Executive Insights: Wealth Management

It’s always good to have a solid financial expert in your corner. But when times are challenging and the markets are roiled, it’s even more important. We gathered five wealth management professionals to talk about the latest developments in the industry and get their takes on what investors need to know in the current climate. Business First publisher Lisa Benson moderated the discussion with Joe Reeves, chief executive officer of ARGI; Dean Donohue, chief executive officer of Encore Wealth Management Group; Scott Olinger, CEO of Harding, Shymanski and Co. PSC.; John Gardner, director and market executive Merrill Louisville; and Kellie Sheryak, senior vice president for UBS Financial Services Inc. The participants paid for a seat at the table for this discussion.

Click here to read the full article published by Lousiville Business First.

CARES Act Provider Relief Fund Regulatory Alert: HHS CARES Act Grant Funding Attestation Portal Now Open

The Portal for attestation of receipt and acceptance of the Provider Relief funds authorized under the CARES act is now open. Providers that received a payment from HHS as part of the Provider Relief Fund authorized under the CARES Act must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions within 30 days of receiving payment.

HHS has set up the web page portal which can be found by clicking this link.

To complete the attestation, providers and medical practices must provide their Taxpayer Identification Number (Either EIN or SSN) that is attached to the enrolled providers for whom the attestation is being sought. The provider will be asked to verify the amount received as part of this process prior to signing the attestation.

Should you choose to reject the funds, you must also complete the attestation to indicate this choice. The Portal will guide you through the attestation process to accept or reject the funds.

It is advised that providers fully understand the terms and conditions of the funding before signing the attestation.

Since the release of the first phase of money from the Provider Relief Fund last Friday (4/10) many providers have been raising questions about these funds. CMS staff have informed us that they are creating a FAQ page for the Provider Relief fund which they will be posting soon. The FAQs should  respond to the questions that have been raised such as:

  • What should a provider do if he/she feels the amount of money they’ve received is incorrect – too high or too low?
  • What should a provide do if he/she did not receive a payment but believes they are entitled to a payment? CMS said they intend to have more information about the Provide Relief Program posted this week on the Provider Relief web page.
CMS has also established the Provider Relief Payment Hotline for providers with questions to call. The hotline number is (866) 569-3522

More to come as information becomes available.

Please contact Brenda Wallace, CPA, CMPE at bwallace@hsccpa.com for more information.

SBA Stops Accepting PPP Loan Applications – Funding Runs Out

The U.S. Small Business Administration stopped accepting applications for the Paycheck Protection Program after exhausting the initial $349 billion in funding provided by Congress to fund forgivable loans to small businesses impacted by the COVID-19 pandemic.

The SBA, which is administrating the program with Treasury, posted a statement on its website saying that it is currently unable to accept new PPP applications based on available appropriations funding. The SBA also said it is unable to enroll new PPP lenders at this time.
The AICPA issued a news release urging Congress to swiftly approve additional funding for the program.

“The need for quick and decisive action by Congress is clear,” the AICPA release says. “Small businesses are the nation’s economic engine, and supporting and stabilizing them is essential to our economic recovery.”
The $2 trillion Coronavirus Aid, Relief, and Economic Security (CARES) Act, P.L. 116-136, established the PPP to provide up to $349 billion in forgivable loans that businesses with 500 or fewer employees could use to cover payroll, mortgage interest, rent, and utilities. Congress authorized the Treasury and the SBA to spearhead the PPP process as an extension of the SBA’s 7(a) loan program.

Small businesses have flooded SBA-approved lenders with PPP requests since the application window opened April 3. Lenders and the SBA have struggled to keep up with the demand as small businesses seek desperately needed help in an economy stymied by restrictions imposed to slow the spread of the novel coronavirus that caused COVID-19.

“This program was rolled out with remarkable speed, and while there have been some bumps along the way, small businesses view the Paycheck Protection Program as a critical lifeline,” said AICPA President and CEO Barry Melancon, CPA, CGMA, in the Institute’s news release. “We need to extend that support so we can protect workers and ensure our economy can rebound quickly once restrictions are lifted.”

