CARES Act Grants Healthcare Companies Provider Relief Fund Payments

The Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law on March 27, 2020, providing $100 billion in relief funds to hospitals and healthcare providers on the front lines of the coronavirus response, amongst other provisions.

The CARES Act created the Provider Relief Fund, which reimburses healthcare providers for lost revenues and increased expenses due to the COVID-19 pandemic. The funds are being distributed by the Health Resources Service Administration (HRSA) section of the U.S. Department of Health and Human Services (HHS).

Through this program, $50 billion in funds is available for general distribution and the remaining $50 billion for targeted distribution. These payments are grants, not loans, and will not need to be repaid if certain terms and conditions are met. A complete list of the terms and conditions for Provider Relief Fund distributions can be found on the HHS website.

General Distribution Qualifications

To be eligible for the general distribution, a healthcare provider must have billed Medicare in 2019 and provided diagnosis, testing, or care to individuals with possible or actual cases of COVID-19 after January 31, 2020. Some healthcare providers may have already received a payment from HRSA as $30 billion was distributed prior to April 24, 2020. These funds were paid in proportion to the healthcare provider’s Medicare fee for service reimbursements in 2019.

These initial payments did not require an application nor engagement activity, however, within 30 days of receiving the funds, the provider must sign an attestation confirming receipt and agreeing to the terms and conditions of payment. Should a provider choose to reject the payment, they must also complete the attestation to indicate this. If the payment is not returned within 30 days of receipt it will be processed as accepted, and in turn, the terms and conditions will be viewed as accepted as well.

For those that received general distribution payments prior to April 24, 2020, a CARES Act Provider Relief Fund Application Portal has been deployed by HHS to collect information from healthcare providers. There are four pieces of information needed to allocate the remaining general distribution funds, which can be found on the HHS website.

The remaining $20 billion of the general distribution began dispersal on April 24, 2020, ensuring the program properly allocates each healthcare providers’ share proportionally based on its 2018 net patient revenue. 

Targeted Distribution Qualifications

The CARES Act also provides $50 billion for targeted distributions to:

• Hospitals disproportionately impacted by COVID-19
• Healthcare providers who treated the uninsured with COVID-19
• Rural providers
• Indian healthcare service providers
• Other healthcare providers such as skilled nursing facilities and other Medicaid providers

Eligibility details and application instructions for these distributions can be found on the HHS website along with additional information regarding the CARES Act Provider Relief Fund. Alternatively, this information is available via the CARES Provider Relief line at (866) 569-3522. 

If you have any questions regarding the CARES Act or need assistance with the application, please reach out via email, give us a call at (401) 921-2000, or fill out our online contact us form.

For additional information, please visit our COVID-19 Resources page.

Expanded Unemployment Benefits for the Self-Employed and Others

The U.S. Department of Labor recently announced the publication of the Unemployment Insurance Program Letter (UIPL) providing guidance to states for implementation of the Pandemic Unemployment Assistance (PUA) program, a provision under Section 2102 of the Coronavirus Aid, Relief, and Economic Security Act (CARES). Pandemic Unemployment Assistance provides temporary “unemployment” assistance to those individuals not traditionally eligible for unemployment benefits, and affected by COVID-19, including the self-employed, independent contractors, and gig workers. 

Eligibility

Eligibility appears very broad. Section 2102 provides for payment of PUA to “covered individuals,” defined as individuals not qualified for regular unemployment compensation, extended benefits under state or federal law, or Pandemic Emergency Unemployment Compensation (PEUC), including those who have exhausted all rights to such benefits. Individuals seeking part-time employment, individuals lacking sufficient work history, or those otherwise not qualified for regular UC, extended benefits under state or federal law, or PEUC  are also included. For purposes of PUA coverage, an individual “lacking sufficient work history” means an individual (1) with a recent attachment to the labor force (2) who does not have sufficient wages in covered employment during the last 18 months to establish a claim under regular UC, and (3) who became unemployed or partially unemployed because of one of the COVID-19 related reasons identified under Section 2102. 

