperman
There’s much uncertainty in the world of estate planning for high net worth individuals and their families. With numerous legislative proposals that would drastically alter the current estate planning landscape, listen in as our Trust and Estate Services Practice team discusses: various proposals, including those in Congress and the Biden Administration’s Green Book, estate and gift planning strategies for the remainder of tax year 2021, and more.
Payroll Webinar: A to Z of Garnishments Part 1Ascentis
In this three part series on the proper handling and processing of garnishments we will discussed the rules, regulations and requirements as they apply to withholding and paying child support, tax levies, creditor garnishments and others.
In Part 1 we focus on Child Support. Payroll departments must know both the federal laws and the state laws and must determine which one applies to the child support withholding order. In addition to these laws and regulations, the federal rules now require that a standard Income Withholding Order (IWO) be used for all child support withholding garnishments. This webinar will review this form and its requirements. And although the IWO can include all the information necessary to comply with the order, employers must familiarize themselves with both federal and state regulations to avoid penalties and liabilities. Withholding monies for child support is not the only requirement that applies to providing for a child, medical support orders are required to be process by payroll as well. And these orders have their own rules and regulations on both the federal and state level.
C-Suite Snacks Webinar Series: Tax Structures to Reduce Cost and Improve Comp...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
Running a business can be quite difficult, and the process of getting things up and running often overshadows other considerations, such as what type of business tax structure you should operate under. During this session, we covered how to structure your business for optimal tax benefits. Key takeaways included:
- Best tax structure for your business
- New insights on tax structure
- Tips to avoid tax traps based on the type of structure
PYA hosted a complimentary one-hour webinar aimed at helping independent medical group owners, partners and practice executives, law firms, and financial advisors by offering strategies for physician practice survival. Practices are exploring every avenue to remain solvent while health systems express concerns about the survival of the independent groups in their communities.
PYA Principals Lori Foley and Jeff Bushong, along with Consultant Katie Ray, discussed:
Cash flow support, including the CARES Act Paycheck Protection Program and Medicare Advance Payments.
Staffing considerations, including the Families First Coronavirus Response Act (FFCRA), pay reductions, and furloughs.
Operations during crisis management, including topline revenue preservation and expense reductions.
The webinar took place Monday April 6, 2020, at 11:00 am EDT.
In this webinar, CARES Act Funding and Single Audit Update, Withum’s Devin Desmond and Jennifer Stewart discuss recent developments related to Coronavirus Aid, Relief and Economic Security (CARES) Act funding in addition to revisions to Uniform Guidance and Single Audit implications. Viewers are able to identify recent developments related to CARES Act funding and better understand revisions to Uniform Guidance and impact on Single Audits.
PPP Loan Forgiveness and Re-opening Guidance for the Restaurant IndustryWithum
In the midst of COVID-19, restaurants have been forced to change their business model quickly. Withum is partnering with New Jersey Restaurant and Hospitality Association to provide insight on PPP Loan forgiveness and how to prepare for re–opening your restaurant.
PPP Loan Forgiveness and Tax Considerations For the Construction IndustryWithum
Withum’s Construction Services Team is partnered up with New Jersey Subcontractors Association and New Jersey Land Improvement Contractors of America to host a forum regarding Paycheck Protection Program (PPP) Loan Forgiveness and Tax Considerations for the Construction Industry.
Practical Steps for Managing Provider Relief Fund DistributionsCitrin Cooperman
Our Healthcare Practice professionals participated in a webinar discussion, "Practical Steps for Managing Provider Relief Fund Distributions," for healthcare organizations.
Topics included: Provider Relief Fund Overview Managing Provider Relief Funds Eligibility Fund Usage & Risk Management Tracking, Documentation, and Reporting Tax and Audit Considerations Sector-Specific Considerations Post-Acute Providers Dental Providers
Webinar: “Provider Relief Fund Payments – What We Know, What We Don’t Know, W...PYA, P.C.
The federal government is now making CARES Act Relief Fund payments to Medicare providers. These payments are not loans—they do not have to be repaid or forgiven. However, this money comes with strings attached.
During PYA’s 30-minute webinar, Provider Relief Fund Payments—What We Know, What We Don’t Know, What To Do Now, PYA Principals Martie Ross and Lori Foley discussed:
The source of the funds.
The required attestation process.
Compliance, tax, and audit concerns.
The webinar took place Friday April 17, 2020.
Webinar: Free Money with Strings Attached – Cares Act Considerations for Fron...PYA, P.C.
PYA, in conjunction with the Montana Hospital Association, recently co-hosted a Frontier States Town Hall Meeting webinar, “Free Money With Strings Attached: CARES Act Considerations for Frontier States’ Healthcare Provider Organizations.” Principals Lori Foley, Martie Ross, and David McMillan introduced the CARES Act Provider Relief Fund including distribution formulas, the attestation process, the verification and application process, and ongoing recordkeeping requirement. They also answered attendees’ numerous questions regarding these matters.
Webinar: “Making It Work—Physician Compensation During the COVID-19 Pandemic”PYA, P.C.
What to do with your physician compensation plan in the face of the COVID-19 pandemic? It’s a question that leaves administrators searching for answers.
PYA Principal Angie Caldwell and Senior Manager Katie Culver introduced several key considerations for provider compensation during and after the COVID-19 pandemic. In PYA’s complimentary webinar, they:
Summarized the current environment impacting physician compensation associated with the pandemic.
Provided an overview of the Stark Blanket Waivers and opportunities created for physician compensation.
Described restoration and recovery strategies for physician resources.
PYA hosted this one-hour webinar Tuesday, April 28, 2020, at 11 a.m. EDT in conjunction with the Florida Hospital Association.
This webinar continues the COVID-19 Insights webinar series. Topics include the loans and grants being offered by the government, how they differ, and how they may benefit your practice, including SBA Loans and Grants, HHS Grants, Medicare Advance/Accelerated Payments, and Telehealth Funding. The webinar also goes over the CareOptimize technology developed to assist with streamlining COVID-19 monitoring and reporting.
Congress Gave Hospitals and Providers $100B in the Coronavirus Stimulus Packa...Health Catalyst
The COVID-19 pandemic has caused immense financial strain on healthcare systems across the nation. As a result, Congress passed a $3 trillion stimulus package that includes $100 billion for hospitals and other healthcare providers. While this relief for healthcare organizations is much needed, it can also add confusion. What can organizations use these stimulus funds for? What are the risks and compliance requirements?
Bobbi Brown, Senior Vice President of Professional Services, and Dan Orenstein, General Counsel at Health Catalyst, discuss answers to these questions and more. With over thirty years of experience in healthcare financial planning and analysis, Bobbi shares her unique perspective on the stimulus package and how providers can use these funds in their recovery planning. Dan has over two decades of legal experience in healthcare and discusses the specifics of compliance requirements.
In this webinar, Bobbi and Dan address the following:
-Explain significant sections of the four laws passed, including the CARES Act.
-Review program details of the Provider Relief Fund.
-Explore the use of the funds and compliance with terms and conditions.
-Discuss policy changes to better prepare for healthcare emergencies.
This episode continues our COVID-19 COVID-19 Insights Webinar discussing CMS changes, available grants and loans, existing opportunities in telehealth, and more state openings for elective surgeries.
Medicare Bad Debt Checklist and Recent ClarificationsPYA, P.C.
