Podcast (Dental)

HHS Provider Relief Fund Reporting for Period 1 Now Due

August 4, 2021

If dentists received more than $10,000 of HHS Provider Relief Funds in “Reporting Period 1” (the period between April 10, 2020, when the relief funds started being received, and June 30, 2020) they must report any expenses incurred to prevent the spread of the coronavirus and their lost revenue. These expenses must be reported by September 30, 2021.

In this episode of The Art of Dental Finance and Management podcast, Art meets with the leaders of Eide Bailly’s HHS Provider Relief Fund team Tyler Bernier, CPA, FHFMA  and Ashley Brandt-Duda, CPA to discuss how dentists can properly report in the HHS Provider Relief Fund Portal.

Tyler and Ashley spearheaded the Provider Relief Fund (PRF) campaign at Eide Bailly to help healthcare providers navigate all the complexities surrounding the funding. They’ve also created an email address where you can send questions and concerns and get answers: PRF@EideBailly.com.

Topics covered include updates related to the timeline for use and reporting of the funds, as well as clarifications on the process and terms and conditions released to date. It’s important to note that the PRF portal hosts an Excel spreadsheet that will help calculate expenses and lost revenue as you work through the process. It will also calculate a remainder at the end to clarify whether you have spent all your funds or if you have leftover funds that need to be sent back. If you do have any PRF funds that you have not spent, those need to be sent back to HHS within 30 days.

Tyler and Ashley recommend taking these steps in prepping for PRF reporting:

  1. Mark your calendars. Be sure you know when you must report and what those deadlines are because you don't get to go back again later. There is a chart in the portal to help keep track of deadline dates.

  2. Start tracking and figuring out where you're at with expenses and lost revenue.

  3. Go to the portal page (even if you haven't registered yet), access the Excel document to track all of the information you need to start putting together. It will put the information that you need in a centralized place, as well as give you an idea of how much of these funds you can support and how much you can keep. Don't spend the money until you know you can keep it.

  4. Reference the PROVIDER RELIEF FUND (PRF) REPORTING PORTAL - REPORTING user guide pages 7-10 in the portal as it includes a detailed and bulleted list of everything that you're going to need for reporting.

  5. When you run into complex issues, reach out to our Eide Bailly PRF team. Inevitably, there will be lots of questions and concerns. 

TylerToday's Guests

Tyler Bernier, CPA, FHMFA

Eide Bailly

Ashley Brandt-Duda

Ashley Brandt-Duda, CPA

Eide Bailly

Show Notes and Resources:

The Transcript

Art Wiederman, CPA: And hello, everyone, and welcome to another edition of the Art of Dental Finance and Management with Art Wiederman, CPA. I am your host. My name is Art Wiederman. I'm a dental division director at the CPA firm of Eide Bailly. Very proud member of Eide Bailly. In fact, for those of you who've been listening to the podcast, I was just talking to our guests that on the 20th of July I will have been a part of Eide Bailly for one year. Time flies when you're having fun. And I will tell you, I could not be happier with all the people at Eide Bailly.

And you're going to meet two of my new friends, two partners today at Eide Bailly. And we're going to be talking about the HHS Provider Relief Fund. Now, you guys are probably sick and tired of listening to the talk about PPP and ERTC and ESPN and HBO and Cinemax and whatever else I've been talking about the last six months. Well, I got another one for you folks.

Most of you have received money from the federal government, from what's called the Department of Health and Human Services Provider Relief Fund. And my two guests today are two partners at Eide Bailly, Tyler Bernier from our Oklahoma City office, and Ashley Brandt-Duda from our Fargo, North Dakota office. And they have taken the lead with our firm for all of our clients in the healthcare industry who have received money from this one hundred seventy five billion dollar program. So we're going to tell you about all of the things that you need to know for reporting, because you can't just take this money, keep it, not tell anybody about it. Guys, you're going to have to tell the government a little bit of information, in fact a lot of information and that's what we're going to talk about today.

So this is really important. Please pay attention and we'll get to Ashley and Tyler in a moment. But I want to give you some information first. First of all, I'd like you to please go on to our partner, Decisions in Dentistry's website. Decisions in Dentistry is the primary premier dental clinical magazine in the country. If not in the world. They have a who's who of dentists and other professionals in the dental profession who write great articles. If you're looking for very inexpensive quality CE, they have over one hundred and forty courses that they provide at one annual cost. Go to their website at www.DecisionsinDentistry.com.

If you're looking for a complimentary consultation with me or any member of our Academy of Dental CPAs, you can click on the box on their website and we'll give you a call. Also, the Academy of Dental CPAs is my mother ship. Twenty four CPA firms around the United States that represent over ten thousand dentists. Go to our website at www.ADCPA.org. Eide Bailly is a very proud member. I was one of the founding members of the ADCPA.

And if you want some great information about anything dental, you can go to our YouTube page. We've been doing a yearlong series on the business of dentistry, and we do it the second Wednesday of every month and it's live from six to eight p.m. California time. And if you can't make it at six to eight p.m. California time, I know that's late for a lot of you. And we have a lot of listeners on the East Coast, especially in the Northeast, I'm finding. So if you can't do that, it's on our YouTube page. So you go to Eide Bailly's YouTube page and you can get all of the web casts that we're doing. And it's really, really good information.

If you want to register for our dental series, it's www.EideBailly.com/dentalseries. You can also call me at any time with any questions about any of this stuff. My office number six five seven two seven nine three to four three and my email is awiederman@EideBailly.com.

Just one more thing. I'm not going to give you my announcement on HHS because that's what we're talking about today. We'll get to that in a second.

I just want to remind you, this podcast is going to go up on August the 4th and by August the 4th, if you have not filed for your PPP forgiveness, you need to file. You have so here's how you figure out how you when you have to file for forgiveness, because if you don't file for forgiveness, you're going to have to start paying your loan back over two years. So it's a big payment. What you do is you take the date that you got the money, add twenty four weeks, which is the maximum covered period, and then add 10 months to that. So for most of our doctors, that comes to late July to some time in August and most you will have to file in August.

So if you have not, what we're finding, folks, is that we are now able to coordinate the PPP with the Employee Retention Tax Credit. I just spent time on the phone with Andrew Stolle, who's one of our great management folks at Eide Bailly, who's specializing in the IRS. And what we've been determining is that even if you have filed for SBA forgiveness, we can still get tens of thousands of dollars of tax credits. And we're doing that for dozens and dozens of doctors where I think we're going to might be getting over 100 that we're doing this for.

We've gotten over two million dollars in credits for our doctors from the government. So my job and my objective is to run that federal deficit up until the place explodes and we're doing a good job. So if you need help with the forgiveness or the Employee Retention Tax Credit, if you had a greater than 50 percent reduction in your revenues, give me a call. We can definitely help you. We got this thing down to a science. We got a spreadsheet that a CalTech and an MIT grad would be proud of.

So. All right, let's get to our guests. Let's get to Tyler and Ashley. So, like I said, Tyler Bernier, who's a partner in our Oklahoma City office, and Ashley Brandt-Duda, who's a partner in our Fargo, North Dakota office, have spearheaded the campaign to help our clients with the HHS Provider Relief Fund. And all I'm going to do to start off, because they're going to do most of the talking. I know that's hard to believe, guys, but you're going to do most of the talking. It doesn't seem that way, but that's how this is going to work. And basically, you are going to have to provide information to the government if you got money. So, Tyler and Ashley, welcome to the Art of Dental Finance and Management.

Ashley Brandt-Duda: Thank you. Thanks for having us, Art. We're happy to be here.

