Provider Relief Funding Now Also Applies to Dentists

July 13, 2020 | Article

Within the $2.2 trillion CARES Act signed by President Trump on March 27 was $175 billion for 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. Until recently, it was limited to physicians, hospitals, and other healthcare providers other than dentists. But a few weeks ago, it was opened to dentists who treated Medicare and Medicaid patients.

On Friday, July 10, the Department of Health and Human Services (HHS) opened this program to all dentists.

The deadline to file for these additional funds is Friday, July 24.

We recently talked about what this means for dentists on our dental podcast.

Overview of Provider Relief Funding for Dentists

  • If you are eligible, the fund will pay 2% of your gross receipts from your most recently filed business income tax returns. For example, if your practice grossed $1 million in 2019 you would be eligible for $20,000.
  • HHS will use your taxpayer identification number to verify eligibility. The FAQ outlines the steps to take if they do not have your TIN.
  • This is not a loan but a grant, and it will be taxable income. The HHS web site indicates that a 1099 will be issued to the recipients of the funds. The ADA and other groups are lobbying Congress to make these payments non-taxable.

Eligibility of Dentists for the Provider Relief Fund
To be eligible to apply, a dental provider must meet all of the following requirements:

  1. Must not have received payment from the initial $50 billion Medicare-focused general distribution.
  2. Must not have received payment from the $15 billion Medicaid and CHIP distribution.
  3. 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).
  4. Must have provided patient dental care after January 31, 2020.
  5. Must not have permanently ceased providing patient dental care directly, or indirectly through included subsidiaries.
  6. 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.

Terms and Conditions for the Provider Relief Fund for Dentists
There are a few terms and conditions that need clarification. Below are two you should carefully review:

  • The recipient certifies that they provide or provided after January 31, 2020, diagnoses, testing, or care for individuals with possible or actual cases of COVID-19; 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 healthcare programs; and does not currently have Medicare billing privileges revoked.
  • The recipient certifies that they 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.

How to Apply for the Provider Relief Fund
When preparing to apply for the program, you should have the following documents ready:

  1. Most recent federal tax return for 2017, 2018 or 2019.
  2. First Quarter 2020 Form 941, Form 940 Annual Federal Unemployment Tax Return or a statement as to why neither from is required to be filed.
  3. HHS provides an applicant’s FTE Worksheet.
  4. A Gross Revenue Worksheet is provided by HHS, if required by Field 15.

As with the other government programs that have been introduced since the start of the COVID-19 pandemic, this one appears to come with questions. It is important that you evaluate whether this is right for your practice.

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