PYA Senior Consultant Holly Bizic presented “Medicare Bad Debt Checklist and Recent Clarifications.” The presentation reviews:
Key facts and expectations.
Progression of Medicare bad debt policy.
Recommendations for compiling and defending bad debt listings.
Audit and desk review clarifications.
Benchmarking.
Pandemic Heroes Compensation Act - Overview and Key RisksJasonSchupp1
The Pandemic Heroes Compensation Act (HR 6909) as introduced on May 15 draws heavily from the framework established for the September 11th Victims Compensation Fund. The main objective of the program is to efficiently deliver no-fault compensation to essential workers and their family members who have contracted COVID-19. This presentation provides an overview of the proposal and identifies key risks.
Healthcare Reform Proving To Be A Calendar Challenge
Healthcare reform is a significant administrative, clinical, financial and technical undertaking. As the nation moves forward to implement the mandates, the critical resource of time is proving harder to find and pay for. As 2013 comes to an end, the changes expected for 2014 will become more apparent and as we move through the year into 2015, more changes and challenges can be expected.
www.healthcaremedicalpharmaceuticaldirectory.com
John G. Baresky
https://www.linkedin.com/in/johngbaresky
#baresky
“CARES Act Provider Relief Fund: Opportunities, Compliance, and Reporting”PYA, P.C.
PYA Principal Martie Ross spoke at the virtual North Carolina Healthcare Association Critical Access Hospital Statewide Meeting. The two-day event, “Quality Focus is a Finance Focus,” provided critical access hospital leaders with the opportunity to network and review data-informed strategies as well as updates to the Medicare Flexibility Program Project. It also provided guidance on federal compliance and tracking of Provider Relief Funds.
In “CARES Act Provider Relief Fund: Opportunities, Compliance, and Reporting,” Martie gave an overview of the history of distribution of those funds as well as regulations and guidelines including:
Statutory Language
Reporting Requirements
Use of Funds Calculation
Expenses
Risk Management
Martie presented Thursday, March 4, 2021.
If you would like guidance related to Provider Relief Fund regulations, or for assistance with any matter related to strategy and integration, compliance, or valuation, contact one of our PYA executives at (800) 270-9629.
Health Reform: Interim Guidance on Expatriate Plans; Updates on ACA Reportin...CBIZ, Inc.
This Health Care Reform Bulletin provides information on the following topics:
a. Interim Guidance on Expatriate Health Coverage
b. Updates on Section 6055/6056 Reporting
i. Revised and Increased Reporting Penalties
ii. E-filing requirements for Employers
c. Final Rules: Preventive Services
d. Reminder on PCOR Fees and Transitional Reinsurance
i. Checklist for PCOR and Transitional Reinsurance Fee
As many of us are working remotely during the COVID19 pandemic, we wanted to share some thoughts and
observations about how the pandemic could impact the
medical and retirement plans that you offer to your
employees.
The following Health Reform Checklist is intended to guide you through the general compliance requirements of
t he Affordable Care Act (ACA) as you prepare now for 2015 and beyond.
In general, these items apply to all employers.
Webinar: “Trick or Treat? October 22nd Revisions to Provider Relief Fund Repo...PYA, P.C.
On October 22nd, the Department of Health and Human Services released revised Provider Relief Fund (PRF) reporting requirements. Under HHS’ September 19 directive, “lost revenue” was defined narrowly as a negative change in year-over-year patient care operating net income. Now, HHS will permit providers to use PRF funds to cover the difference between their 2019 and 2020 actual patient care revenue with some adjustments for COVID-related expenses. The October 22nd notice is available here.
PYA Principals Martie Ross and Michael Ramey hosted a complimentary 30-minute webinar, “Trick or Treat? October 22nd Revisions to Provider Relief Fund Reporting Requirements” on Thursday, October 29th.
US Medical Billing A Comprehensive Overview for Healthcare Providers.pdfmedquikhelathsolutio
The intricate world of medical billing can feel like a labyrinth for healthcare providers. Between deciphering complex medical codes, navigating insurance regulations, and ensuring timely reimbursements, it's easy to get overwhelmed.
Health Reform Bulletin 131 | The ACA Remains The Law of The LandCBIZ, Inc.
As has been covered extensively in the press, Congress went on its summer recess without repealing, replacing or modifying the Affordable Care Act. What this means for employers is that it is “business as usual”, including all reporting obligations, as more fully described below. So where does health care reform stand at this point? The answer to this question is far from clear.
Similar to CARES Act - Key Takeaways for Healthcare Organizations (20)
C-Suite Snacks Webinar Series: Modern Decision SupportCitrin Cooperman
The role of finance continues to evolve in response to the ever-changing business environment. In order to keep your business agile, it is important to make sure that you're fully benefiting from a best-in-class FP&A function.
During this C-Suite Snacks webinar, Dominic DiBernardo, Partner and Corporate Performance Management Practice Leader, discusses what modern decision support looks like and the ingredients for a great financial planning and analysis (FP&A) function.
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
C-Suite Snacks Webinar Series: Building an Advisory BoardCitrin Cooperman
Many private businesses evolve to the point where adding an advisory board can be a significant resource for the owners and senior leadership team, as they accelerate growth and profitability in their companies.
During this C-Suite Snacks webinar, Mark Dailey, a partner at Newport, LLC and seasoned advisory board expert, discusses when you should evaluate building a board, the leading practices and board structures you should consider, and the responsibilities that come with running your board.
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
C-Suite Snacks Webinar Series: Prepping Your Company's Financials for SaleCitrin Cooperman
The business acquisitions market is booming and it’s a seller’s market out there! What can you do NOW to make sure that your business is ready?
Join us at our upcoming C-Suite Snacks webinar as Peter Colgan, Transaction Advisory Services Practice manager, discusses what business leaders find most challenging about preparing their financials for sale and how to efficiently conquer those challenges through the lens of a sell-side financial due diligence.
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
Preparing for the new lease accounting standard can seem like a daunting task. In this webinar, we reviewed how you can handle and prepare to navigate your business through the new lease accounting standard in 2022.
Lease Accounting: Preparing Your Business for 2022Citrin Cooperman
Making a smooth transition to the new lease accounting standards and putting new practices in place for the future is a top priority for any business as they plan for 2022. During this webinar session, we reviewed how you can handle and prepare to navigate your business through the new lease accounting standards.
Topics included:
- What private companies should think about for 2022
- How the lease accounting standards can impact your financial
statements, financial covenants, and taxes
- Identifying opportunities for your business due to the new lease
accounting standards
High Net Worth Webinar Series - Tax Planning and Update for 2022Citrin Cooperman
As 2021 comes to an end, business owners and individuals are seeking opportunities to maximize their savings through year-end tax planning. This webinar session will help you navigate the many complexities, obstacles, and impending tax landscape changes that the 2021 tax year brings to the table and what 2022 has in store.
C-Suite Snacks Webinar Series: The Talent Wars - Can Benefits Be Your Secret ...Citrin Cooperman
In today’s candidate-driven job market, offering a competitive benefits package can significantly improve your company’s success in both attracting and retaining talent. In this webinar session, Shaun Gagnon, president and managing partner of Cambridge Insurance Advisors, shares his insights on maximizing your employee benefits to attract employees and combat the talent shortage.