The SBA has approved more than 1.6 million loans submitted by nearly 5,000 lenders. That has accounted for more than 14 years’ worth of loans in less than 14 days, according to a joint statement  issued Wednesday night by Treasury Secretary Steven Mnuchin and SBA Administrator Jovita Carranza. Mnuchin and Carranza also urged Congress to approve $250 billion in additional funding.

“We urge Congress to appropriate additional funds for the Paycheck Protection Program – a critical and overwhelmingly bipartisan program – at which point we will once again be able to process loan applications, issue loan numbers, and protect millions more paychecks,” the joint statement said.

The U.S. economy has lost 22 million jobs over the past four weeks, according to unemployment benefits claim data released Thursday by the U.S. Department of Labor.

Originally published by Jeff Drew, Senior Editor, JofA on April 16, 2020.

Please contact Scott Touro, MBA at stouro@hsccpa.com for more information.

CARES Act Provider Relief Fund 

If you received payment as part of the Provider Relief Funding provision of the CARES Act, please become familiar with the terms of the funding.  Below is a link to the ten page attestation agreement that contains the terms for retaining all or part of the funds you received.  While the funding is a grant, not a loan, there are certain requirements that must be met.  We are working closely with the HBMA, who is in turn working closely with HHS to develop a Q & A to more clearly define the terms of the funding.

  • Terms & Conditions for acceptance and retention of all or part of the funds are detailed in the agreement which can be read in full at this link: Terms and Conditions – PDF. The terms and conditions on this document are numerous and there is subsequent reporting that will be required of the provider accepting these funds.
  • 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.
  • Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The portal for signing the attestation will be open the week of April 13, 2020. Not returning the payment within 30 days of receipt will be viewed as acceptance of the Terms and Conditions.
  • If a provider receives payment and does not wish to comply with these Terms and Conditions, the provider must do the following: Contact HHS within 30 days of receipt of payment and then remit the full payment to HHS as instructed. Appropriate contact information will be provided soon.

More to come as information becomes available.

Please contact Brenda Wallace, CPA, CMPE at bwallace@hsccpa.com for more information.

Updated Guidance on PPP Loans

The Small Business Administration released an additional Interim Final Rule yesterday that provides guidance on a couple of key areas of uncertainty around the Paycheck Protection Program (PPP).

  • The new guidance discusses loan amounts and loan forgiveness calculations for individuals with self-employment income (with and without employees).
  • Additionally, the guidance clarifies that the self-employment income of general partners may be reported as a payroll cost, up to $100,000 annualized, on a PPP application filed by or on behalf of the partnership (and LLC filing taxes as a partnership).

You’ll find the new guidance here.

Please contact Scott Touro, MBA at stouro@hsccpa.com for more information.

How The CARES Act Affects Employer-Sponsored Benefits 

By now, most employers have presumably read up on the basic tax relief and financial assistance aspects of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. What you may not have heard much about is how the law affects employer-sponsored benefit plans. Here are some highlights of its impact:

Coverage mandates. Under the Families First Coronavirus Response Act, an earlier law passed in response to the outbreak, health insurers and group health plans were required to cover coronavirus (COVID-19) testing and related provider visits without cost-sharing. The CARES Act has extended this requirement to additional categories of COVID-19 tests – even if not FDA-approved.

Health plans and insurers must reimburse the diagnostic testing provider according to any negotiated rate with the provider, or they must pay the provider’s publicized cash price for the diagnostic test in the absence of a negotiated rate. Health insurers and group health plans will have to cover, without cost-sharing, COVID-19 preventive services and immunizations that receive specified recommendations from the CDC’s United States Preventive Services Task Force. This requirement will apply 15 business days after the task force’s recommendation.

Telehealth exemption for high-deductible health plans (HDHPs). A safe harbor allows HDHPs to cover telehealth and other remote care services without a deductible for plan years beginning on or before December 31, 2021. This provision is effective March 27, 2020, the date of the law’s enactment.