Art Wiederman, CPA: Well, thank you and thank you for everything that you're doing for Eide Bailly and for our clients who really need help with these government. I mean, wouldn't it be easy? It's kind of like one time I saw a tax form that said line one, how much money did you make, line two send it in? Wouldn't it be easier if they just kind of gave us an HHS hey, how much money did you spend? Tell us. And it's good. That not how this works, right?

Ashley Brandt-Duda, CPA: It unfortunately isn't. Maybe we can write them in a suggestion and see if they can do that, because unfortunately it's quite a bit more complicated.

Art Wiederman, CPA: I thought, like all the IRS offices or the HHS offices had like a little suggestion box in the front you could drop something in. Dear HHS, this is too hard. I don't like it. I want to do something different. So, anyway, I quickly, guys, Tyler, a little bit of your background and history and how long you've been with Eide Bailly and then Ashley the same.

Tyler Bernier, CPA, FHMFA: Sure. So once again, this is Tyler out of Oklahoma City. I've been with Eide Bailly actually from the start, so I am in my 16th year now and my third Eide Bailly office. As you can tell from my accent, it is not Oklahoma original, but I can throw some y'alls in there every once in a while. So previously I was up north with Minneapolis and then closer to where Ashley is in Fargo, so I can still drop some o's in there and some long a's. But recently my normal services is primarily or exclusively in the healthcare area, normally helping clients and working on audits and financial statements, the like. But as you mentioned, Ashley and I kind of spearheaded our attack here on the Provider Relief Funds. And little did we know this would be a years long process. As you said, everybody was hoping and expecting simplicity. And what the heck, we're 14 months later and I feel like not that much closer to where we started, but we'll see how much we can help get people across the finish line here.

Art Wiederman, CPA: Well, my hair is already gray, guys. I don't know how much what other color it turns, after we get into this stuff. Ashley, what's your story?

Ashley Brandt-Duda, CPA: Yeah, my story is actually very similar to Tyler's in that I primarily in the past have worked in our audit and assurance practice, working with clients on their financial statements and the like. And again, recently similar to Tyler got, I guess, roped into what we maybe thought would be a simple project. But we're still here and still working on the Provider Relief Fund. But I've been with Eide Bailly for roughly 15 years. I started out in our Aberdeen, South Dakota office and now I'm in Fargo.

Art Wiederman, CPA: Well, that's great. It's great to have both of you two very, very excellent professionals. And you're helping a lot of people. And we're going to help a bunch more today, thousands who listen to our podcast. So let's start off, guys. Give us a little history of the HHS Provider Relief Fund. What was its purpose and who got the money?

Tyler Bernier, CPA, FHMFA: Sure. Let's take a ten thousand foot view and go back in history. And it all kind of magically started with the passing of the CARES Act. And then on April 10, a number of providers across the country in different realms that served Medicare patients got an early Christmas gift or a late one, depending on when you're looking at. So money magically appeared in their bank account and they had no idea why. And that is where our fun story begins. And from there, it just gets more complicated and complex and strange and all the same ways.

So the intent of the program was really as COVID was ramping up or really in its strengthening period. The country's shutting down. There's lots of healthcare providers that were experiencing struggles. So this was meant to provide a direct inflow of capital to all of these organizations. And as I said, as the time went on, that grew. So it started with these Medicare providers. And I think that attached this idea that it had to be, you had to be a Medicare provider. This is a Medicare program. And it clearly wasn't, it was a stimulus program.

And as we went along, the number and types of healthcare providers changed. So on June 10, the dental providers were actually scoped in, along with providers that only included Medicaid and then CHIP. And we'll probably use a lot of acronyms, those that actually matter, I'll try to spell out, those that don't, I'll just skip right by. And I don't think CHIP's probably that big of a deal. So many of the listeners on this really got scoped in or around that middle of June phase with the opportunity to apply for funds and receive them. So there may be some that got them in June, a lot that probably got them in that July frame. And then we kept going.

We kept adding in new providers, skilled nursing facilities, assisted living facilities. And then we announced in October what was called this Phase three payment. And that was really the big dollars is if you could apply for them, because the first ones were really based more on this Medicare, Medicaid volume. So phase three comes in and dollars continue to flow in and they're flowing in throughout twenty twenty, twenty twenty one, and we're still in a period where there's dollars sitting at HHS that they have yet to distribute.

Plus, as we get through these reporting phases, there's going to be money paid back to them inevitably from various providers. So that all kind of goes into a pot that we fully expect will be potentially available for future distributions. And in fact, the stimulus bill in January provides for an outline of how those distributions need to be handled, and that has yet to be done. So that's actually a federal law that was passed that still hasn't occurred.

Art Wiederman, CPA: So my dentists have gotten a couple of dollars of government money. You're telling me, Tyler, there might be more available down the road maybe?

Tyler Bernier, CPA, FHMFA: That is the expectation. And again, until something happens, I'm not sure any of us will know. But based on what the regulations include in them, it does provide an opportunity for more funding.

Art Wiederman, CPA: Well, and everybody watch Eide Bailly's website, watch our YouTube page, watch the articles, because Tyler and Ashley are going to be keeping everybody up to date. So this was supposed to be a program that was going to help, you know, healthcare providers during the pandemic. And you go apply for the funds, you get approved. Life is good. We're all happy. Why does it seem like it's so hard for us to keep this money? I mean, what's the deal?

Tyler Bernier, CPA, FHMFA: Well, first off, we're dealing with the government.

Art Wiederman, CPA: Yeah, I'm from the government, I'm here to help.

Tyler Bernier, CPA, FHMFA: Yes, I will say my own personal opinion. I was very surprised at the speed at which they were able to get dollars out. I have also been very disappointed at the back end information on how to utilize, retain, report, et cetera, all of these various funds that individuals received. So Art, as you said, this will be coming out in August. I do have to throw a disclaimer out there for everybody. The information we'll talk about is as of the latest release July 1st. And I say that because there are times when there are updates weekly or even daily to things that change what we're talking about. So obviously be aware that changes could occur by the time you're listening to this.

However, why is it so difficult? If you listen back to what I have just talked about, this program was intended to support the healthcare industry. And if you look at it, that is health systems, hospitals, nursing homes, physicians, physician practices, dentists, behavioral health companies. The variety of service providers is huge.

And the dollar amounts that people got is also very, very wide. It goes from 10s to hundreds of dollars, up to 10s to hundreds of millions of dollars. So trying to put rules and regulations around a program that's intended to cover that many people and that range of dollars just breeds complexity. So hopefully now that we are at this point where we can actually finally support some of the use of funds and have what I think to be a relatively complete guideline for what we can do, we're probably in a better spot.

I will point out as we work through this, there are going to be tons of questions that pop up, right? I mean, all from what we're going to talk about on this podcast from how to use the expenses, what we're talking about with lost revenues, but probably most importantly, how we're going to report on these funds. So as any of the providers on this have those questions or need assistance, we have plenty of people that are available and we have a specific email address that we're utilizing just because we know the number of requests coming in are going to be significant. So it is PRF, like provider relief fund, the three letters PRF@EideBailly.com and that's E I D E B A I L L Y. So once again, PRF@EideBailly.com.

Art Wiederman, CPA: And we'll go ahead folks and put that into the show note so that when you get your notification of the podcast or you log on, you'll be able to see that. All right. Let's get a little more into the weeds, guys. So I know that the basic you say ten thousand foot view is they got to use the money for two things. Number one, to spend money to fight COVID-19 and then also to replace lost revenue. So let's get into some details. How does this money have to be spent? What are the rules?