Topics included:
• Trends in open enrollment and wellness fairs
• Popular and practical benefits
• The war on talent
• Cost increases and how to deal with them
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
High Net Worth Webinar Series - The Business of Digital Assets & BlockchainCitrin Cooperman
The recent rise of Bitcoin and digital assets has created significant new opportunities and challenges for investors. This emerging asset class is transforming both the technology and finance industries. In this session, you will learn about Bitcoin, its progeny, the emerging use cases for digital assets, and how investors are getting involved.
Showtime for Shuttered Venue Operators Grant (SVOG) RecipientsCitrin Cooperman
We discuss the ever-changing guidance around the conditions attached to the distribution of these funds and the specific requirements your organization needs to execute.
C-Suite Snacks Webinar Series: A Year Like No Other - Manufacturing and Distr...Citrin Cooperman
Our second annual Manufacturing and Distribution Pulse Survey Report explores the impact of the pandemic on the industry, and how businesses have pivoted to survive, including managing new product offerings, technology implementation, and supply chain disruptions.
During this webinar session, we discussed how 200 leaders of M&D companies, ranging from $20 million to over $1 billion in revenue, responded to our survey.
Topics included:
• How COVID-19 has accelerated the 4th Industrial Revolution
• Product sourcing changes
• Business pivots and what made them successful
Manufacturing & Distribution Update: The Economic Impact on the IndustryCitrin Cooperman
This presentation focused on what the future is likely to bring to manufacturers and distributors as the nation attempts to claw its way back from the worst of the COVID-19 crisis.
High Net Worth Webinar Series: SALT Thoughts - Pass-Through Entity Taxes & Re...Citrin Cooperman
During this webinar, we discussed how to potentially mitigate the impact of the state and local tax (SALT) cap at the federal level. New York State has joined the list of states that have enacted an elective pass-through entity tax in an effort to do just that. We also dove into the possibility of changing residency to a low-tax or no-tax state. With state tax rates on the rise in some places and the realization that remote work is doable, many individuals are contemplating making a move. To succeed in making a change like this, one must be aware of the technical rules and be willing to significantly adjust one’s life. We talked through all these considerations.
The New Rage in SALT: State Pass-Through Entity TaxCitrin Cooperman
During this webinar, Partner Eugene Ruvere and Principal Jaime Reichardt take deeper dive into the new elective tax regime in New York, in addition to neighboring states like Connecticut, New Jersey, and Rhode Island, among others.
C-Suite Snacks Webinar Series: What's Your IP Worth? Discovering the Value of...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
Every day brings news of a new music catalog sale, strategic piece of intellectual property purchased by a large company or private equity firm, or major transaction of a patent-driven business.
During this C-Suite Snacks webinar session, we discussed which intangible assets and intellectual property are commanding the highest prices and what is behind the value of these assets. Key takeaways included:
- An overview of what drives IP value
- COVID-19 impacts on IP value
- Current IP value trends
C-Suite Snacks Webinar Series: Best-In-Class Finance and Accounting: Should Y...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
During this C-Suite Snacks webinar session, Jason Slivka, executive vice president of strategic initiatives, and Steve Ronan, principal and leader of our Business Process Outsourcing Practice, discussed how outsourcing your accounting function drives profitability and business value. They covered:
- Cleaning up historical books and records
- Combining in-house staff and outsourced capabilities
to get best-in-class expertise across your accounting
function
- How better forecasting and financial analysis drives
better management decisions
- Best practices for accounting technology
- Trends in middle-market accounting operations
C-Suite Snacks Webinar Series: Not Sold on Selling Your Business? Why Now is ...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
The recently proposed tax provisions in the Biden Administration’s American Families Plan should provide substantial incentives for business owners to discuss the creation of an Employee Stock Ownership Plan (ESOP).
During this C-Suite Snacks webinar session, Howard Klein and Heather Oboda covered more about ESOPs, including:
- An overview of what an ESOP is including financial and non-financial benefits
- The common misconceptions about ESOPs
- How the current tax proposals make an ESOP more attractive
MasterSnacks: Cybersecurity - Playing Offense: A Proactive Approach to Cybers...Citrin Cooperman
Sign up for our weekly MasterSnacks courses here: https://www.citrincooperman.com/infocus/mastersnacks
MasterSnacks, our C-Suite Snacks spin-off, brings you a series of topic-specific courses, using our snack-sized sessions to go in depth on content important to you. Join MasterSnacks live every Wednesday at noon for live exclusive sessions.
In today's world, a cyber attack happens every 39 seconds on average. For every doom and gloom story we can tell, there are also instances where another organization’s proactive defense has helped to avoid a cyber attack.
During our final MasterSnacks: Cybersecurity session, we discussed strategies your company can implement to move your IT environment from reactive to proactive. We also shared examples of current clients whose proactive positions have had a real impact in thwarting hackers' attempts at infiltrating their organizations. We covered:
- Case studies on companies that have successfully staved off cyber attacks
- Proactive strategies for protecting your infrastructure
- Automated tools to facilitate more timely evaluation and monitoring
MasterSnacks: Cybersecurity - Disaster Recovery: Hoping for the Best but Plan...Citrin Cooperman
Sign up for our weekly MasterSnacks courses here: https://www.citrincooperman.com/infocus/mastersnacks
MasterSnacks, our C-Suite Snacks spin-off, brings you a series of topic-specific courses, using our snack-sized sessions to go in depth on content important to you. Join MasterSnacks live every Wednesday at noon for live exclusive sessions.
Since a disaster is more a matter of “when” and not “if,” it’s critical to have a plan in place to ensure a rapid recovery. Whether it’s a natural cataclysm or a human-made catastrophe, having actionable, tested steps in place to recover could mean the difference between a brief outage and weeks of downtime.
During session 2, we covered disaster recovery planning. Key takeaways included:
- Knowing the key components to include in a plan
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4. 4
Healthcare Provisions:
Medicare Advance Payments
Provision Details
Medicare Advance Payment Option
• Most providers/suppliers: Up to 100% of the average Medicare payments received, determined by the
MAC, for a three-month period. 120 days following the issuance of the payment, recoupment begins
and providers have 90 days to repay the balance.
• Application: Providers can apply through their MAC’s website
• Process time: Providers should receive finding within a week of the request
Key Details
• Intended as a cash advance, versus a subsidy; should be tied to services already performed
• For most providers, any amount not repaid 31 days after the end of the 210-day payment period will begin accruing interest at 10.25%
5. 5
Healthcare Provisions:
Medicare Advance Payments
Advance
Payment Made
120 days
Recoupment
Begins
Outstanding
Balance Due
90 days
Interest Accrual
Begins on Any
Balance
Outstanding
31 days
Year 1
Most Suppliers and Providers
6. 6
Healthcare Provisions:
Provider Relief Fund
Provision Details
$100B Public Health and Social Services Fund
FEDERAL STIMULUS
$100 billion has been allocated, until expended, “to prevent, prepare for, and respond to coronavirus,
domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms,
eligible health care providers for health care related expenses or lost revenues that are attributable to
coronavirus.”