Examples of Inability to Work

Under Section 2102, reasons for an inability to work include:

• The individual has been diagnosed with COVID-19 or is experiencing symptoms of COVID-19 and seeking a medical diagnosis; 
• The individual is providing care for a family member or member of the individual’s household who has been diagnosed with COVID-19; 
• A child or other person in the household for which the individual has primary caregiving responsibility is unable to attend school or another facility that is closed as a direct result of the COVID-19 public health emergency and such school or facility care is required for the individual to work; 
• The individual is unable to reach the place of employment because of a quarantine imposed as a direct result of the COVID-19 public health emergency; 
• The individual’s place of employment is closed as a direct result of the COVID-19 public health emergency.

A qualified individual’s benefit equals the amount the person would have otherwise received under state law plus $600. Section 2102, however, explicitly excludes from coverage individuals who can work remotely with pay and individuals who are receiving paid sick leave or other benefits (even if they would otherwise qualify for unemployment under the CARES Act).

Further Information

The process for applying for these benefits will vary from state to state. For more information on whether you may qualify for Section 2102 benefits, and how to apply, please contact the Rhode Island Department of Labor and Training or the Massachusetts Department of Unemployment Assistance.

If you have any questions, please reach out via e-mail, give us a call at (401) 921-2000, or fill out our online contact us form.

For more information on COVID-19 and to get the latest updates, visit our COVID-19 Resources page.

While challenging times can bring out the best in people, there are also individuals who view these times as opportunities to prey on those most vulnerable by trying to steal money, identities or both. The novel coronavirus (COVID-19) pandemic has caused significant disruption to both domestic and international economies and led governments to impose various forms of social, travel, and work restrictions. As a result, there are many people in our communities that are experiencing significant financial hardship. The Coronavirus Aid, Relief, and Economic Security (CARES) Act was recently signed into law and is designed to bring assistance to those in need. 

One of the items included in the CARES Act is a direct stimulus payment (economic impact payment) to individuals, married couples, and children who qualify. The CARES Act provides direct payments of up to $1,200 for single filers and $2,400 for married couples filing jointly, plus $500 for each child under 17. Children who are, or can be, claimed as dependents by their parents aren’t eligible individuals even if they have to file a return. Income limits apply, for single filers the phase-out range begins at an adjusted gross income of $75,000 and completely phases out at $99,000. For married couples the phase-out range begins at $150,000 of adjusted gross income and completely phases out at $198,000. 2019 tax returns, if they have been filed, will be used to determine eligibility. If a 2019 tax return has not been filed yet, the payment will be based on the 2018 return. This means that taxpayers who receive a smaller payment than they are eligible for based on 2020 income will receive the difference after filing a 2020 tax return, but overpayments due to a higher income in 2020 are not expected to be due back.

This provision provides relief for individuals and families who are struggling financially right now, however, the desire to receive this money quicker leaves people vulnerable to scammers. By keeping the following in mind, you can protect yourself, and those you care about, from falling victim to fraud:

The federal government will NOT contact you. Federal offices will NOT contact individuals directly via phone, email, or text to verify personal or bank information. If someone contacts you claiming additional information is necessary to process your economic impact payment, immediately cease communications and report the number or email address.

There is not a faster way to get the economic impact payment. If someone claims they can expedite your check, know that this is a scam. Currently, the payments are expected to go out in the next three weeks. 

You do not need to pay anything! There are no processing fees involved in receiving your economic impact payment. If anyone contacts you regarding a small fee to authorize the payment, know that it is a scam.

Communicate directly with the IRS. If you’d like to set up a direct deposit of your stimulus payment, communicate only with the IRS directly. The United States Department of the Treasury plans to develop a web-based portal for individuals to provide their banking information to the IRS online, which will streamline distribution. If your bank information was already provided to the IRS on your 2018 or 2019 tax return, no further action will be required. If the federal government does not have your bank information, they will send a hard check to your home address.

