On July 10, 2020 the US Department of Health and Human Services (HHS) announced that dentists may now apply for the financial assistance through the Enhanced Provider Relief Fund Payment Portal.1 Although the Provider Relief Fund was initially only made available to hospitals and other healthcare providers directly responding to COVID-19, subsequent decisions by HHS have increased the eligibility requirement to a broader series of providers.
HHS has developed a list of dental practice taxpayer identification numbers (TINs) from third-party sources and HHS datasets to help support payments to dental providers who may not bill Medicare or Medicaid. When a dental provider applies, the first step of the application process is to validate that their TIN is on the curated list. Any eligible dental providers not on the list will undergo further review and, if validated, will be permitted to apply for funding.2
Providers with TINs on the curated list must not be excluded from receiving federal payments and must meet the following requirements:
- The dental provider must not have received payment from the initial $50 billion Medicare-focused general distribution; and
- Must not have received payment from the $15 billion Medicaid and CHIP distribution; and
- Must have either (i) filed a federal income tax return for the fiscal years of 2017, 2018, or 2019 or (ii) be an entity exempt from the requirement to file a federal income tax return and have no beneficial owner that is required to file a federal income tax return (e.g. a state-owned hospital or healthcare clinic); and
- Must have provided patient dental care after January 31, 2020; and
- Must not have permanently ceased providing patient dental care directly or indirectly through included subsidiaries; and
- If the applicant is an individual, have gross receipts or sales from providing patient dental care reported on Form 1040, Schedule C, Line 1, excluding income reported on a W-2 as a (statutory) employee.3
In addition to inclusion on the list, not being excluded from receiving federal payments and meeting the above six eligibility requirements, dental providers must also ensure they are not:
- Terminated from participation in Medicare or precluded from receiving payment through Medicare Advantage or Part D;
- Must not be excluded from participation in Medicare, Medicaid, and other federal healthcare programs; and
- Must not currently have Medicare billing privileges revoked.4
Payments for dental providers will be determined on 2% of (revenues * percent of revenues from patient care) for the most recent tax filing reported by the applicant with accompanying submitted tax documentation.
Applying dental providers will need to upload the following documentation to the Enhanced Provider Relief Fund Payment Portal:
- The applicant’s most recent federal income tax return for 2017, 2018, or 2019. A written statement explaining why the applicant is exempt from filing a federal income tax return may be submitted in place of these documents (e.g., a state-owned hospital or healthcare clinic).
- The applicant’s Employer’s Quarterly Federal Tax Return on IRS Form 941 for Q1 2020, Employer’s Annual Federal Unemployment (FUTA) Tax Return on IRS Form 940, or a statement explaining why the applicant is not required to submit either form (e.g. no employees).
- The applicant’s FTE worksheet (provided by HHS).
- If required by Field 15, the applicant’s Gross Revenue Worksheet (provided by HHS). 5
It is important to note that if a dental provider was approved for their initial Medicare-focused General Distribution of Medicaid and CHIP General Distribution Payment, they are ineligible for an additional payment at this time. These providers may be eligible for future distributions of the Provider Relief Fund.
The deadline to submit an application is July 24, 2020. Dental providers can apply through the Enhanced Provider Relief Fund Payment Portal found at: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html.
Readers should not act upon information presented without individual professional consultation.
Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.