• Eligible Providers: Public entities, Medicare or Medicaid enrolled suppliers and providers, and such for-
profit entities and not-for-profit entities not otherwise described in this proviso, within the United States
(including territories), that provide diagnoses, testing, or care for individuals with possible or actual cases
of COVID-19
• Use of Funds: Lost revenues and expenses attributable to PREVENT, PREPARE AND RESPOND TO COVID-
19, including building or construction of temporary structures, leasing of properties, medical supplies
and equipment, increased workforce and trainings, emergency operation centers, retrofitting facilities,
and surge capacity
• Timing of Distribution: $30B was distributed starting 4/10/2020
7. 7
Healthcare Provisions:
Provider Relief Fund
Provider Relief Fund Initial $30B Distribution
The CARES Act appropriated $100B to HHS for the support of eligible healthcare providers. On April 10, 2020, the first $30B of that fund was distributed to healthcare providers, based on their 2019 Medicare FFS billings.
While there does seem to be flexibility around the use of these funds, there are several key requirements noted in the Terms & Conditions that accompanied the announcement of the distribution. We are continuing to
monitor guidance issued around these funds, however, we have outlined initial considerations below.
Key Questions
Q: How was the distribution amount determined?
A: Medicare based the distribution on healthcare organization’s 2019 Medicare Fee-for-Service billings. A provider can estimate their payment by dividing their 2019 Medicare FFS (not including Medicare
Advantage) payments they received by $484,000,000,000, and multiply that ratio by $30,000,000,000. Providers can obtain their 2019 Medicare FFS billings from their organization's revenue management
system. This equates to 6.2% of Medicare billings.
Q: Who is eligible?
A: All providers who received Medicare FFS reimbursement in 2019. There are, however, several conditions outlined below attached to this money.
Q: How was this money distributed?
A: It was distributed via direct deposit on April 10, 2020. Providers who do not take electronic payment from Medicare will receive a check. All payments were made according to the provider’s tax identification
number (TIN).
Q: What conditions apply to this distribution?
A: On the next slide, please find an outline of the terms and conditions that apply to this initial distribution from the Provider Relief Fund. Providers must make these certifications through an HHS online portal
available at: hhs.gov/provider-relief/index.html. This portal opened as of the morning of April 16, 2020. Not returning the payment within 30 days of receipt will be viewed as acceptance of the terms and
conditions.
Q: We have had to close due to COVID-19, but we received money from this distribution. Are we still eligible to use it?
A: According to updated guidance on the HHS Provider Relief website, if you ceased operation as a result of the COVID-19 pandemic, you are still eligible to receive funds so long as you provided diagnoses,
testing, or care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19.
8. 8
Healthcare Provisions:
Provider Relief Fund
Category Terms & Conditions Considerations
Eligibility Certifications 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
The provisions here for general eligibility are extremely broad. Based on this guidance from HHS, most providers
who received funds through the initial distribution is likely to eligible to keep it for application to eligible
expenses and losses.
Patient Billing
For all care for a possible or actual case of COVID-19, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that
are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.
Providers are obligated to abstain from "balance billing" any patient for COVID-related treatment.
It seems clear, from this language along with statements made by President Trump, that appropriations with this
fund will be used to cover the uninsured, which could reduce funds available to cover extraordinary
expenses/losses associated with COVID-19. As a reminder, HHS has clarified that it “broadly views every patient
as a possible case of COVID-19.”
Medicare Standing
Certifications
Recipient billed Medicare in 2019
Recipient is not currently terminated from Medicare participation
Recipient is not currently excluded from participation in Medicare, Medicaid, and other federal health care programs
Recipient does not currently have Medicare billing privileges revoked
CMS has indicated that it is aware that many providers do not receive a large proportion of their reimbursement
from Medicare, such as pediatricians, and will focus on those providers in the next tranche of funding.
Use of Funds Certifications
Payment will only be used to prevent, prepare for, and respond to coronavirus
Payment shall reimburse the Recipient only for healthcare-related expenses or lost revenues that are attributable to coronavirus
Payment will not be used to reimburse expenses or losses that have been reimbursed for other sources or that other sources are obligated to reimburse
It is unclear how broad the interpretation of these conditions will be. It does seem, however, that these funds
cannot be used to cover costs/lost revenue coved by mechanisms like business interruption insurance.
Reporting Requirements
Recipient will submit reports HHS deems are needed to ensure compliance with conditions imposed on the payment
No later than 10 days after the end of each calendar quarter, recipients that received more than $150k total in funds under the CARES Act, the Coronavirus
Preparedness and Response Supplemental Appropriations Act, the Families First Coronavirus Response Act or any other Act primarily making
appropriations for the coronavirus response and related activities, shall submit a report containing:
o Amount of funds received from HHS
o Amount of funds received that were expended/obligated for each project or activity
o A detailed list of all projects or activities for which large covered funds were expended/obligated, including the name of the project, description, and
estimated number of jobs created/retained by the project, where applicable
o Detailed information on any level of subcontracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees
Careful tracking of all funding secured through the various acts enacted to address the COVID-19 crisis and its
use will be critical. This tracking will need to include funding from Medicare Advance Payments, PPP, the Main
Street Lending Program, the FCC COVID-19 Telehealth program, and others. One key question that remains
unclear is whether these funds will be considered taxable income.
Note: At this point, it is unclear whether the $150k threshold includes funds from other mechanisms put into
place by the CARES Act to improve reimbursement, such as the suspension of the Medicare Sequester.
Record Keeping
The recipient shall maintain appropriate records and cost documentation, including documentation required by Section 75.302 of Title 45 of the Code of
Federal Regulations:
o Identification in its accounts of all federal awards received and expended, including the CFDA title and number, federal award identification number
and year, and the name of the HHS awarding agency
o Accurate, current, and complete disclosure of the financial results of each federal award. If the HHS awarding agency requires reporting on an accrual
basis from a recipient that does not maintain its records on an accrual basis, the recipient must not be required to establish an accrual accounting
system. This recipient may develop accrual data for its reports on the basis of an analysis of documentation on hand.
o Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining
to federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source
documentation
o Effective control over and accountability for all funds, property, and other assets.
o Comparison of expenditures with budget amounts for each federal award
o Written procedures to implement internal controls, per requirements of section 75.303
o Written procedures for determining the allowability of costs
The recipient shall promptly submit copies of such records and cost documentation upon the request of HHS
The recipient agrees to fully cooperate in all audits HHS, the Inspector General, or the Pandemic Response Accountability Committee conducts to ensure
compliance with Terms & Conditions
Here again, careful record keeping will be critical to ensure compliance and prepare for any potential future
audits. Additionally, documentation of internal controls and for determining the allowability of costs will need to
be developed if not already in place.
Other Terms & Conditions
In addition to the terms outlined above, general provisions of FY2020 consolidated appropriations also apply, including prohibition of the use of funds for highly
compensated individuals, lobbying, abortions, gun control advocacy, and needle exchange programs, among others.
Recipients should be sure to review all terms and conditions included in this section.
9. 9
Additional Funding Opportunity:
FEMA Public Assistance
Provision Details
Eligible Providers
• State, Local, Tribal, and Territorial entities
• Public and non-profit entities which must:
o Be a 501(c), (d), or (e) tax-exempt nonprofit or owned or operated by one;
o Operate an eligible facility, such as a medical facility;
o And provide eligible services such as clinics, in-patient acute care, in-patient convalescent and chronic care, nursing homes, facilities that
support the provision of health care such as central services facilities, extended-care facilities, laboratories, long-term care facilities,
outpatient facilities, ambulance operations and rehabilitation facilities.