Ashley Brandt-Duda, CPA: Yeah, and so I think along the lines of what Tyler was saying, that the money was definitely released from the government very quickly. And as such, I will tell you, the terms and conditions for the use of the funds is actually they're actually quite vague and very broad. So really there's two different areas where the money can be spent. And the first one is on healthcare related expenses that are to prevent, prepare for and respond to coronavirus. And that's why I say quite broad, because, of course, there's a lot of different things that can fall within that prevent, prepare for and respond to coronavirus. Of course, some of the more common ones we see here, the obvious ones that you think of, any additional supplies that you had to purchase, PPE, your equipment. But it could also be things like additional staff time if you had additional staff that you had to hire to screen patients or things like that coming into your clinics.

The other piece is the funds can be used to cover any lost revenues that you had as a result of the coronavirus as well. Another key. Oh, sorry. Go ahead Art.

Art Wiederman, CPA: So, Ashley, so this brings up like a hundred other questions. But so one of the things we were actually talking yesterday in our meeting, all of us, about the fact of the lost revenues. Are we going to get into that now as far as like do we take a look at the whole year? Do we look at a quarter? I mean, how does that all work?

Ashley Brandt-Duda, CPA: Yeah, so the lost revenue is actually the time period that you're looking at is actually going to be based on what the covered period of your reporting is. And so that's going to be depending on what payments you received. And there are some good tables out there explaining all that information. But essentially, the key part here for providers to know is that they are going to have to report their revenue on a quarterly basis, essentially throughout the covered period. So it's going to be two thousand twenty. And most of two thousand twenty one at this point as well.

There's a few different ways that you can look at the lost revenue. And I would imagine for most dentists, what they're going to do is compare their actual two thousand and nineteen to both two thousand and twenty in two thousand and twenty one, because that comparison is just going to make the most sense. But there are some other alternative ways of looking at the lost revenue as well.

Art Wiederman, CPA: So let me throw an example out to you. I've got a five million dollar dental practice. This is a real example, five million dollar dental practice. Most all the dentists shut down the week of March 16th. The American Dental Association recommended, the CDC recommended nobody, few states mandated, but most were recommendations. They shut down and they were shut for eight to 12 weeks. So this particular practice had basically 700 or 800 thousand dollars in lost revenues in the second quarter.

What happened in the dental profession, guys, is that they came back when they opened up in May and June, there was all this pent up demand. These guys, even though they had to social distance, they were adding hours and people and all the stuff. Some of my dentists actually had higher revenues in the third quarter than they'd had in 2019. And in the fourth quarter, some of them even came back to where they were in twenty nineteen. So if I got, if my client got four hundred thousand dollars, I mean are they up the creek on that or can we use a particular quarter. How does that work.

Ashley Brandt-Duda, CPA: Yes. And this was actually a point that HHS just clarified very recently because under the old guidance, as Tyler said, it changes sometimes up to weekly, but under the old guidance that would have unfortunately negatively impacted the dentist if they had that increased demand later. But now that lost revenue is actually assessed on a quarterly basis. And so if you have a quarter where you had significant lost revenue, but then the next quarter you had an increase in revenue, that increase in revenue is just essentially shown on your form as zero. So the positive note is that those if you have those really negative quarters, you won't be you won't be I guess your lost revenue won't be impacted if you make up those gains later.

Art Wiederman, CPA: You won't be penalized if the third or the fourth quarter. So if I have lost big lost revenue in the second quarter, maybe a little bit of lost revenue in the third, but then I gain in the fourth, I can use only the second and third quarters?

Ashley Brandt-Duda, CPA: Yes, something to keep in mind is you still, they are still going to have to dentists still have to report for all quarters, but it just won't negatively impact that final calculation. So just to clarify that, so you'll keep in mind that you'll still need to go through, you'll still need to report for all quarters. But yes, it will only be the quarters with losses that will be added together that will essentially calculate that lost revenue number.

Art Wiederman, CPA: Now, you guys also said that we can't use expenses that are reimbursed by another source. So maybe we're talking PPP because PPP covers wages, rent as of December 27th it now covers PPE stuff, which is in the HHS. So how does it work if my dentist, because most of my dentists got their PPP loans in the second quarter, so they had a big revenue loss in the second quarter and then they get a big check for PPP in the second quarter. How does that all fit into this?

Ashley Brandt-Duda, CPA: So the positive note is that the PPP loan itself or that any other assistance, whether it's PPP, whether it's any other grants that were received, those will not negatively impact the lost revenue calculation as from a lost revenue standpoint, they do not need to be included. The piece that everyone does need to take a look at, though, is what you mentioned, Art, with the that it can't be reimbursed or is obligated to be reimbursed by another source. So in this case, for example, if a dentist received a PPP loan and as part of that, they are getting or having those salaries covered by the PPP loan, they can't, for example, claim those same salaries under their Provider Relief Fund expenses. So that's really the piece that they just need to keep in mind is you cannot claim any expenses that are either covered by PPP, covered by another grant, for example, or even that are covered by your patients that are coming in. So if you have supplies or things that are billable to the patients, you cannot claim any of that under the Provider Relief Fund.

Art Wiederman, CPA: OK, so let's get into some of these expenses. So bottom line is, I get this money. Most of my dentists got two percent of their revenues. Most of them got them in August, as best as I can see from our accounting records. And then they got some of them got this phase three and some of them got hundreds of thousands of dollars, several of them did. So we can use it for expenses to fight coronavirus.

So let's talk about that for dentists. We're talking about air purification machines, hand sanitizer. I had one dentist who called me yesterday and said I spent nine dollars and fifty one cents on the sign that said, please wear a mask. Does that count? I said, I think so. I mean, you're both done that. Yeah, there you go. It said then there's another sign that said I'm with stupid. No, that doesn't count. But anyway, so let's talk about some of these other expenses. Is there like a list of pre-approved expenses that we get to use for the fighting of covid?

Tyler Bernier, CPA, FHMFA: Unfortunately, there is no pre-approved list, and that would be magical if there ever was one, but there are some there's various guides that are out there and examples of types of expenditures that can be claimed. So I think what many of the dental practices are probably going to see a lot of the stuff you talked about Art and some of them really think back to that March timeframe when everything shut down. What did you do in response to that? Right. Exactly what kind of purchases did you have to make? You probably had to ramp up your personal protective equipment. Now, previously, you probably had some gloves, maybe gowns. There were still some personal protective equipment you purchased on a regular basis. You can't necessarily claim something that you did anyway.

But now you have masks and face shields and all kinds of extra personal equipment. N95 masks. Right. I did not see that previous. So any of those additional purchases all qualify. Air purification machines, like you said, improvements to the air handling systems, HVAC systems. Obviously, we've all known now and even back then we had an inclination that this was an airborne disease. So anything that is preventing the spread from potentially infected person. You know, you mentioned hand sanitizers. Think about coverings on the various items that you have, the additional cleaning materials or cleaning costs. Maybe you had a cleaning crew that came in once a week and now they were coming in daily or twice a day.

And then probably, you know, for some a very significant and often overlooked area is the technology area, you know, computer upgrades. Did you expand your Wi-Fi ability because now you wanted to give your patients the ability to log in from in the parking lot so they didn't have to do that from your office. Are you having them sign in on an iPad? Because that's what I do when I go in now. I get a covered iPad that I got to sign everything in on now instead of actually going and talking to anybody. Tele dentistry, did you expand your services into that new format?

So any of those things where you went from, hey, we did this previously and now we shut down. We had to rethink things. We have to go here. So the sign is a great example because honestly, that should, it's a small thing. Right. But that sign might trigger hey, when I put that sign in, I did like these 50 other things and that adds up.

Art Wiederman, CPA: I know I'm going to get a call after this podcast. So Art if I put up a billboard on the freeway that says wear a mask, does that qualify? I don't know. I mean, it's kind of like my golf score, all HHS Provider Relief Fund reporting applications recorded approximately. That's kind of how it works, right, guys?