No need to sign up or file a simple tax return. Social Security recipients who are not required to file an income tax return will not need to file a simple tax return to receive a payment. Rather, the economic impact payments will be automatically deposited into your bank account, as is the case with the normal monthly payments received.

Watch out for fake checks! Some people have reported the receipt of economic impact checks in the mail for odd amounts, including ones with cents. It is going to take the United States Department of the Treasury a few weeks to mail out hard checks, so if you receive one too early, it is likely a scam. Also, these early, fake checks may ask you to verify the check online or by calling a certain number; these are signs of a scam!

If you do identify any coronavirus-related scams, you should report them to the Federal Trade Commission.

Hopefully, the information above will provide you with the awareness and information that you need to avoid falling victim to a scam related to the economic impact payments. We are all in this together, and together we will make it through this stronger than ever. If you have any questions related to the economic impact payments and/or the CARES Act, our team of professionals stands ready to assist you. Please give us a call at (401) 921-2000, or fill out our online contact us form.

For more information on COVID-19 and to get the latest updates, visit our COVID-19 Resources page.

Like many others, your company has likely transitioned many of its staff members to a work-from-home model. This is a good time to remind everyone to be diligent in checking for potential malware and online scams. While many people are adjusting to working from home for the first time, they are also being asked to homeschool children or care for elderly family members. This distracting environment makes it easy for employees to inadvertently click a bugged link or document, thereby introducing malware or ransomware into your systems.

Recently, we’ve seen reports of the following phishing scams:

• Fake coronavirus maps and websites – there have been numerous attempts of malware on sites that offer fake maps of the spread of the virus. We recommend you only use trusted news sources like CDC.gov.
• False ads for masks and protective gear – again feeding on people’s fears, scammers are pushing malware or phishing for personal information through sites claiming to have protective gear for sale. We recommend shopping local, or through a known online retailer.

COVID-19 has already caused countless interruptions to our daily lives, but we urge you to mitigate additional long-term business disruptions by offering your employees frequent reminders about these online risks.

For additional information about coronavirus scams, please reference the FTC’s consumer information page. If you have any concerns regarding your company’s finances, please contact us.

For more information on COVID-19 and to get the latest updates, visit our COVID-19 Resources page.

Resources Available to Help Your Business and Family

As you’ve probably noticed, more and more businesses are temporarily closing their doors each day. Some of them working remotely, some providing free shipping options, and others just closing completely for the time being. With all of the uncertainties surrounding COVID-19, chances are you and your business are feeling the impact as well. You can rest assured that government agencies are hard at work creating programs to provide support to ease the burden on businesses, individuals, and the economy.

Here are some of the resources currently available:

1. For when you need to make a plan – The Rhode Island Society of Certified Public Accountants (RISCPA) knows how critical it is for businesses to prepare for the future, especially as we don’t know how severe COVID-19’s impact will be. Refer to their COVID-19 Business Planning Checklist to make sure your business is ready, here.
2. For when COVID-19 has taken a bite out of your revenues – The U.S. Small Business Administration (SBA) is offering low-interest federal disaster loans up to $2 million. These loans can be used to help meet financial obligations and operating expenses that would have been met had the disaster not occurred. This SBA assistance is available in the entire state of Rhode Island and the counties of Bristol, Norfolk, and Worcester in Massachusetts. Visit SBA.gov/disaster to confirm eligibility and start the loan process.
3. For when your employees are unable to work due to a public health emergency – The Families First Coronavirus Response Act was signed on March 18, 2020 and takes effect on April 2, 2020. The Act provides the following provisions:
   1. Emergency Family and Medical Leave Act (FMLA) Expansion
   2. Emergency Paid Sick Leave Act
   3. Employer Tax Credits for Paid Sick and Paid Family and Medical Leave

For more specific details on the provisions under the Families First Coronavirus Response Act, see our recent email update.