Eligible Expenses
1. Efforts to manage, control or reduce immediate threats to public health and safety
2. Emergency Medical Care and Activities
3. Medical Sheltering Related to Patient Surges
4. Other Eligible Costs, including purchase and distribution of medicine, household pet sheltering, overtime costs, and security and law enforcement
Restrictions
• Inpatient care
• Follow-up treatments beyond the duration of the Public Health Emergency
• Insured care, including care insured by Medicaid and Medicare
• Healthcare administration and business costs that are not directly linked to COVID-19, including revenue and business disruption
• FEMA cannot duplicate assistance provided by HHS, including the CDC and other federal agencies
Application
• Applications will be accepted throughout the duration of the Public Health Emergency, until 30 days after its conclusion
• Applications can be made through grantee.fema.gov – STATE FEMA AGENCY - $ available and timing is unknown or provided during initial
application
• FEMA requires detailed documentation for all reimbursable expenses, including specifics about the pressures the emergency is placing on the facility
• Detailed accounting of estimates, bids, expenditures, invoices, payments, and receipts is critical
More information is available at: https://tinyurl.com/FEMA-COVID
As part of the COVID-19 Public Health Emergency, FEMA has made public assistance funding available to eligible State, Local, Tribal,
and Territorial governments as well as eligible private non-profit organizations.
11. 11
Healthcare Provisions: Coverage
Provision Details
Testing
Section 3202: Group health plans and health insurance issuers shall reimburse providers for COVID-19
tests at an agreed-upon rate with providers, or if not agreed to, then at the cash price for such service
as listed by the provider on a public internet website (which is now a mandated requirement)
Preventative Services
Section 3203: Group health plans and health insurance issuers are required to cover all qualifying
coronavirus preventative services (any item or service meant to mitigate or immunize against the virus)
Vaccine Cost-Sharing Section 3713: Eliminates cost sharing for COVID-19 vaccine under Medicare Part B
Medicare Sequester Suspension
Section 3709: Ends the Medicare sequester from May 1 through December 31, 2020, boosting
Medicare payments by 2%
FMAP Increase
Section 3720: Increases the Federal Medical Assistance Percentage by 6.2% for each qualified state and
territory from January 1, 2020 through the end of the quarter in which the public health emergency for
COVID-19 ends. Rhode Island and Connecticut have passed temporary increases to Medicaid
providers of 10% for the months April – June 2020.
On March 30, CMS issued sweeping regulatory changes pursuant to these and other provisions of the CARES Act
12. 12
Post Acute Care Provisions & Funding
Provision Details
Flexibility for Post-Acute Care
CARES Act - Section 3711:
• Waives 3-hour rule for inpatient rehabilitation facilities.
• Waives site neutrality rules for LTCHs
• Suspends 50% rule for LTCHs.
CARES Act - Section 3811
• Extends the Medicaid Money Follows the Person demonstration, occurring in 44 states; extends approximately $75M in funding
through November 30, 2020
Additional Waivers
• CMS has waived the 3-day hospital stay requirement for coverage of SNF stay
• For some beneficiaries, CMS also authorizes renewed SNF coverage without first having to start a new benefit period
• CMS is allowing non-SNF buildings to be temporarily certified for use by a SNF to support isolation protocols
• CMS is allowing rooms in long-term care facilities not typically used for patients to be used to accommodate beds and residents
• CMS is waiving the requirement for physicians and non-physician providers to perform in-person visits; these may be conducted via
telehealth, as appropriate
• CMS is also permitting physicians to delegate a broader scope of tasks to appropriate providers at SNFs
• Additional waiver pertaining to transfers and patient grouping
• Additional waivers pertaining to reporting requirements and data submission
LTCH Waivers
• CMS has issued a blanket waiver to LTCHs to exclude patient stays where an LTCH admits or discharges patients in order to meet the
demands of the emergency from the 25-day average LOS requirement. This will also apply, during the waiver period, to facilities
seeking LTCH classification.
Potential Funding for Nursing
Home Facilities
CARES Act - Title III: Earmarks $100M of a $200M appropriation for “necessary expenses of the survey and certification program,
prioritizing nursing home facilities in localities with community transmission of coronavirus”. Details have not been released as of the
date of this webinar.
13. 13
Telehealth: Regulatory Changes
Provision Details
HIPAA
Due to the need for healthcare providers to scale telehealth capabilities quickly, the Office of Civil Rights (OCR) will not be
enforcing certain aspects of HIPAA to allow providers to communicate with patients using technologies that may not be HIPAA
compliant.
• There is no timeline on when OCR will begin enforcing again
• Providers must act in good faith and do their utmost to protect PHI
• Providers and patients will be able to use services like Apple FaceTime, Skype, Zoom, and Facebook video chat to communicate
via their personal devices
• Usage of certain public communication platforms, like Tik Toc or Facebook Live, will still be considered violations of HIPAA
• Some services like Skype for Business or Microsoft Teams already provide HIPAA-compliant video communications as well as
BAAs. The OCR encourages providers to use these more secure platforms where possible.
Licensing
• Under the Section 1135 Waiver issued by the Secretary of Health and Human Services, the requirement that healthcare
professionals hold a license in the state in which they provide services has been waived, so long as the provider has an
equivalent license in another state
• CMS has not issued guidance on how this will be implemented, however, the ability to provide telehealth across state lines is
critical, as patients may have travelled or may reside in a different state than the practice where they are normally seen,
particularly in areas like New York City and Washington, D.C.
• CMS is currently reviewing how the CARES Act may allow for them to relax rules around providing physical, occupational, and
speech therapies via telehealth
Additional Changes
• Medicare has expanded flexibility around telehealth, eliminating the need for a patient to have seen the provider within the
past three years and permitting audio-only visits
• Providers may also use telehealth for visits with chronic kidney disease patients who are on home dialysis
• Providers may use telehealth to recertify patients for hospice
• The Department of Health and Human Services must issue clarifying guidance on the use of telecommunications systems for
home care, e.g., remote patient monitoring services
14. 14
Telehealth: Reimbursement Changes
Provision Details
High Deductible Health Plans
Telehealth visits for patients enrolled in high deductible health plans with HSAs can be covered by payors before the patient meets
his/her deductible
CMS Reimbursement Rate Medicare will be reimbursing for telehealth visits at the same rate as face-to-face
Setting Flexibility
For the duration of the emergency, Medicare will make payment for professional services furnished to beneficiaries in all areas of the
country in all settings. This flexibility also allows providers to furnish services from their homes
Cost-Sharing Under Medicare, healthcare providers have the option to waive coinsurance and deductible requirements
Medicare Advantage &
Part D Plans
CMS has also issued flexibility to MA & Part D plans, allowing them to add services, like telehealth, that were not included in their bid
15. 15
Telehealth: Opportunities for Post-Acute
Provision Details
Additional Reimbursable
Services
In order to meet the demands of the current pandemic, CMS has expanded the number of codes covered by telehealth by
over 80 additional CPT codes. Taken in conjunction with the waivers issued by CMS to offer additional flexibility to SNFs,
telehealth can help support patients and SNFs in navigating the COVID-19 crisis. Some examples include:
• Emergency Department Visits: ED Visits are now reimbursable via telehealth, allowing patients in nursing settings to
avoid unnecessary trips to the hospital
• Evaluation and Management: Telehealth providers can provide these care under these codes, supporting nursing staff
while allowing SNFs to reduce potential patient and provider exposure to COVID-19
• Specialty Support: Telehealth can also be used to provide specialty care, such as wound care
Remote Patient Monitoring
In addition to telehealth visits, provision of remote patient monitoring can also help to enhance patient care, particularly
in circumstances where nursing facilities may be short staffed or where access to key specialists may be limited.