Tyler Bernier, CPA, FHMFA: I guess it depends on what the picture you had on the billboard.

Art Wiederman, CPA: They don't want to see my picture. So, OK, so we talked about expenses and we've talked about lost revenues. Now, most of my folks got two percent. So if I have a million dollars practice they get twenty thousand dollars, OK. So maybe they didn't spend twenty thousand dollars. So if the expenses don't cover the full amount that they receive because they got say they got twenty thousand and then in December they got one hundred and fifty. I've gotten I kid you not guys, I've gotten at least five to 10 calls. I got this check for like two hundred and twenty thousand dollars. I said, well then you're buying lunch and where are we going on vacation and all this stuff. Right.

But so how does that work? If, you know, they're not going to spend two hundred and forty thousand dollars on PPE, the N95 masks were expensive at the beginning, but not that expensive. So if the expenses don't cover everything, how does the lost revenue calculation work? We talked a little bit dive a little more into that.

Ashley Brandt-Duda, CPA: Yeah. So we talked a little bit about how. And one thing I wanted to clarify on the lost revenue, too, is, is they're talking just patient service revenue. So if there you have investments that are earning income or perhaps a rental property or something like that, just keep in mind, when we're talking lost revenue, we're talking more of that true patient service revenue.

But as we did talk about the comparison to actual, which I think is going to be the most common within this industry, that that will be utilized where you are looking at that quarterly comparison during your covered period, comparing each quarter to the same quarter in two thousand and nineteen since nineteen is considered to be the base year, or I guess when things were still normal, if you will. But there also are a couple of other comparison that comparisons that dentists should keep in mind if for whatever reason, they're looking at that comparison to actual and it just doesn't seem to make the most sense for them.

You can also utilize the comparison to budget, and that would be if you have an official budget put together and that was done prior to March twenty seventh of twenty twenty if that's something that you utilize in your practice. You could consider doing a quarterly comparison to budget as well. And then there is also this third catch all just because of course HHS can't keep anything too straightforward. There is this third option where you can utilize any reasonable method to calculate your lost revenue. And so I would not encourage a lot of providers to do that if they're able to capture the lost revenue in one of the first two ways that we talked about, because it is more complicated, you have to submit a lot more information regarding the methodology and why and justification for it. But I think certainly something to keep in mind if you're a provider and you're looking at your lost revenue and it's not really coming out how you think it should, that would be one of those where I think you could certainly reach out to us using that email address. And we could certainly help you determine if another method makes more sense.

Art Wiederman, CPA: But the thing that I thought when you talked to me, when you guys talked to me yesterday about this, is that, again, if I have a loss in the quarter, I get to count the loss. If I have an increase in the quarter, comparing quarter of twenty twenty versus twenty nineteen, if I have a gain, I put down zero. That's what you're telling me, right?

Ashley Brandt-Duda, CPA: Yeah. It will calculate in your form. You'll still have to put the revenue for those quarters, but essentially the form will make it a zero. So it'll be net. So yeah absolutely.

Art Wiederman, CPA: So if I have, so I will get credit for quarters that I have that have losses, which is going to be huge because the second quarter is going to cover most all of this, because as I understand it, when they made those phase three, it was intended, I think and correct me if I'm wrong to give the dentist and the other healthcare providers to reimburse them so that they got 88 percent of what they would have had had there not been a pandemic. I think that was the number or something like that. Right. I had heard that maybe.

Tyler Bernier, CPA, FHMFA: It kind of comes out pretty close to that number. That's sort of the idea based on the submissions of data. And of course, luckily what they said was, you know, because when most people submitted, it was already after that fact. Right. So you can always kind of go back and utilize that historical information and probably something we haven't pointed out yet. But the period to use funds really starts at the beginning of the pandemic, regardless of when you receive the dollars. Right. So as we're talking through quarters and things, you know, you're really going back to essentially the beginning of 2020, regardless of when you received it.

Art Wiederman, CPA: Because my dentists got very little money. One thing I did want to mention, I don't know if we're going to. Well, let's go to this next issue. So we talked about lost revenues. And it's something that we've talked about in our planning meetings is that a lot of my dentists who got their phase three money, they didn't get it until January or February of twenty twenty one. So if I have to look at January, if I have to look at twenty twenty one revenues, most of my dentists, I'm doing. You can hear that knock wood, are doing really, really well in twenty, twenty one. OK, they're really, really come back.

So if they don't have lost revenues in twenty twenty one they're going to say Art I got this two hundred thousand dollars in January but my lost revenues were really in twenty twenty which is when I applied for this based on that. How does that work? Is there a carry over? Because that's a big, that's always been a concern of mine.

Ashley Brandt-Duda, CPA: Yes, fortunately, there is. And so along those lines of what Tyler was talking about with the covered period, essentially January 1st of twenty twenty is when the calculations start, regardless of when they received any of these payments. So if you're a dentist and you essentially receive the money in two thousand twenty one, but you had lost revenue for your quarters in twenty twenty, you can absolutely use that for those twenty twenty one payments.

Art Wiederman, CPA: Now the other thing you were we were talking about two guys is that I think you said in our meeting that we, to make it easier if all of this is covered by lost revenues. You still have to report the amount of your PPE in your COVID expenses, but you can only use. Did you guys tell me that you can you can choose to only use lost revenues to cover all of this?

Ashley Brandt-Duda, CPA: You essentially can choose to only use lost revenues to cover. In that case, you would really just enter your expenses at zero and then move forward to the lost revenue calculation. The only thing that providers should keep in mind when they're taking a look at potentially using that approach, is that possibility that Tyler talked about in the beginning of there might be future potential payments that are out there and future funds that dentists might receive, and so the only, I guess, risk, I would say, of using revenue only is if you get through your first reporting period and you don't report those expenses, there is a good chance that you can't come back later and say, OK, now I have these expenses in this previous period. So it's sort of if you already have those expenses tracked and you know that you have them, it's probably better off. You're better off overreporting rather than underreporting, because then that way, if you have those future payments, you can potentially carry the amounts forward and apply to those. So just something to keep in mind.

Art Wiederman, CPA: And because, again, a lot of my doctors say this is a lot of time and do I really have to do this? And my answer to them is, hey, guys, the federal government's given you free money. You got to do a little bit of work for it. So we're going to that's very good advice. So what you're what you guys are saying is even if the lost revenues are covered, we should still put down all of PPE because it might affect future calculations.

OK, so let's talk about when do we have to do. You know, first of all, how much time do we have to spend this money? What are the time frames?

Tyler Bernier, CPA, FHMFA: So the guidance that was released is all tied into when you actually officially receive the payment. So not when you spent it or earned or applied. It was when you cashed the check or when that direct deposit hit your bank account. That's sort of the trigger date, right. So HHS has defined four different periods. The first period is essentially that April 10th, that first magical day for a lot of people through June 30 of twenty twenty. That's reporting period one. You have until June 30th of twenty twenty one, which is already passed to expend all those funds.

The next period, which is probably most of the dentists, at least the first payments they received is if you got the money between July 1st, 2020 and December 31st twenty twenty, you have until December 31st twenty twenty one to spend or support the dollars. So either through those purchases that we've been talking about or lost revenues, who knows that the fall may bring us. Right. Let's hope for the best. Here's some more knocking on wood. Period three just extends out another six months. So those that got the funds in this first half of twenty twenty one that January to June timeframe, you have until June 30th of twenty twenty two now to support it. And then they created a period four which is July 1st through the end of twenty twenty one and you have to the end of twenty twenty two to spend it now.