Over-the-counter (OTC) drugs and certain other products. The CARES Act removes the prescription requirement for OTC drug reimbursements that previously applied to:

  • Health Flexible Spending Arrangements,
  • Health Reimbursement Arrangements,
  • Health Savings Accounts (HSAs), and
  • Other accident and health plans.

In addition, menstrual care products now qualify as medical care for purposes of reimbursement or tax-free distribution. These changes generally apply to expenses incurred after December 31, 2019; however, in the case of HSAs, they apply to amounts paid after that date. (As of this writing, there’s no expiration date.)

HIPAA privacy. The CARES Act aligns the Federal Confidentiality of Alcohol and Drug Abuse Patient Records Act with privacy rules under the Health Insurance Portability and Accountability Act (HIPAA). That is, the law generally allows disclosure and redisclosure of covered records for treatment, payment or health care operations to the extent permitted by HIPAA after a patient provides initial written consent. The U.S. Department of Health and Human Services (HHS) has been instructed to update its regulations and issue guidance regarding this change.

ERISA deadlines. The law adds public health emergencies declared by HHS to the list of events permitting the U.S. Department of Labor to delay, for up to one year, deadlines under the Employee Retirement Income Security Act (ERISA). Examples include deadlines for filing claims or appeals under a plan’s internal claims procedures.

Employers may need to immediately adjust their benefits administration systems to the many changes occurring because of the COVID-19 emergency. Contact us for help understanding how the CARES Act, or any other actions in response to the pandemic, may affect your organization.

Please contact Matt Folz, CPA at mfolz@hsccpa.com for more information.

IRS Provides Filing Relief for Form 5500 Filings Due Before July 15, 2020

The IRS issued Notice 2020-23 which provides additional filing relief for taxpayers affected by the ongoing Coronavirus pandemic. The IRS relief includes Form 5500, Annual Return/Report of Employee Benefit Plan, due to be filed (originally or pursuant to a valid extension) on or after April 1, 2020 and before July 15, 2020. With the relief the due date for filing is July 15, 2020. The relief is automatic and taxpayers do not have to call the IRS or file extension forms or send letters or other documents to receive this relief. Additional filing extensions beyond July 15 must be requested using the appropriate extension form by July 15, but the extension may not go beyond the original or regulatory extension date. The IRS filing relief for Form 5500 comes through Rev. Proc. 2018-58 . Notice 2020-23 states that Specified Time Sensitive Actions are covered and refers taxpayers to Rev. Proc. 2018-58 which explicitly includes Form 5500. This immediate relief does not extend to calendar year 2019 Form 5500 filings originally due July 31, 2020. The EBPAQC will continue to advocate for and monitor filing relief from the IRS and DOL, and will communicate to members any additional relief notices.

Please contact Paul Esche, CPA, CCIFP, CCA at pesche@hsccpa.com for more information.

IRS Releases Q&A on Payroll Tax Deferral Program – Clarifies When it Can Be Used In Relation to PPP Loan Forgiveness Program

The Coronavirus, Aid, Relief and Economic Security Act (CARES Act) allows employers to defer the deposit and payment of the employer’s share of social security taxes and self-employed individuals to defer payment of certain self-employment taxes.  These FAQs address specific issues related to the deferral of deposit and payment of these employment taxes.

These FAQs will be updated to address additional questions as they arise.

Please contact Matt Folz, CPA at mfolz@hsccpa.com or Scott Touro, MBA at stouro@hsccpa.com with any questions.

Webinar – Paycheck Protection Program Loans – Act II Maximizing Forgiveness |Maintaining Compliance

If you have applied for or received a Paycheck Protection Program Loan, you will soon be faced with the second act. . . maintaining compliance and maximizing forgiveness.  Join this special webcast presented by our COVID-19 Fast Response Team members to learn about how the forgiveness calculations work, what still needs to be explained in the regulations, and how to maintain compliance with your PPP Loan.