• Digital vitals monitoring
• Store and Forward consultations
16. 16
FCC COVID-19 Telehealth Program
Provision Details
Appropriation $200M through the CARES Act
Eligible Providers
Non-profit and public eligible healthcare providers in rural or non-rural areas:
• Post-secondary healthcare education providers, including teaching hospitals and medical schools
• Community health center and health centers providing care to migrant populations
• Local health departments or agencies
• Community mental health centers
• Not-for-profit hospitals
• Rural health clinics
• Skilled nursing facilities
• Consortia of health care providers consisting of one or more entities falling into the first seven categories
Eligible Expenses
• Purchase of telecommunications, information services, and connected devices
• Will provide full funding for eligible services and devices, but do not anticipate awarding more than $1M to a single applicant
• Awards will be made based on estimated cost in application, but to provide flexibility, providers will not be tied to purchases
outlined in their application
• Applicants who exhaust funds may reapply
Application
• Awarded on a rolling basis
• Will target hardest-hit areas
• Will not target toward specific conditions, patient populations, or geographic areas
• Applicants should document hardships like provider shortages or limited access to Internet in their applications
• FCC will consider programs’ ability to directly aid in the prevention of pandemic spread
• Devices and services funded must be integral to patient care
In addition to this program, the FCC is also going live with their Connected Care program, which targets projects that would
primarily benefit veteran and low-income patients
17. 17
FCC COVID-19 Telehealth Program
For more information, visit:
https://www.fcc.gov/covid-19-telehealth-program
The application for the FCC COVID-19 Telehealth Program has been posted online
as of 12PM Eastern on April 13, 2020.
18. 18
Telehealth:
Programmatic Considerations
Programmatic Considerations
• Telehealth Platform: If you do not already have a telehealth platform in place, are you able to consider standing up telehealth using readily available
technologies like FaceTime or Skype, under the relaxed regulatory environment, to provide telehealth immediately?
• Cybersecurity and Compliance: Have you consulted with counsel and cybersecurity experts to understand risk exposure and mitigation strategies?
• Malpractice Coverage: Have you checked with your malpractice provider to ensure telehealth coverage?
• Bookkeeping: Have you established a separate cost center for telehealth programming under the current emergency so you can track costs and revenues
and prepare yourself for any current or future government funding opportunities? Tracking should include any waived cost-sharing.
• Physical Footprint: If providers are able to provide care outside of the clinic setting, is there an opportunity to consolidate or repurpose space and reduce
costs or add patient rooms?
• Work Flow: If your providers are still seeing patients in clinic, how are you integrating tele-visits and face-to-face visits to maximize flexibility and fill
providers’ schedules as much as possible?
• Commercial Reimbursement: Have you worked with your top commercial payors to understand what telehealth services they are reimbursing?
• Revenue Cycle: Are you working with payors and your revenue cycle function to understand documentation requirements for telehealth to ensure
collections?
• Privacy: For providers taking tele-visits in clinic, have you designated office or exam room space to maximize privacy?
20. 20
into
PPP Overview: PPP Loan Forgiveness:
For small Businesses < 500 employees
No collateral / no personal guarantee
Determination of loan size:
Your max loan is equal to the lower of 250% of your average monthly
“payroll costs”, or $10M.
Borrowers will be reviewing average monthly payroll costs for the preceding
calendar year (2019)
Payroll Costs:
Employee compensation (not to exceed $100,000, or $8,333.33 per month).
Group health care coverage, including health insurance premiums, net of
employee contributions
Payment of any retirement benefit
Payments to Independent Contractors are not included
Loan Terms:
The interest rate of the PPP loan will be 1%
The maturity date of the PPP loan is 2 years from the loan origination date.
6 month deferral period to begin making payments.
Loan Administration and Application:
Administered through banks under the SBA 7(a) loan program.
Currently, SBA issued “Interim Final Rule”, subject to interpretation and
change.
Eligibility for Loan Forgiveness:
Up to a business’ costs during 8 weeks following date of loan’s origination for the
following categories:
Compensation to employees
Group health benefits
Rent and utility payments
No less than 75% of the loan proceeds need to be used on payroll costs in 8 week
period following receipt of the loan in order to be eligible for full loan forgiveness.
Criteria for Loan Forgiveness:
FTE Headcount: The portion of the loan that will be forgiven will be based
on a ratio of your full-time equivalent employee headcount during the 8
week period compared to the FTE headcount during the test period
February 15, 2019 - June 30, 2019 or from January 1, 2020 until February 29,
2020.
Salaries and wages: Employee salaries must be maintained to at least 75%
of the test period salary in order for the employee to be counted.
Declines in headcount or wages between February 15, 2020 and April 26, 2020
will not trigger a reduction in loan forgiveness if the business reverses the decline
and returns to pre-decline levels by June 30, 2020.
***Loan forgiveness will not be included in a business’s taxable income***
Section 1102:
Paycheck Protection Program (“PPP”)
21. 21
into
Qualified small businesses (as defined by the SBA, less than 500 employees)
Loan proceeds up to $2M for working capital funding
The SBA will determine the exact amount a business can borrow based on cash flow projections and demonstrated need
Collateral required for loans over $25,000
Personal guarantees for loans over $200,000
Proceeds can be used for working capital, including payroll, accounts payable, inventory, equipment and machinery purchases,
real estate payments, and other operating expenses
This program is not eligible for loan forgiveness
Interest rate is 3.75%, and borrower can defer principal and interest for the first 11 months of the loan.
Administered through SBA website
Short form application for $10,000 advance, convertible to a grant – capped at $1,000 per employee
If applying for EIDL grant and/or loan and applying for PPP, the PPP loan will be less the EIDL grant amount and the EIDL loan
amount will be added, not to exceed $10M
Economic Injury Disaster Loan (“EIDL”)
22. 22
Main Street Lending Program Overview
Term
New Loans
(Main Street New Loan Facility – MSNLF)
Expanded Loans
(Main Street Expanded Loan Facility – MSELF)
Eligible Loans New, unsecured term loan originated on or after April 8, 2020
Term loan made by an Eligible Lender to an Eligible Borrower, originated
before April 8, 2020, provided the upsized tranche has the following
features:
Interest Rate Adjustable rate of SOFR plus 250-400 basis points Adjustable rate of SOFR plus 250-400 basis points
Term 4-year maturity 4-year maturity
Repayment Terms
• 1-year deferral of principal and interest payments
• Prepayment permitted with no penalty
• 1-year deferral of principal and interest payments
• Prepayment permitted with no penalty
Minimum Loan Size $1 million $1 million
Maximum Loan Size
Maximum loan size that is the lesser of (i) $25 million or (ii) an amount
that, when added to the Eligible Borrower’s existing outstanding and
committed but undrawn debt, does not exceed four times the Eligible
Borrower’s 2019 earnings before interest, taxes, depreciation, and
amortization (“EBITDA”)
Maximum loan size that is the lesser of (i) $150 million, (ii) 30% of the
Eligible Borrower’s existing outstanding and committed but undrawn bank
debt, or (iii) an amount that, when added to the Eligible Borrower’s
existing outstanding and committed but undrawn debt, does not exceed
six times the Eligible Borrower’s 2019 earnings before interest, taxes,
depreciation, and amortization (“EBITDA”)
Participation in Other
Programs
• Borrower cannot participate in the MSNLF and MSELF simultaneously
• Borrower cannot participate in the MSNLF and Primary Market
Corporate Credit Facility
• Borrower can participate in MSNLF and PPP
• Borrower cannot participate in the MSNLF and MSELF simultaneously
• Borrower cannot participate in the MSELF and Primary Market Corporate
Credit Facility
• Borrower can participate in MSELF and PPP
Fees
• An Eligible Lender will pay the SPV a facility fee of 100 basis points of the
principal amount of the loan participation purchased by the SPV. The
Eligible Lender may require the Eligible Borrower to pay this fee.
