By Amy Brisson, CLC Partner/Consultant
The Federal government passed a new $900 billion COVID relief package on Sunday, December 27 entitled the Consolidated Appropriations Act. Included in this bill are a few items that may have an impact on FQHCs.
PPP Funds - Additional PPP funds have been approved allowing for a second round of PPP loans for businesses that already received a loan and that meet the new eligibility requirements. Applicants must have fewer than 300 employees and show a 25% reduction of revenue from at least one quarter of 2020 as compared to the same quarter in 2019. The loans for second-time borrowers are capped at $2 million. The SBA has released the Interim Final Rule related to second-time loans, however there has not been any updates to the FAQs nor a revised application released. The Interim Final Rule can be found here: https://www.sba.gov/sites/default/files/2021-01/PPP%20--%20IFR%20--%20Second%20Draw%20Loans%20(1.6.2021).pdf?utm_medium=email&utm_source=govdelivery
Provider relief fund (PRF) changes - Included in this relief package are additional funds to the PRF program and the language in the bill restores the lost revenue calculation guidance from June of 2020. The latest FAQs on HHS’s website for the PRF are dated 12/28/20 but did not address any changes to the lost revenue calculation. Keep your eye out for added guidance coming: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/provider-relief-fund-general-info/index.html
As a reminder the first report to HHS for PRF funds will be due on February 15, 2021. The reporting portal will open on January 15, 2021.
On Dec. 11, 2020, HHS released a one-pager that gives examples of allowable expenses for these funds. Find it here: https://www.hhs.gov/sites/default/files/allowable-expenses-one-pager.pdfhttps://www.sba.gov/sites/default/files/2021-01/PPP%20--%20IFR%20--%20Second%20Draw%20Loans%20(1.6.2021).pdf?utm_medium=email&utm_source=govdelivery