Now, no dollars that I have seen yet have been distributed in that period. In fact they created this fourth period before July even started. So that's what kind of gives us the expectation, along with the other stimulus bills, that more dollars will be received. The other thing to point out within that period, so I mentioned that deadlines, right? So they basically stagger by six months, starting with June 30th of twenty twenty one and six months thereafter. The beginning period for every single one of those is the beginning of the pandemic regardless of when you receive funds.

Let's say you got one payment in July of twenty twenty and then you've got your phase three payment in January of twenty twenty one. For both of those, the start date is the same, beginning a pandemic. HHS believes that shouldn't be before January 1st of twenty twenty. But then the deadline kind of extends and so that July payment, you know, you really have essentially two years to support it. That January twenty twenty one payment you got you have two and a half years to support it. So it's kind of a staggered period.

So you may actually if you got enough money and either of the periods and we'll talk about this with the reporting in a second, you may also have to report more than once and kind of support these funds and in different ways, which is a little bit complicated and unfortunate that they did it this way, but at least they extended some of the time frames.

Art Wiederman, CPA: So, guys, I'm gonna take a break. I need to go to the bathroom and get some Advil because I have a headache right now listening to you. No, I'm just kidding.

Tyler Bernier, CPA, FHMFA: We haven't even gotten into the fun stuff yet.

Ashley Brandt-Duda, CPA: We did that to you?

Art Wiederman, CPA: You did. And that's why I have no hair and that's the deal. So anyway, so now I know that they were supposed to open this portal up in January and January 15th they opened the portal. They did. They actually opened the portal and they said, put your name in, right? Pretty much.

Tyler Bernier, CPA, FHMFA: Yeah. And an email.

Art Wiederman, CPA: So they were supposed to do that. Now, I remember that we had at that time a new administration coming in. And I don't think they even brought in the new director of HHS until what March or April was it or was it later? I mean, it all got delayed.

Tyler Bernier, CPA, FHMFA: I'm sure that did not help the cause of this program. Yes, there was a definite quiet period.

Art Wiederman, CPA: Yeah, so they came out and by the way, guys, there's a document that came out, maybe talk a second and I don't know if I'm getting ahead of myself here, but on the HHS website, there's frequently asked questions. There's a what a June 11th document, I think that lays out a lot of this pretty nicely.

Tyler Bernier, CPA, FHMFA: Correct. So on the as you said, the HHS.gov website, there is a sub page for provider relief funds that has a ton of information. It talks about all these various distributions, the purpose of them, the calculations behind them, more stuff than you ever want to know or care to know. But there are within the reporting page, there's this June 11th as it sits now reporting guide, which outlines what is expected in this reporting portal that you mentioned, Art, which officially opened on July 1st.

Art Wiederman, CPA: OK, so let's get into the reporting. So when do we have to do it? Do we have to worry about this now? Walk us through that.

Tyler Bernier, CPA, FHMFA: So the reporting essentially starts with this first phase of recipients. So if you receive the money between April 10th and June 30th, so that first initial phase, the reporting portal's open now. And as I mentioned previously, you have until June 30th twenty twenty one to spend it. Every time there's that deadline, just assume the next day the reporting portal opens for you and you have three months to submit your information and get it in.

Unfortunately, there are no extensions. So make sure that you are aware of these deadlines again, three months after the deadline to use the funds. Now, what would have been nice and easy, as you mentioned, I have a number of providers that, you know, in that second quarter was bad. The third quarter, fourth quarter ramped up. They've already supported all their dollars. Right. But they got it in January of twenty twenty one. So does that mean we're going to have to wait until, like, that specific day that's a year from now in order they can in order for them to actually do anything? And unfortunately, it's. Yes.

So if you got money in January of twenty twenty one, let's say, the reporting portal doesn't open for you until July 1st twenty twenty two. So you might be sitting on this information for a lot of time. But thinking about that, imagine a year ago. How much stuff can we remember? I mean I've completely blocked everything out on purpose just because of the stress and chaos. But looking back, there's, you know, it's very difficult. So you have to understand that there's these specific reporting windows, a three month window when you have to get your stuff and you can't do it early and you can't be late.

Art Wiederman, CPA: Well, considering that my doctor told me when I was young that somebody got 80 percent of my brain cells when I was born, it's hard enough to do it as it is. But what is important is, is just like you said, if you got a check for two hundred thousand dollars in January of twenty twenty one, you had best put something on your calendar for, you know, that's July of twenty twenty two for, you know, April for April or May and say guys, we got to deal with this. So this is a big deal.

So most of the folks that listen to this didn't get any money until August, but a lot of them did get money from Medicare and other government programs in, you know, you said to start April 10. So April, May, June. And so if they got, was it ten thousand dollars? This is important because they have to know this for now, correct? They got, how does that work? If they got more than a certain amount of money they have to report now before June 30th.

Tyler Bernier, CPA, FHMFA: Yeah. So each of those four periods I mentioned if you got money in those period, so carve them out, make them all separate. Right. So take period one. If you got over ten thousand dollars and all of your funds during that period, then you have to report. Period two you do the same thing. So let's do an example, quick. Period one provider got two thousand dollars. They got it in June and then July of twenty twenty one they got eight thousand dollars. Right. Well, in that scenario, neither one equals ten thousand dollars in those specific reporting periods, so they don't have to report at all, even though the total was ten thousand. So let's take another example.

Art Wiederman, CPA: Let me stop you. So I got a client. I'm just thinking of this. It's a five million dollar practice and they listen to my podcast. So I know they know who they are. They called me up and it all affected all this. They got a check for like one hundred and forty three dollars in April. Then they got one hundred thousand dollars in August. Does that mean that they have to report as of August. They get their ten thousand as of the second period. Right.

Tyler Bernier, CPA, FHMFA: Perfect. Yes. So again, you carve out each period. So you take that first period on its own. One hundred and forty three dollars, clearly less than ten thousand. Ignore it. Move on. Now you go to the second period, you don't add in that one forty three. You just look at what they got in August. Was it more than ten thousand. Yes.

Another example. Just in case this happens, let's say that you got eight thousand dollars in July. Right. You found out that the dental practices can apply. You applied based on your application. Got like eight thousand. But then you found out about this phase three and you're like, whoa, there's a lot more money. So I'm going to go out and I'm going to submit my application. And it was a magical Christmas because in December I got one hundred and fifty thousand dollars. Right, right.

So now I got eight thousand in July. One hundred and fifty thousand in December. Add those two together because they're in the same period. So even though the eight was less than ten, you add them together and you have one fifty eight. That's what you're reporting on for that period.

Art Wiederman, CPA: So as soon as you go over the ten thousand, whatever period you go over the ten thousand, that's the period you got to start looking at the rules as to when to report.

Tyler Bernier, CPA, FHMFA: Correct.

Art Wiederman, CPA: So what if. We do what Steve Martin, I don't know if you ever heard Steve Martin, his comedy act. They would ask him about filing tax returns. He said, this is what I do with the IRS. Two simple words. I forgot to pay my taxes. So what if we use the Steve Martin method and we just tell HHS a year or two from now, I forgot to file with the HHS. How is that going to work?

Ashley Brandt-Duda, CPA: Well, I mean providers could certainly try that. But they have said that any there are as Tyler mentioned, there are no extensions on the reporting. So when it's due, that's when it's due. And the comment that's been made out there by HHS is that for any reports that are not filed, those payments are subject to full recoupment.

So I don't think it's a road I would want to go down unless you potentially want to have to pay all of the money back at some point. So I think it's very important to make sure you're staying on top of the reporting and getting it done timely.