• An Eligible Borrower will pay an Eligible Lender an origination fee of 100
basis points of the principal amount of the Eligible Loan.
• An Eligible Borrower will pay an Eligible Lender a fee of 100 basis points
of the principal amount of the upsized tranche of the Eligible Loan at the
time of upsizing.
The Federal Reserve has announced an initiative that will enable up to $600 billion in new financing for eligible borrowers. This program will permit eligible
lenders to originate new loans to eligible borrowers or increase the size of existing loans, for loans originated before April 8, 2020.
23. 23
Main Street Lending Program Overview
Term
New Loans
(Main Street New Loan Facility – MSNLF)
Expanded Loans
(Main Street Expanded Loan Facility – MSELF)
Required
Attestations
• The Eligible Lender must attest that the proceeds of the Eligible Loan will not be
used to repay or refinance pre-existing loans or lines of credit made by the Eligible
Lender to the Eligible Borrower.
• The Eligible Borrower must commit to refrain from using the proceeds of the Eligible
Loan to repay other loan balances.
• The Eligible Borrower must commit to refrain from repaying other debt of equal or
lower priority, with the exception of mandatory principal payments, unless the
Eligible Borrower has first repaid the Eligible Loan in full.
• The Eligible Lender must attest that it will not cancel or reduce any existing lines of
credit outstanding to the Eligible Borrower. The Eligible Borrower must attest that it
will not seek to cancel or reduce any of its outstanding lines of credit with the
Eligible Lender or any other lender.
• The Eligible Borrower must attest that it requires financing due to the exigent
circumstances presented by the coronavirus disease 2019 (“COVID-19”) pandemic,
and that, using the proceeds of the Eligible Loan, it will make reasonable efforts to
maintain its payroll and retain its employees during the term of the Eligible Loan.
• The Eligible Borrower must attest that it meets the EBITDA leverage condition stated
in section 5(ii) of the paragraph above specifying required features of Eligible Loans.
• The Eligible Borrower must attest that it will follow compensation, stock repurchase,
and capital distribution restrictions that apply to direct loan programs under section
4003(c)(3)(A)(ii) of the CARES Act.
• Eligible Lenders and Eligible Borrowers will each be required to certify that the entity
is eligible to participate in the Facility, including in light of the conflicts of interest
prohibition in section 4019(b) of the CARES Act.
With respect to the upsized tranche:
• The Eligible Lender must attest that the proceeds of the upsized tranche of the Eligible
Loan will not be used to repay or refinance pre-existing loans or lines of credit made by
the Eligible Lender to the Eligible Borrower, including the pre-existing portion of the
Eligible Loan.
• The Eligible Borrower must commit to refrain from using the proceeds of the upsized
tranche of the Eligible Loan to repay other loan balances. The Eligible Borrower must
commit to refrain from repaying other debt of equal or lower priority, with the exception
of mandatory principal payments, unless the Eligible Borrower has first repaid the Eligible
Loan in full.
• The Eligible Lender must attest that it will not cancel or reduce any existing lines of credit
outstanding to the Eligible Borrower. The Eligible Borrower must attest that it will not
seek to cancel or reduce any of its outstanding lines of credit with the Eligible Lender or
any other lender.
• The Eligible Borrower must attest that it requires financing due to the exigent
circumstances presented by the coronavirus disease 2019 (“COVID-19”) pandemic, and
that, using the proceeds of the upsized tranche of the Eligible Loan, it will make
reasonable efforts to maintain its payroll and retain its employees during the term of the
upsized tranche of the Eligible Loan.
• The Eligible Borrower must attest that it meets the EBITDA leverage condition stated in
section 5(iii) of the paragraph above specifying required features of Eligible Loans.
• The Eligible Borrower must attest that it will follow compensation, stock repurchase, and
capital distribution restrictions that apply to direct loan programs under section
4003(c)(3)(A)(ii) of the CARES Act.
• Eligible Lenders and Eligible Borrowers will each be required to certify that the entity is
eligible to participate in the Facility, including in light of the conflicts of interest
prohibition in section 4019(b) of the CARES Act.
The Federal Reserve has announced an initiative that will enable up to $600 billion in new financing for eligible borrowers. This program will permit eligible
lenders to originate new loans to eligible borrowers or increase the size of existing loans, for loans originated before April 8, 2020.
25. 25
into
Section 2301: Employee Retention Credit for Employers Subject to Closure or Experiencing Economic Hardship Due to COVID-19
• Refundable payroll tax credit for 50&% of wages paid by employers to employees during the COVID-19 crisis
• The credit is available to employers whose (1) operations were fully or partially suspended, due to a COVID-19-related shut-down
order, or (2) gross receipts declined by more than 50% when compared to the same quarter in the prior year
• The credit is based on qualified wages paid to the employee. For employers with greater than 100 full-time employees, qualified
wages are wages paid to employees when they are not providing services due to the COVID-19-related circumstance.
• The credit is provided for the first $10,000 of compensation, including health benefits, paid to an eligible employee
• The credit is provided for wages paid or incurred from March 13, 2020 through December 31, 2020.
Section 2302: Delay of Payment of Employer Payroll Taxes
• Allow employers to defer paying the employer portion of certain payroll taxes from 3/27/2020 to 12/31/2020, with deferred amounts
due in two equal installments:
• 50% at December 31, 2021
• 50% at December 31, 2022
• Payroll taxes that can be deferred include the employer portion of Social Security taxes
• 50% of payroll taxes incurred by self-employed individuals (i.e. partners) also qualify for the deferral.
• Employers who have applied for a PPP loan or received a PPP loan that is not yet forgiven, may defer deposit and payment of their
share of social security tax without penalties until the time that the employer receives a decision from its lender that the PPP loan is
forgiven.
