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Understanding COVID-19 Federal Aid Programs
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BY STEVEN SELDE | JULY 2020
During the pandemic your ASC might have relied on financial support from federally administered programs, like the Paycheck Protection Program (PPP) from the US Small Business Administration (SBA) or Provider Relief Fund from the US Department of Health & Human Services (HHS). Since implementation, these programs have been updated by the administering agency or even changed by Congress.
ASCs must continue to work with their legal and lending teams to understand how these programs and changes may apply to them.
Provider Relief Fund
Different portals for different types of assistance
The Provider Relief Fund was created under the Coronavirus Aid, Response and Economic Security (CARES) Act, which was signed into law on March 27. The first distribution went out in early April to ASCs and other providers who billed Medicare in 2019. Since that initial distribution, additional distributions have been made to certain types of providers. Similarly, HHS has built separate application and information portals for providers seeking the various distributions from the Provider Relief Fund.
For example, a single-specialty pediatric dental ASC that is predominately reimbursed by a state Medicaid program is now eligible for a distribution from the Provider Relief Fund and would use the Enhanced Provider Relief Fund Payment Portal to seek that funding. If your ASC previously attested or provided information through a different portal, those portals, which are different than the one described above, are still operational, and it seems that HHS is still using various portals for the different allocations. Learn more about the portals.
Helpful questions and answers
The FAQs page for the Provider Relief Fund includes helpful information and has been regularly updated. Find examples and more detailed information on a variety of topics on this page, like the prohibition on balance billing that your center may have attested to, the publication of information on funding recipients and a host of other topics. Important information for your ASC that is forthcoming, like the additional reporting requirements for healthcare providers that receive more than $150,000 in support—including any COVID-19 related programs, not just the Provider Relief Fund—will be posted on this FAQs page.
Paycheck Protection Program
Like the Provider Relief Fund, the PPP was authorized under the CARES Act and has been an important lifeline for many ASCs. Since implementation, Congress has made changes to the program and replenished funding so that more loans could be issued. On June 11, SBA published revisions to the first interim final rule for the PPP that change key provisions as directed by the Paycheck Protection Program Flexibility Act of 2020, which was signed into law in early June. This updated rule amends the covered period, maturity date and deferral period for PPP loans, as well as loan forgiveness.
On June 16, SBA published an additional update to the PPP third and sixth interim final rules. This update modifies the allowable uses of PPP loan funds and loan forgiveness. On June 17, SBA posted a revised PPP loan forgiveness application. In addition to revising the full forgiveness application, SBA also published a new “EZ” version, which requires fewer calculations and less documentation for eligible borrowers. The EZ forgiveness application is limited to borrowers that:
- are self-employed and have no employees; or
- did not reduce the salaries or wages of their employees by more than 25 percent and did not reduce the number or hours of their employees; or
- experienced reductions in business activity due to health directives related to COVID-19 and did not reduce the salaries or wages of their employees by more than 25 percent.
The administration already published general information about the PPP, like the number of loans issued. Soon, SBA will disclose the business names, addresses, North American Industry Classification System (NAICS) codes, ZIP codes, business type, demographic data, nonprofit information, jobs supported and loan amounts for PPP loans greater than $150,000.
Economic Injury Disaster Loans
While the Economic Injury Disaster Loan (EIDL) program predates the coronavirus pandemic, it might be a new program for your ASC. SBA has made changes to the program throughout the pandemic, and in the early stages of the pandemic, capped loan amounts to meet demand. Additionally, only agricultural businesses could apply for these loans. While the cap still seems to be in effect, SBA began accepting new EIDL and EIDL Advance applications from qualified small businesses on June 15. Previous applications to the program are proceeding on a first-come, first-served basis. Learn more about the eligibility requirements and access other information for the EIDL program. Read ASCA’s weekly Government Affairs Update to stay up to date on developments with these programs and learn about new programs.