Art Wiederman, CPA: So here's an important question then I want to get into the what do they have to get ready for? OK, so let's say we go down the road and we say, hmm, that's interesting. I added up all my PPE and all my covid expenses. And then I went through this lost revenue calculation and it comes to be one hundred and eighty thousand, but I got 240. How do they. Is it an issue of they just send in the reporting and someone's going to call them back and say, by the way, you owe us, HHS is going to send you a thing, says you owe 60,000 or do you recognize that you're short? And then do you individually volunteer to send money back? How does that work?

Ashley Brandt-Duda, CPA: Yeah, it essentially will calculate within the report as you work through the process, you have the expenses, you have the lost revenue. It will essentially calculate at the end if you have essentially extra to where you have now spent all of your funds or if you have additional funds that need to be sent back. So that will be calculated as part of the reporting process. And then if you do have funds that you have not spent, those need to be sent back to HHS within 30 days, they'll be providing a mechanism for that.

Art Wiederman, CPA: So when I go on to the portal and I start putting all this information in, are you saying, guys, that at the end when I'm done with all my information, something's going to pop up on the computer screen says red light, red light. You owe us 60,000. Is that how this is going to work or is there going to be like a little Smurf or a Minion? I love the Minions, by the way. Kevin's my favorite.

Ashley Brandt-Duda, CPA: I don't know if they'll make it quite that obvious. There is a summary essentially that is put together at the end where it'll have all of your information summarized. And I think certainly very, very important to go through when it all is said and done and double check that summary against all the information that you've entered, because we all know how technology can be and make sure that something wasn't missed or entered incorrectly. But, yes, it will appear on that summary page. So that's something that providers will want to take a look at very closely. And if it's saying you owe a bunch of money and you don't think you should a whole bunch of money back, that probably means there's just something not right with your reporting.

Art Wiederman, CPA: OK, and then they have 30 days to pay that money back. So one of the messages I think, guys, and this is me commenting, is folks don't spend this money until you do the calculations. I have my client I was talking about earlier, they got four hundred and fifty thousand dollars in December. And they said, well, Art, we really we would like to take it. I said, don't touch that money or I will come and hurt you. Don't touch that money because you might have to give it back. I don't know yet. So do we have enough information from this portal? I know we've talked about that there's a workbook. And is that something Eide Bailly is putting together or is that something HHS.

In other words, if my doctors wanted to right now go through because we're past the June 30 of twenty twenty one, most of these guys have spend their money. Is there a workbook or a spreadsheet or a really smart person or something that can that we can do these calculations now even if we don't have to report until this summer or next summer. For a lot of these guys, if they get the money in January, they're not going to have to report until July a year from now. But they want to know whether they're going to get to keep this money. Is there a mechanism right now or something? Is it something that we're doing at Eide Bailly? Is it something that, how does that work?

Ashley Brandt-Duda, CPA: Yeah, so there is certainly there is a template out there, I guess, for starters that HHS has released and really it's just they plug the numbers in, this is what you are going to need, information that you need to put within the portal when you report. That being said, us at Eide Bailly and our provider relief fund team, we are certainly helping numerous medical providers work through these calculations to help them determine, OK, is this something that we can include? What's our best method for calculating lost revenue, are we going to have any issues claiming these funds? So I say it's a little bit of both. And if you'd like to go it alone, there is a lot of information out there on the HHS website, but we are also here to assist as well.

Art Wiederman, CPA: OK, so let's get into. That's great. All right. The dentists are going to go into this portal. And are they able right now, is that portal open to report? It's got to be because you have until September 30th if you got money in April, May and June. That portal is open. So can we go in and take a look at what is required and what information do our dentists have to get ready to report? What do we have for them?

Ashley Brandt-Duda, CPA: So the portal is open. But really the nuance here is, is along those lines of what Tyler was talking about with the various reporting periods is the portal is open, but if you don't fall into that first reporting period, it will actually calculate if you need to report or not based on the funds that you have received. I actually had a client that that tried to go in early. They were in a later reporting period and it essentially, not booted them out, but it gave them an error message and said, you haven't received ten thousand dollars in this first window, so you don't need to report yet.

So unfortunately, you can't go in early if it's not your window. But there is a lot of general information out there that just tells you what do you need to know and how can you get ready. And so one is, as I mentioned, the Excel template. And then there's also a very extensive, I believe, 70 some page reporting guide out there with all of the details.

But overall, some of the things that dentists should keep in mind that they'll need to report as they move forward. A lot of it there's general demographic information, basic type, things like that. There's also a subsidiary questionnaire. And I don't know how relevant this will be for most dental practices, but at least wanted to bring it up is if you are more than just a stand alone practice, if you have multiple entities involved, you will need to answer some questions and do some things regarding that. So keep that in mind.

You'll also need to report some different personnel, patient facility type of metrics by quarter types of things like your number of full time employees, number of visits that you've had, et cetera. One unique thing you'll have to report is any interest that you've earned on any of your Provider Relief Fund payments. So if you took that money and you listened to Art and you set it aside until you knew you could spend it, but if you did that in an interest bearing account and earned any money, they want to know what money that you that you've earned on that. So you will have to report that number.

You will also have to report any of your other assistance received. So think along the lines of you received a PPP loan, you received a state grant or anything like that. You will need to report all that, all of that money, even though it won't impact your lost revenue calculation. They still want to know about it. And then, of course, the obvious ones that you talked a lot about, you will have to report both those expenses attributable to coronavirus and also the lost revenues.

Art Wiederman, CPA: So, Ashley, are they going to have to submit? It's like with PPP, if you're using the E-Z form and it's over 150,000 loan, you actually have to upload payroll information. You have to upload receipts. Are they going to have to upload every receipt for every N95 mask? How that going to work.

Ashley Brandt-Duda, CPA: Fortunately no.

Art Wiederman, CPA: Yay! There's good news in this? I don't believe it.

Ashley Brandt-Duda, CPA: Yes. So they will not, that information does not all need to be uploaded. But that being said, I would encourage everyone, please don't be complacent and think that that means that I don't need to worry about this documentation. One thing that we're really encouraging providers to do is, as Tyler said, some of this you might be reporting a year, a year and a half later down the line, maybe even two years from when you actually incurred some of these expenses. So really get that documentation in order. Make sure that you're documenting how was this expense used to prevent, prepare for, respond to coronavirus and make sure that you have it set aside for if you should get to provide that information someday down the road, you have it.

Art Wiederman, CPA: OK, so if I've got a doctor and then. I don't know if I missed it, but lost revenues, don't we have to report that by type. So like for the dentists, if they got Medicare or MediCal or something like that, if they got insurance, most of my, many of my dentists have PPO. So if they get payments from insurance companies, we have to break that out separately, right?

Ashley Brandt-Duda, CPA: Correct.

Art Wiederman, CPA: So for the dentist it's mostly going to be insurance and cash. Right.

Ashley Brandt-Duda, CPA: For your patient base, yes.

Art Wiederman, CPA: OK, so what's the break that by quarter for eight quarters, 19 and 20, right?

Ashley Brandt-Duda, CPA: It would be 19 and 20 and then into twenty one as well. Depending on when your reporting period ends, you need to go all the way through.

Art Wiederman, CPA: So if I have a dentist that has multiple offices or corporations or I know that in the ERC and the PPP, there's aggregation rules. Do we have any kind of aggregation rules here?

Tyler Bernier, CPA, FHMFA: I'm not sure there's much for aggregation rules, but as Ashley mentioned, when you register, it does ask you for all of your subsidiaries. And that's essentially any organization that you control all has to get put together, then you can kind of have the choice depending on where the dollars came from. But most dentists are going to be receiving funds under what's called the general distribution. So it's the various phases. Right.

So if you received any of the general distribution funds and you have multiple entities and let's say multiple entities receive dollars, so you might have like one parent company and three separate practices and all three received money, you can actually report it all together as one if you so choose. Or you can do them individually one each. So you do have that flexibility and being able to report separately or aggregated.