Key Tax Provisions
26. 26
into
Section 2303: Modification of Net Operating Losses (NOLs)
• Modification of the treatment of NOL carrybacks
• In the case of taxable years beginning before 2021, taxpayers will be eligible to carry back NOLs to the prior five taxable years
• Effectively, this delays the 80% taxable income limitation until 2021 and temporarily extends the carryback period from zero to five years
• C corporations may elect to file for an accelerated refund to claim the carryback benefit
• This provision would modify the treatment of NOL carry forward
• For taxable years beginning before 2021, taxpayers will be entitled to an NOL deduction equal to 100% of taxable income (rather than the 80% limitation in present
law)
• In the case of taxable years beginning after 2021, taxpayers will be eligible for: (1) a 100 percent deduction of NOLs arising in tax years prior to 2018, and (2) a
deduction limited to 80% of modified taxable income for NOLs arising in tax years after 2017
Section 2304: Modification of Limitation on Losses for Taxpayers other than Corporations
• Retroactively turn off the excess active business loss limitation rule implemented with 2017 Tax Law by amending the provision to apply to tax years beginning after
December 31, 2020 (rather than December 31, 2017)
Section 2306: Modification of Limitation on Business Interest
• This provision generally allows businesses to elect to increase the interest limitation from 30% of Adjusted Taxable Income (“ATI) to 50% of ATI for 2019 and 2020,
and allows businesses to elect to use 2019 ATI in calculating their 2020 limitation
Section 2307: Qualified Improvement Property Technical Correction
• The CARES Acts corrects a Congressional oversight by defining Qualified Improvement Property as 15-year property, thus allowing 100% of improvements to be
deducted in the year incurred.
• The change was made as if it included in the original TCJA and, thus, is effective for property acquired and placed in service after September 27, 2017
Key Tax Provisions (continued)
28. 28
COVID-19 Public Health Emergency
Funding MechanismsThe federal government has made monies available to eligible provider organizations through several mechanism. Below, please find an overview of the
funding mechanisms available to date. Please note that most of these mechanisms have additional terms and conditions that cover eligibility, use of funds,
and reporting requirements.
Funding Mechanism
Form of
Distribution
Purpose Agency Eligible Groups
Provider Relief Fund
Grant
(note: assuming subsequent
tranches follow same methodology
as initial tranche)
Cover costs associated with the preparing
for, preventing, and responding to COVID-19
HHS/CMS
• Hospitals/Health Systems
• Physician Practices
• Some Post-Acute
PPP Forgivable Loan
Support payroll expenses to reduce need for
layoffs/furloughs
SBA
• Some Hospitals (<500 employees)
• Physician Practices
• Some Post-Acute (<500 employees)
EIDL Loan
Provides working capital infusion at a low
interest rate
SBA
• Some Hospitals (<500 employees)
• Physician Practices
• Some Post-Acute (<500 employees)
Main Street Lending Facility Loan Providing needed liquidity to businesses Federal Reserve
• Most Hospitals/Some Health Systems (<10,000 employees)
• Physician Practices
• Most Post Acute (<10,000 employees)
Medicare Advance Payments
Cash Advance (interest applies after
recoupment period ends)
Provide needed liquidity to Medicare
providers
CMS • All Medicare Providers
FCC COVID-19 Telehealth Program
Reimbursement
(invoices/documentation required
for disbursement)
Provide funding for providers looking to
enhance telehealth capabilities
FCC
• Most Hospitals/Health Systems
• Some Physician Practices
• Some Post-Acute
FEMA Public Assistance Grant
Support costs associated with provision of
emergency response
FEMA
• Some Hospitals/Health Systems
• Few Physician Practices
• Some Post-Acute
32. 32
FCC COVID-19 Telehealth Program:
Application Preparation
Step Details
Step 1: Obtain eligibility
determination from the Universal
Service Administrative Company
• Provider sites that have already secured a USAC eligibility determination may rely on that eligibility determination for the COVID-19
Telehealth program
• Interested providers who have not received a previous eligibility determination must submit FCC Form 460
• Applications that do not yet have an eligibility determination from USAC can still nonetheless file an application with the FCC for
the COVID-19 Telehealth program while their FCC Form 460 is pending
• Consortium applicants may file an FCC Form 460 on behalf of member health care providers if they have a Letter of Agency. The
Letter of Agency should be submitted as an attachment to FCC Form 460
Step 2: Obtain an FCC Registration
Number
• All applicants must register for an FCC Registration Number (FRN), which is unique to the business and used to identify the
registrant’s dealings with the FCC
• To register for an FRN, visit: https://apps.fcc.gov/cores/userLogin.do
• Users will need to provide their taxpayer identification number
Step 3: Register with System for
Award Management
• To receive payments through the program, applicants must be registered with the federal System for Award Management
• Applicants who are already registered do not need to re-register
• Registration can take up to 10 business days
• To register, go to: https://www.sam.gov/SAM/
• To register, applicants will need to provide: (a) Data Universal Number System; (b) Taxpayer Identification Number (TIN) or
Employment Identification Number (EIN); (c) Bank routing number, bank account number, and bank account type
• Only applicants registered through the System for Award Management will be able to received COVID-19 Telehealth Program
funding
Other Requirements
• Applicants will need to submit their Data Universal Number System Number (DUNS). To register for a DUNS number if an
organization does not already have one, visit https://fedgov.dnb.com/webform/displayHomePage.do or call 1-866-705-5711
The FCC has issued additional guidance on its COVID-19 Telehealth Program, including steps interested organizations should be taking
prior to the application process opening and additional detail on the content of the application.
33. 33
FCC COVID-19 Telehealth Program:
Additional Application Detail
Requirement Details
Medical Services to be
Provided
Applicants will check all that apply:
• Patient-Based Internet-Connected Remote Monitoring
• Other Monitoring
• Video Consults
• Voice Consults
• Imaging Diagnostics
• Other Diagnostics
• Remote Treatment
• Other Service
Conditions to be Treated
with COVID-19 Telehealth
Funding
• Whether the applicant will treat COVID-19 patients directly
• Whether the applicant will treat patients without COVID-19 symptoms or conditions (applicants will check all that apply):
o Other infectious diseases
o Emergency/Urgent Care
o Routine, Non-Urgent Care
o Mental Health Services (non-emergency)
o Other conditions
• How using COVID-19 Telehealth Program funding to treat patients without COVID-19 symptoms or conditions would free up resources that
will be used to treat COVID-19
34. 34
FCC COVID-19 Telehealth Program:
Additional Application Detail, continued
Requirement Details
Additional Information
Concerning Requested
Services and Devices
• Goals and objectives for use of the COVID-19 Telehealth Program Funding
• Timeline for deployment of the proposed service(s) or devices funded by the COVID-19 Telehealth Program
• Factors/metrics the applicant will use to help measure the impact of the services and devices funded by the COVID-19 Telehealth Program
• How COVID-19 has affected health care providers in your area
• Any additional information about the geographic area and population serve by the applicant. Indicate whether the geographic area you serve
has been under any pre-existing strain (e.g., large underserved or low-income patient population; HCP shortages; rural hospital closures;
limited broadband access and/or Internet adoption). If so, describe such factors
• Whether the applicant plans to target the funding to high-risk and vulnerable patients. If so, describe how
• Any additional information to support the application and request for funding
Requested Funding Items
• Total amount of funding requested
• Whether funding for devices is being requested. If so:
o How are the devices integral to patient care?
o Are the devices for patient use?
o Are the devices for the health care provider’s use?
Supporting Documentation
An applicant should provide supporting documentation for the costs indicated in its application. Such supporting documentation should
summarize the expected costs of the eligible services and devices requested and may include documentation such as an invoice or quote from a
vendor or service provider (or similar information). Such information should be specific enough to identify line-items to facilitate swift review of
the application, and we encourage applicants to include information such as a description of the service or device, its eligibility category, the
quantity ordered, the upfront and monthly expenses, and the service dates for recurring services