Edition #8
March 30, 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
Delay in Payment of Required Contributions to Single-Employer Pension Plans 

Ten Percent Tax on Early Distributions
The 10% tax that generally applies to distributions prior to age 59-1/2 from tax qualified retirement plans will not apply to any Coronavirus-related distribution, assuming this does not exceed $100,000. Amounts can be re-contributed back to the qualified plan within a three year time frame.  

Qualified Plan Loans
A participant who would be eligible to receive a Coronavirus-related distribution from a tax qualified plan may receive plan loans in an amount not to exceed the lesser of $100,000 100% of the participant's vested account balance. Also, a participant who has an outstanding plan loan or obtains a plan loan may defer any payments otherwise until December 31, 2020.
Temporary Waiver of Required Minimum Distributions
The required minimum distribution requirements for individuals over 70 ½ will not apply to qualified retirement plans for 2020.
Plan Amendments
Employers are not required to adopt plan amendments prior to making these changes, rather they will have at least through the last day of the plan year ending 2022.
Delay in Payment of Required Contributions to Single-Employer Pension Plans
The due date for minimum required contributions to single-employer defined benefit pension plans that would be due during calendar year 2020 is now January 1, 2021.
For more information, contact Paul Esche, CPA, CCIFP CCA at pesche@hsccpa.com
DOL Released Additional Guidance on Interpretation of Families First Coronavirus Act 

The U.S. Department of Labor will continue to provide compliance assistance to employers and employees in the form of Frequently Asked Questions on their responsibilities and rights under the FFCRA. 

These required posters issued by the Department of Labor are required to be posted.

Click here to read about the Families First Coronavirus Response Act and to obtain some helpful flowcharts regarding the Act.
Business Aid: COVID-19 

RSM US has provided a helpful overview of the aid available to businesses related to 
COVID- 19. 

Please contact our COVID-19 Fast Response Team for any questions you may have at 
Employee Retention Tax Credit for Employers Subject to Closure Due to COVID-19

The CARES Act provides for a credit against old age, survivors and disability insurance (OASDI) taxes or Tier 1 Railroad Retirement excise taxes for businesses to use to offset the effects of COVID-19 related business issues. The credit will be available to all qualified employers that either had to suspend operations or had a significant drop in gross receipts in an applicable credit quarter.
Specifically, the credit applies to :

(1) Any employer who was carrying on a trade or business in calendar year 2020 that was suspended due to orders from an 'appropriate government authority' limiting commerce, travel, or group meetings due to COVID-19; OR

(2) any employer who during the period: 1) beginning with the first calendar quarter after 2019 in which it experienced a 50% or greater reduction in gross receipts in that quarter when compared against the gross receipts of the same quarter in the prior year; and 2) ending with the subsequent quarter (to which the credit was claimed) in which it had gross receipts greater than 80% of the gross receipts in the same quarter of the previous calendar year. Non-profits might also qualify for this credit under the suspension of operations rules.
This credit is generally allowed for 50% of qualified wages for each qualified employee. Qualified wages are generally any wages paid to employees during shutdowns caused by COVID-19, or in a quarter with a significant decrease in gross receipts as described above.

For companies with employees greater than 100, the employee must not be working because of either a suspension in operations or substantial drop in gross receipts. For companies with less than 100 employees, the wages must be paid because of a suspension in operations, or wages paid with respect to a quarter of significant drop in gross receipts. The important distinction is that companies with less than 100 employees will be allowed to claim the credit for wages paid to employees during an applicable quarter whether or not the business is operating. 

The qualified wages include health care plan expenses that are allocable to wages in a group health plan (excluded from income of employees under section 106(a)). However, the qualified wages cannot exceed $10,000, or the amount the employee would have been paid for an equivalent time during the 30 preceding days. Qualified wages also cannot include any wages considered in the   Families First Coronavirus Response Act (FFCRA)

This credit applies to offset employment taxes after they are reduced by credits for employment of qualified veterans, research expenses for qualified small businesses, and the payroll credits for either qualified required paid sick leave or required paid family leave under the FFCRA. Any amount in excess of these limitations is refundable under sections 6401(a) and 6413(b), and treated as other refunds under section 1324. The credit does not apply to government employers, and can be elected out of by an employer. The employer must also exclude an employee if such employee is included in a work opportunity tax credit, and the employer cannot use wages used to compute the paid family and medical leave credit enacted in the 2017 Tax Cuts and Jobs Act. Finally, an employer is not eligible if they are taking a small business interruption loan.

For more information, please read   RSM'S article, or contact John Rittichier at jrittichier@hsccpa.com or Mike Vogel at mvogel@hsccpa.com for additional information.
Practice Relief Options in CARES Act

According to the Healthcare Business Management Association (HBMA) there are a couple of provisions in the law that will be of interest to healthcare providers.

