Edition #14
April 13, 2020
HSC COVID-19 Fast Response Team
We are here to help!

In these uncertain times with multimedia channels reporting conflicting and sometimes incorrect information, our firm is working to add clarity to this situation by providing new and verified information as it becomes available to us. We have also set up a Coronavirus Resource Center on our website for ongoing information. 

In addition, we have created the HSC COVID-19 Fast Response Team to serve our clients in addressing the difficult decisions they are being faced with on a daily basis. This dedicated multi-disciplinary team consists of our tax, payroll, HR, capital markets and accounting professionals. 

If you have questions or would like to speak with this team please contact your HSC team member or Kyle Wininger, CPA, CICA, CVA, CFE at kwininger@hsccpa.com
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

Space is limited - first come, first served.

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.
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.
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.
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Disclaimer: The information contained in this email is for general guidance on matters of interest only. The publication does not, and is not, intended to provide legal, tax or accounting advice.  
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