Date: Thursday, April 16th

Time: 12:00 CT/1:00 ET

REGISTER HERE

Space is limited – first come, first served.

CARES Act Provider Relief Fund

President Trump is providing support to healthcare providers fighting the COVID-19 pandemic. On March 27, 2020, the President signed the bipartisan CARES Act that provides $100 billion in relief funds to hospitals and other healthcare providers on the front lines of the coronavirus response. This funding will be used to support healthcare-related expenses or lost revenue attributable to COVID-19 and to ensure uninsured Americans can get testing and treatment for COVID-19.

Immediate infusion of $30 billion into healthcare system
Recognizing the importance of delivering funds in a fast and transparent manner, $30 billion is being distributed immediately – with payments arriving via direct deposit beginning April 10, 2020 – to eligible providers throughout the American healthcare system. These are payments, not loans, to healthcare providers, and will not need to be repaid.

Who is eligible for initial $30 billion?

  • All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for this initial rapid distribution.
  • Payments to practices that are part of larger medical groups will be sent to the group’s central billing office.
    • All relief payments are made to the billing organization according to its Taxpayer Identification Number (TIN).
  • As a condition to receiving these funds, 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.
  • This quick dispersal of funds will provide relief to both providers in areas heavily impacted by the COVID-19 pandemic and those providers who are struggling to keep their doors open due to healthy patients delaying care and cancelled elective services.
How are payment distributions determined?
  • Providers will be distributed a portion of the initial $30 billion based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019.
  • 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.
  • As an example: A community hospital billed Medicare FFS $121 million in 2019. To determine how much they would receive, use this equation:
    • $121,000,000/$484,000,000,000 x $30,000,000,000 = $7,500,000
What to do if you are an eligible provider?
  • HHS has partnered with UnitedHealth Group (UHG) to provide rapid payment to providers eligible for the distribution of the initial $30 billion in funds.
  • Providers will be paid via Automated Clearing House account information on file with UHG or the Centers for Medicare & Medicaid Services (CMS).
    • The automatic payments will come to providers via Optum Bank with “HHSPAYMENT” as the payment description.
    • Providers who normally receive a paper check for reimbursement from CMS, will receive a paper check in the mail for this payment as well, within the next few weeks.
  • Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The portal for signing the attestation will be open the week of April 13, 2020, and will be linked on this page.
  • HHS’ payment of this initial tranche of funds is conditioned on the healthcare provider’s acceptance of the Terms and Conditions – PDF, which acceptance must occur within 30 days of receipt of payment.  If a provider receives payment and does not wish to comply with these Terms and Conditions, the provider must do the following: contact HHS within 30 days of receipt of payment and then remit the full payment to HHS as instructed.  Appropriate contact information will be provided soon.

Is this different than the CMS Accelerated and Advance Payment Program?

Yes. The CMS Accelerated and Advance Payment Program has delivered billions of dollars to healthcare providers to help ensure providers and suppliers have the resources needed to combat the pandemic. The CMS accelerated and advance payments are a loan that providers must pay back. Read more information from CMS.

How this applies to different types of providers?

All relief payments are being made to providers and according to their tax identification number (TIN). For example:

  • Large Organizations and Health Systems: Large Organizations will receive relief payments for each of their billing TINs that bill Medicare. Each organization should look to the part of their organization that bills Medicare to identify details on Medicare payments for 2019 or to identify the accounts where they should expect relief payments.
  • Employed Physicians: Employed physicians should not expect to receive an individual payment directly. The employer organization will receive the relief payment as the billing organization.
  • Physicians in a Group Practice: Individual physicians and providers in a group practice are unlikely to receive individual payments directly, as the group practice will receive the relief fund payment as the billing organization. Providers should look to the part of their organization that bills Medicare to identify details on Medicare payments for 2019 or to identify the accounts where they should expect relief payments.
  • Solo Practitioners: Solo practitioners who bill Medicare will receive a payment under the TIN used to bill Medicare.

Please contact Brenda Wallace, CPA, CMPE at bwallace@hsccpa.com for more information.