"1. Healthcare Provider "lost revenue/ increased cost" Grants
The CARES Act establishes a $100 Billion Grant Fund exclusively for healthcare providers who are enrolled in the Medicare and Medicaid program. The purpose of this fund is to provide grants to practices that have experienced a reduction in revenue or an unexpected increase in costs due to the COVID-19 pandemic. The money will be available during the period of the national emergency.
Many healthcare providers have reported that they have seen a significant drop in revenue because of a drop in patient volume. Patients are concerned about coming into the office - even for routine visits. Similarly, many "elective" non-essential surgeries have been canceled leaving surgeons and anesthesiologists without income. These are not just Medicare patients, but Medicaid and commercially insured patients as well. Consequently, cash flow for many healthcare providers is a serious problem.
The Healthcare Provider Lost Revenue Grant program is intended to provide medical practices with an infusion of money that will help replace the money lost due to reduced patient volume because of the COVID-19 pandemic.
The Department of Health and Human Services (HHS) is currently working on a formula to determine how to calculate a provider's lost revenue. This is lost revenue whether it is reduced volume for Medicare, Medicaid, or commercially insured patients.
It may take a week to 10 days for CMS to have all of the necessary applications in place to get the money flowing but these grants could be critically important for healthcare providers that are experiencing a revenue decline due to COVID-19.
More on this as it becomes available.
2. Medicare Advanced Payments
The Coronavirus Aid, Relief, and Economic Security (CARES) Act authorizes CMS to expand the current Accelerated and Advance Payment Program to a broader group of Medicare healthcare providers and suppliers. The expansion of this program is only for the duration of the public health emergency.
An accelerated/advance payment is a payment intended to provide necessary funds when there is a disruption in claims submission and/or claims processing.
CMS is authorized to provide accelerated or advance payments during the period of the public health emergency to any Medicare provider/supplier who meets the required qualifications (see below) and who submits a request to the appropriate Medicare Administrative Contractor (MAC).
To qualify for advance/accelerated payments the provider/supplier must:
  1. Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider/supplier request form,
  2. Not be in bankruptcy,
  3. Not be under active medical review or program integrity investigation, and
  4. Not have any outstanding delinquent Medicare overpayments.
Healthcare providers seeking an advanced Medicare payment can request a specific amount using a form available on each Medicare Administrative Contractor's website. Most healthcare providers will be able to request up to 100% of the Medicare payment amount for a three-month period. The provider can continue to submit claims as usual after the issuance of the accelerated or advance payment
Repayment of the advanced payments will commence 120 days after the date of issuance of the payment and providers will have 210 days from the date of the accelerated or advance payment was made to repay the balance.
At the end of the 120-day period, the recoupment process will begin and every claim submitted by the provider will automatically be offset from the new claims to repay the advanced payment. Thus, instead of receiving payment for newly submitted claims, your outstanding advance payment balance is reduced by the claim payment amount.
For a more detailed explanation of this initiative, you can review the CMS  Advanced Payment Fact Sheet.
For more information and to get a copy of the form to request an advanced payment, go to your Medicare Administrative Contractor's website or call your MACs Corona Virus Hotline:
CGS Administrators - Jurisdiction 15
The toll-free Hotline Telephone Number: 1-855-769-9920
Hours of Operation: 7:00 AM- 4:00 PM
First Coast Service Options Inc. - Jurisdiction N
The toll-free Hotline Telephone Number: 1-855-247-8428
Hours of Operation: 8:30 AM - 4:00 PM
National Government Services (NGS) - Jurisdiction 6 & Jurisdiction K
The toll-free Hotline Telephone Number: 1-888-802-3898
Hours of Operation: 8:00 AM - 4:00 PM
Novitas Solutions, Inc. - Jurisdiction H & Jurisdiction L
The toll-free Hotline Telephone Number: 1-855-247-8428
Hours of Operation: 8:30 AM - 4:00 PM
Noridian Healthcare Solutions - Jurisdiction E & Jurisdiction F
The toll-free Hotline Telephone Number: 1-866-575-4067
Hours of Operation: 8:00 AM - 6:00 PM
Palmetto GBA - Jurisdiction J & Jurisdiction M
The toll-free Hotline Telephone Number: 1-833-820-6138
Hours of Operation: 8:30 AM - 5:00 PM
Wisconsin Physician Services (WPS) - Jurisdiction 5 & Jurisdiction 8
The toll-free Hotline Telephone Number: 1-844-209-2567
Hours of Operation: 7:00 AM - 4:00 PM"

For more information or for any questions, please contact Brenda Wallace at bwallace@hsccpa.com.

*Used with permission from Healthcare Business Management Association
Copyright © 2020 The Healthcare Business Management Association (HBMA), All rights reserved.
Virtual National Small Business Town Hall Hosted by Inc. with the U.S. Chamber of Commerce.

Watch a virtual National Small Business Town Hall hosted by Inc. with the U.S. Chamber of Commerce to learn how to get what your company needs from the CARES Act.
RSM Coronavirus Webcasts

RSM Coronavirus Webcast Series

RSM has launched a weekly webcast series on issues related to the Coronavirus. The webcasts are approximately one hour, each Wednesday at 1:00 p.m. EDT.

Dates and times are below:
Wednesday, April 1, 2020 - 1:00 p.m EDTmust have been 
Wednesday, April 8, 2020 - 1:00 p.m. EDT

Free webcast, no CPE will be provided. 

Click here to register.
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