Art Wiederman, CPA: So now, from what I understand, guys, it's like filing a tax return. We send in the tax return and we hope and pray it never gets audited. And if it never gets audited, we don't have to worry about it. So first, let's ask, what kind of documentation do our dentists need to keep? And then basically we'll talk about the audit procedures. So what do they need to keep?

Tyler Bernier, CPA, FHMFA: Well, first off, you stole my thunder. That's always my great line it's like a tax return.

Art Wiederman, CPA: Oh, sorry, sorry, sorry.

Tyler Bernier, CPA, FHMFA: OK, so yes, you will never get a stamp of approval. It'll be this lingering cloud hanging over you for years. Like will they ever come look, I don't know. And who will look, that's probably even the scarier question because we're not even sure what that may look like. But what the guidance says is you have a requirement to retain the documentation for at least three years as of the date of your reporting. So once you report, start your clock and then you got three years to keep it.

And as Ashley said, what I would expect that you retain is anything that relates to these funds and that might be invoices. It might be financial records, payroll records, whatever the case may be, whatever supporting the information you're including that three year period, because back to what I said before. I look back a year and I can't remember things. I can't imagine two and a half years later. And I know I've dealt with clients that have gone through this before. When you're that far out and that far removed, you're like, I have no idea what this nine dollars and fifty one cent sign was, it could have said I'm with stupid. Right.

So and granted that I'm not sure anybody is going to be sad for getting nine dollars and fifty one cents taken back, but we don't want any dollars taken back. So three year retention period. And I do want to just point out quick, as we roll through the reporting side, almost every reporting category that you're going to have to go through, whether it be expenses, revenues or there's some statistical data dealing with the number of patients that you see it's all reported by quarter, which is kind of a headache in my mind, but that's how HHS wants it. So everything's got to be broken down by quarter. So even though you might have tracked all your expenses and you have a nice spreadsheet even, you're going to have to try to figure out, OK, when did I actually buy that and then put those into the right quarters.

Art Wiederman, CPA: So is there an audit? And again, I know that, you know, I've been doing taxes for forty five years and I know what an IRS audit looks like and I know what I got to get ready. But this is the wild, wild west. I mean, because we've never done this before. So you guys don't have an idea of what this audit, what an audit is going to look like if there's going to be a, is there anything that they've talked about? This is how we're going to audit this is our procedure, or is that just like. Nope.

Ashley Brandt-Duda, CPA: As far as audits from HHS? No, unfortunately not. So they did not give us a nice set dollar amount and say, OK, you're over this, watch out. We're going to audit you, if you're under, no worries. It's very similar to, Art, like you said, an IRS audit of your tax return. It's we don't know who. We don't know when. So I think just the key there is just to be prepared after you've submitted your report.

Art Wiederman, CPA: Well, I stole Tyler's thunder, so I guess I lost one friend at Eide Bailly. Hopefully not.

Ashley Brandt-Duda, CPA: I'm still your friend, Art.

Art Wiederman, CPA: OK, that's good.

Ashley Brandt-Duda, CPA: You're learning so much today, though, I think we'll try to pull you into the Provider Relief Fund team, so. We'll give Tyler the boot.

Art Wiederman, CPA: Did I tell you, I'm taking the three month golfing vacation from January till March? And then one more thing and then I want to kind of put a big summary on this thing and then we'll wrap this up, because you guys have done an amazing job and laying a very complicated subject out in the better part of an hour. So if a dentist has gotten more than seven hundred and fifty thousand dollars, are there some there some special rules, right?

Ashley Brandt-Duda, CPA: Yeah. So the thing to keep in mind, if you've received over seven hundred and fifty thousand dollars, is that you could be subject to an audit by a CPA firm. So this is separate from when we're talking about HHS can come and audit you and ask for information at any time. So they're essentially are audits out there that are required. Typically, it's if you expend more than seven hundred and fifty thousand dollars in federal funds within any given year. And so this would include if you not only the Provider Relief Funds, but if you received any other federal grants, anything like that as well. Fortunately, PPP is not included, but any other federal grants.

And so where it gets a little funny is because of how they've laid out the Provider Relief Fund reporting, there are going to be some strange cut offs between, it doesn't so much matter when you spent the funds, it's going to matter when you report on them and what that time period is for the seven hundred and fifty thousand.

So I guess the moral of the story on this is if you are a provider and you have received more than seven hundred and fifty thousand dollars of provider relief and other funds, please work very closely with your accountant to determine if a different type of audit is required. So the guidance is not even still all out there yet. It's kind of a very confusing process.

Art Wiederman, CPA: So it may be if a if a dentist got more than 750 in these funds, not counting PPP, thank goodness. OK, but if they got more than this amount of money, they may have to come to a firm like ours and do an actual audit or a review. But you're saying that we're not 100 percent sure quite yet what we have to do, or is that clear?

Ashley Brandt-Duda, CPA: It's not entirely clear. There is some more information that is going to be released, hopefully soon. There's this compliance supplement that comes out for auditors that tells us CPA firms what we need to look at and when and what time frames. And so we have a pretty good idea what's happening and what the time frames and everything will look like. But like I said, it's just one of those areas that if you do fall into that, where you've received a large portion of funds just because of the complex nature around it and the ways that things are changing, I think just work closely with your CPA firm on that to see if qualify.

Art Wiederman, CPA: So if any of you. OK, now what if they own let's say I have one doctor that owns four offices and they got HHS money from all four offices and cumulatively they get more than 750. They fall under these rules, right?

Ashley Brandt-Duda, CPA: Yes. It would be essentially if they fall under there would be consolidated, I guess for financial statement purposes, then you would have to look at it collectively. So, again, that would be a scenario. Get someone involved if you have some of those scenarios going on, because it can get to be pretty complicated determining that.

Art Wiederman, CPA: So the bottom line is that if you got more than 750 in entities that you own, you need to check with your CPA and see if they know what to do. And if they don't, that website again, folks, is PRF@EideBailly.com.

I will tell you that again, you know, we have we worked with I think we're getting close to 900 dentists at Eide Bailly that we're working with. And that's what my life has been. But these two nice folks, they're dealing with hospitals, critical care, nursing homes that have way more complex reporting. So they've been living this nightmare and the audit side, they know. So, guys, if you need help again, just send an email to PRF@EideBailly.com. You can email me also.

So I want to put a bow on this case. And let's just kind of for the dentists, I'm going to just kind of throw out some things and just tell me if I'm right. So if a dentist didn't get more than 10 thousand dollars before June 30th, but they got more than ten thousand dollars between June 30th and the end of December, pretty much their reporting starts January 1st and ends March 31st, is that right?

Ashley Brandt-Duda: Correct.

Art Wiederman, CPA: OK, so guys, it's got more than 10,000. This might be the most important thing we tell you today. If you got more than ten thousand dollars from the HHS Provider Relief Fund between April 10th when they started doling out the money and June 30th, you must report now because this has come out on August 4th. You got till September 30th to do this.

OK, if they got money more than if their cumulative amount, they got their, you know, they got their money in August, they're going to report in January, but then they got money in January. They got two hundred thousand in January of twenty twenty one. But they have to report so they'll have to report from January till April, right until until March for like the first money they got in August to two percent and then the money they got in January. When are they reporting that? That reported in July, right of next year?

Tyler Bernier, CPA, FHMFA: Next July and due in September of twenty twenty two.

Art Wiederman, CPA: OK, so if you got.

Tyler Bernier, CPA, FHMFA: You gotta do both, you can't combine those. So if you did get two of those separate payments, you have to do two separate reports.