4. For when your business is working remotely – Microsoft is providing six months of its Office 365 tools for free to enable remote collaboration, file sharing, and video conferencing. Access this free service, here.
5. For when you’re out of work due to COVID-19 – The Rhode Island Department of Labor and Training (DLT) is processing COVID-19 related unemployment insurance claims faster and more generously. Visit their website for more details on how to apply.
6. For when your child’s school is closed – “Grab and Go” meals are available for children at various sites throughout Rhode Island. There are no ID or residency requirements, but the child must be present; schools cannot give a meal to an adult on behalf of a child. Click here for a list of food sites and their respective hours.
7. For when your child is completing their schoolwork in a remote environment – Cox Communications is offering its low-cost internet service to families that don’t have an internet connection at home for free for the first 30 days. They are also partnering with PCs for People to allow families to purchase discounted, refurbished computers. Click here for more information.
8. For when your accountant’s office has temporarily closed – On Friday, March 20, 2020, the IRS issued Notice 2020-18, which automatically extends the filing and payment due date for Federal income tax returns from April 15 until July 15th for Affected Taxpayers. This notice only provides relief for Federal income tax returns and Federal income tax payments. For information on state income tax filing and income tax payment deadlines and extensions see the American Institute of Certified Public Accountants (AICPA) State Filing Relief Chart for Coronavirus, here.

DiSanto, Priest & Co. is still open! Although we are working remotely, we are still here to support you with all your business needs. Please reach out, just as you always have, via e-mail, give us a call us at (401) 921-2000, or fill out our online contact us form.

For more information on COVID-19 and to get the latest updates, visit our COVID-19 Resources page.

Any successful company motivated to grow its sales volume should first focus on the existing relationships it has worked so hard to build. As a best practice, companies should leverage and revitalize current areas of business before tapping resources to develop new product lines and expand selling opportunities in existing markets.

In Inc.com’s article, 7 Powerful Strategies for Strong Sales Growth, Drew Greenblatt advocates for increasing efforts with current clients first, “All the systems are set up. The team knows how to make it right. Stick to your knitting and grow market share in what you do best already.…exploit this foundational portion of your business to get the easiest quickest sales.” 

See below for how your company can handle existing business in different ways, leading to growth opportunities and an overall stronger customer base.

Become more customer-centric than market-oriented. 

Approach client management and new revenue development as separate functions. Understand your client portfolio, strategize new engagement opportunities, and direct resources accordingly. Nurturing these existing relationships can also give way to lucrative cross-selling and upselling opportunities. Appreciate that customers within the same industry may have unique needs and purchasing criteria, and create individualized sales plans for each customer. 

Embrace the digital economy. 

Networking and maintaining relationships used to mean face-to-face meetings with current and prospective customers, but nowadays, the internet is the mainstream transaction tool. It is integral to building and nurturing customer relationships, generating sustainable growth, and promoting brand awareness. Invest in a well-coded website to increase your Google search ranking and “inbound marketing” opportunities – make it responsive, mobile-friendly, and easy for customers to access the information they need. Use social media and email marketing to broaden your digital reach, take advantage of direct customer access, and keep buyers engaged.  

Expand your existing product range with complementary goods or services that meet your customer needs. 

To expand within your existing market, a competitive scope grows revenue while increasing the value you provide your customers. While this may seem like a large undertaking, you can readily implement this strategy by outsourcing to other companies that are willing to produce under your brand name. Outsourcing minimizes production investments, allows your firm to focus on its core mission, provides autonomy in choosing suppliers, and creates access to current technologies.

Boosting flat-lined sales can be challenging, but these strategies employ relatively modest investments that build on pre-existing, successful relationships. The strategies all support one main goal: to communicate to target customers that your firm is committed and has the bandwidth to address their growing needs. For more information on how your company could benefit from these recommendations, contact us. Follow us on LinkedIn for more industry insight on growing your business.

Despite continuous sector growth, it remains no secret that industries across the board are currently facing a wide range of challenges impacting their bottom lines. For private business owners, skyrocketing expenses, skilled-labor shortages, and recent changes to the tax laws may lessen their ability to effectively compete within the marketplace. Many industries face similar barriers in achieving sustainability and financial success, therefore opportunities to optimize cost savings and increase earnings potential are ever important. For this reason, there has never been a better time for businesses to determine their eligibility for the employment-based Work Opportunity Tax Credit (WOTC).