Art Wiederman, CPA: So if you got money between July one and December 31, you're going to report, over ten thousand, you're going to report between January and March of twenty twenty two. If you got money, if you got your two sets of money, both in twenty twenty one, you're going to report them all by March thirty one of twenty twenty two and then you'll be done if that's all you get.

If you got money between July one and December thirty one over 10,000 and then you got your phase three payment, your big payment in January, February, you're going to have to do two reportings right guys?

Tyler Bernier, CPA, FHMFA: Correct.

Art Wiederman, CPA: One will be. So I want you to be sure that you understand that. Keep your documentation, OK? You should really not spend this money until you do some computations to determine whether you really think you're going to be able to keep this. The good news is we only have to take negative quarters. So for many of you, your lost revenue in the second quarter may very well cover everything we think maybe we'll have to see. We don't know. So you got to keep track of it.

But as Tyler and Ashley both said, if you guys want to, because you want to make it simple, we all want to make this simple. It's not simple. Don't just put down lost revenues, because if you don't put down your PPE expenses and they come out with more money down the road, guys. Right. Like Ashley, you were saying they might, you know, mess themselves out of getting that money.

Ashley Brandt-Duda, CPA: Correct.

Art Wiederman, CPA: Don't estimate numbers. Don't estimate, don't estimate, don't estimate. Make sure you report. Put it on your calendar. There are no mulligans. There is no I forgot. One little minor thing. This money is taxable, right? Yes?

Tyler Bernier, CPA, FHMFA: Yes. But. With that being said, if the entity itself actually pays the taxes on the funds versus let's say a pass through, the taxes paid are actually qualifying expenditures.

Art Wiederman, CPA: So if I have a C corporation that got this money, they may get some real interesting surprises when they do their twenty twenty one tax returns if they didn't. So that's interesting.

Ashley Brandt-Duda, CPA: That's why we didn't just answer with a yes. We were both thinking how much detail do we want to go into.

Art Wiederman, CPA: I know. Well, call us if I need some help.

Ashley Brandt-Duda, CPA: How much time do we have?

Art Wiederman, CPA: Well, it's my podcast we got as much time as we want. We can talk about golf and fishing and baseball and all that stuff and how CP3 is halfway to the championship, but by the time they hear this, that will be decided. So anyway.

But listen, any final things, you know, what are the next steps? What do we tell our dentists? We've given them a pretty darn good roadmap today of how this works. But what do they need to do? What's the next steps?

Tyler Bernier, CPA, FHMFA: I think you laid a lot of it out perfectly. It is number one, mark your calendars. Be sure you know when you have to report and what those deadlines are because you don't get the mulligan. So why send money back when you can easily support it? So, mark calendars, number one.

Number two, start tracking and figuring out where you're at if you haven't yet. So as we've mentioned, if you actually go on to the portal page, if you've registered, even if you haven't registered, if you go out to the Provider Relief Fund portal page, there are a bunch of resources, but one of them is that Excel document, and that has the ability to basically track all of the information you need to start putting that together, because not only will it put the information that you need in a centralized place, but it gives you an idea of how much of these funds can I actually support, how much can I keep?

You know, just as Art said, don't spend the money until you know you can keep it, because I know money coming out of the pocket is way worse than money going into the pocket. So start tracking information. And then when you run into those complex things, reach out because there will inevitably be lots of questions, concerns, et cetera. So that PRF@EideBailly.com is kind of our email resource just to centralize this, because we know we're going to have thousands of groups going through the same process essentially every six months for the next two years. So trying to put resources in place to help answer or assist even as the situations arise.

And then finally, on that PRF portal page, there is the really long PDF document, and it is titled The PRF Reporting Portal User Guide. That's the seventy three page long document that Ashley referenced. Art, you're shaking your head and I do too. And I'll tell you what, I read it all. It was amazing, wonderful read. Better than Shakespeare.

Art Wiederman, CPA: Do you have any hobbies, by the way. It's PRF. That's right. That's your hobby.

Tyler Bernier, CPA, FHMFA: Basically. So I reference this guide, however, because on pages seven, eight and nine is a detailed list of everything that you're going to need sorry, seven, eight, nine and ten four pages. But it is detailed and bulleted. It seems like that's a lot, but it actually comes down to some very simple information, things like your name, your business name, your address, contact information, your tax ID number or your Social Security number if you're an individual. So those types of things, it gives you a full list of everything that you'll need. So that is probably the next best resource. Is that just detailed list of everything you can consider. So mark your calendars, start tracking, get ready.

Art Wiederman, CPA: Drink heavily. That's what we need to do.

Ashley Brandt-Duda, CPA: Yeah. The other piece that I think is really helpful within that reporting guide is I know as we've been talking today and talking about how important reporting time frames are, we have thrown a lot of dates around and dates and this date and time frames. There is also a chart that shows when you receive the money, when you can, or how long you have to spend it and when your reporting is due. So please, if you didn't catch all of the dates we talked about today, no worries. There are some good charts in the reporting guidelines as well that lay out all of that information.

Art Wiederman, CPA: And the last thing I'll say is that by the time you guys listen to this podcast, I believe that Tyler and Ashley, you will have already done a webinar on all of this. I think you guys have one scheduled. So what you want to do, folks, is check our YouTube page, which is where all these webinars live that just Google Eide Bailly YouTube. You'll get to our page. You can find it. It's pretty easy.

Tyler Bernier, Ashley Brandt-Duda, you guys are wonderful. You are a wealth of information. I call accountants the financial first responders. We really are. I mean, these government programs have saved a lot of our businesses, but, you know, the fact is they don't make it easy. They're not just given the money out. And we all gotta do a little of work to get this money and to keep it and to keep our businesses afloat. So you guys are golden. Thank you so much. Hang on. As I take us out of the podcast.

Folks, I hope this was helpful to you. Really, just listen to what we said. Listen to this podcast. If you have trouble sleeping, listen to this podcast. I'm just kidding. But the point is, is that if you don't do anything and you put your head in the sand on this, you're going to have to write the government a check back. So don't do that.

Be sure to listen to our Decisions in Dentistry. Go to our Decisions in Dentistry Partners website at www.DecisionsinDentistry.com for great clinical content and continuing education courses. And again, they're coming out with a whole bunch of new stuff.

If you haven't filed for forgiveness for your first PPP loan, you better get going on it. You may even be past your time by the time you hear this podcast. If you have a greater than 50 percent reduction in your gross revenues in the second quarter of twenty twenty, whether you file for forgiveness or not, I'm pretty darn certain that if you have more than two or three employees, we can get you a five figure Employee Retention Tax Credit. We're doing it for lots and lots and lots of people. Give me a call. Six five seven two seven nine three to four three. Send me an email at awiederman@EideBailly.com. Check out our website for the ADCPA www.ADCPA.org.

Eide Bailly is we can handle pretty much anything. We've helped a lot of doctors with research and development tax credits. We've helped them with cost segregation studies, financial planning. I think they make steaks and chops too. They do all this kind of stuff. It's amazing what, it's kind of like a dentist. If you've never been to John Coyes or Frank Speare, if you've never been to the Scottsdale Center and you walk in there, it's like a kid in a candy store coming to work with the folks at this firm. For a CPA like me, who's been in my own little cubbyhole in Tustin for thirty three years, it's really, really cool.

With that said, folks, I'm going to put a bow on this and say thank you for listening. Thank you for the honor and privilege of your time. Thank you for all the thousands of people who listen to us every week. It's an honor and privilege to observe the dental profession for close to 40 years. And I'm going to keep doing it as long as they don't kick me off the stage. And my name is Art Wiederman. And this has been the Art of Dental Finance and Management with Art Wiederman, CPA and we'll see you next time.