Established in 1996, the WOTC is one of the most widely used federal tax incentives to date. The purpose of the WOTC is two-fold, in that both employers and employees can benefit. First, the WOTC aims to encourage businesses to hire from designated target groups within the workforce. Upon hiring these specific individuals, the employers receive compensation by means of a reduction in income tax liability. By reducing your tax rate, your business could benefit tremendously from reduced costs and surplus cash flows. Of equal importance is the WOTC’s solution of leveraging hourly-wage and entry-level individuals who are well equipped and openly available to fill the workforce shortage, which effectively solves two issues simultaneously.

The WOTC also benefits the individual employees comprising the 14 target groups published by the Department of Labor. Typically, the individuals within these groups are under-employed, such as disabled veterans, seasonal workers, or homeless community members. Besides the obvious benefit of gaining employment, the WOTC assists employees by building confidence, reducing their reliance on federal aid, and learning new skill sets. By incentivizing the employment of target groups, the WOTC provides greater opportunities for quality jobs which otherwise may not be obtainable.

Although the WOTC may sound like a complex undertaking, the benefits it produces are undeniable. The first step for a business in any industry is to speak with a tax professional and determine eligibility. In an economy where prices continue to rise, pressure to meet demands grows, and the workforce needed to get the job done is dwindling, determining your eligibility for the WOTC is definitely worth the call.

Please contact us at (401) 921-2000 or email John Rainone at jrainone@disantopriest.com to learn more.

The Federal Reserve’s incremental adjustments to interest rates in the past year have manufacturers reconsidering how to address capital investment needs. Multiple factors can affect whether a company chooses to lease or buy – the return on investment, cash flows, and the productive life of the asset. Generally, the cost of capital is at the top of the list. The low cost of borrowing money over the past ten years tipped the scale toward choosing to borrow and purchase, rather than lease equipment. However, with the prime rate now at 5.0, the choice has become a little murkier. Locking in a borrowing rate now for anticipated purchases over the next year is one short-term solution for which there is generally a premium attached. Even under circumstances where a business has the cash to make capital purchases outright, it may still make better business sense to consider fair market value (FMV) leasing. 

There are a variety of benefits of FMV leasing in today’s market:

• Avoiding the burden of asset obsolescence: This benefit is most apparent when considering purchases of technology and software. Life cycles for these assets typically fall within a 3-year range, which generally coincides with their leasing periods. Upgrades are a natural progression in a leasing program, and in some cases, can be made before leases expire, depending on the agreement.
• Improved cash flow and liquidity: While the purchase of a capital asset requires payment or a significant down-payments and fees upon delivery, lease payments typically begin after the equipment is operational. Without committing to a significant cash outlay, the company can direct cash towards investments in its business versus its infrastructure. 
• Flexibility: Generally, the lessee has options to purchase some or all leased equipment at termination; therefore, taking the risk out of committing to a purchase at the onset.  Leased assets are quicker to obtain and tend to be more flexible than equipment loans giving a business the perspective that time brings into the final decision.

GAAP’s new lease accounting standards, Accounting Standards Update (ASU) 2016-02, have added a new metric, further blurring the lines between owned and leased assets from an accounting perspective. The standards, effective by 2020, re-characterize leasing arrangements whereby a lessee’s contractual access to leased property represents an asset, and the related future obligation to pay for that right is debt. Owned and leased assets will basically tell lenders and vendors the same story about your business; removing the advantage of one over the other from a business reporting stance. (See more about ASU 2016-02 at DiSanto, Priest & Co.’s blog, THE NEW LEASE ACCOUNTING RULES – JANUARY 2020 IS NOT THAT FAR AWAY).

If you’d like to discuss a strategy that would best suit your company’s capital investment needs, please contact us.

The recent outcome of the Sullivan v. Sleepy’s LLC et al. civil case, and the Massachusetts Supreme Judicial Court’s (SJC’s) interpretation of the Mass General Laws has clarified how employers are required to pay commissioned retail employees. 

On May 8, 2019, the SJC issued a unanimous opinion that, under Massachusetts law, salespeople who are paid solely on draws and commissions are entitled to separate and additional overtime and Sunday pay. Prior to the SJC’s decision, retailers had been hanging their hat on two opinion letters issued by the Massachusetts Department of Labor Standards (DLS) over ten years ago that suggested employers did not need to make separate and additional overtime and Sunday payments to 100% commission employees, provided that the employees receive an amount equal to at least 1.5 times the minimum wage for all overtime and Sunday hours worked. 

The SJC’s decision has marked the end of paying non-exempt, retail employees on a commission-only basis in Massachusetts. State law entitles these employees to separate and additional overtime payments, beyond draws and commissions, of at least 1.5 times the Massachusetts minimum wage (currently at $12.00/hour); and premium pay for Sunday work, also equal to no less than 1.5 times the minimum wage. The court also explained that employers are barred from retro-actively repurposing, or renaming, draw and commission payments as overtime or Sunday payments.

The SJC’s decision is already impacting Massachusetts retailers and other companies that pay on 100% commission/draw basis. Now that it’s clear that draws and commissions cannot substitute for other wage and hourly entitlements such as overtime and Sunday pay, employers must carefully examine their pay policies to ensure compliance. Additionally, they are now obliged to recalculate and pay the amounts their employees are entitled to in overtime pay before a lawsuit is filed — failure to do so could have a significant financial impact. Under the Massachusetts Wage Act, sales people not paid for the shortfall prior to filing suit are entitled to automatic treble damages plus attorney fees. 

For more information regarding the most recent developments in Massachusetts Overtime Statute and the implications it may have on your business, please contact us.

For over 100 years, attorneys and CPA’s have worked side by side. Few professions share such a long-standing working alliance for the good of their clients.  So, how similar are we?

• Both professions are made up of a highly educated and skilled workforce.
• Both professions have very strict education and testing requirements to gain entrance.
• Both professions are highly respected and trusted by their clients and the community.
• Both professions form deep, long-lasting personal relationships with their clients – sometimes lasting generations.
• Lastly, both professions are facing short- and long-term partner succession challenges.

Like all businesses and professions, those in senior leadership roles are not getting any younger. With over 7,000 people turning 65 every day, the challenges for succession planning have never been greater. While the statistics vary, a large percentage of equity partners in both law firms and accounting firms will be eligible to retire in the upcoming years – and many already have.

It is no surprise that the impact of retiring equity partners in both professions will be great. The so-called “brain drain”, decreased interest by future equity partners, and client relationship transitions will all lead to a “perfect storm” of leadership transition difficulties for firms specializing in both professions. For many firms, there is also the tendency to be nearsighted as they struggle with the day-to-day operational challenges that come with working in client services. So what can firms do now?

• Senior partners need to be transparent and realistic about their retirement plans (assuming there are no agreements requiring mandatory retirement).
• Firms must train future leaders not only in technical skills, but also in relationship management, business development, general firm operations, and leadership skills.
• Firm leaders must champion the process, embrace its realities, and celebrate its opportunities.
• Senior partners need to “push work down” and delegate partner responsibilities early.
• Senior partners should share and introduce their professional networks to others, often and early.
• Firms need to track and plan financially for future partner retirements and the resulting financial obligations over the next 5 to 10 year period (at minimum).
• Firms need to evolve their compensation models to encourage transition over a period of years, not months.

None of these goals can be accomplished quickly. Employee and client loyalty are the top priorities to keeping a firm sustainable, able to meet its retirement obligations, as well as providing for the future benefit of its emerging leaders. Those future leaders, however, need to know what is in front of them – so transparency is critical.

At DiSanto Priest & Co., we have counseled many professional firms on succession planning. In fact, our own succession plan is always front and center in all of our partner discussions. We have successfully retired many partners over the last ten years and continually plan for future successions to follow. Click here to learn more.