Is the deadline to report on period 1 still September 30, 2021?

The United States Department of Health and Human Services (HHS) continues to encourage doctors to report use of funds by Sept. 30, 2021, for period 1. However, HHS has put into place a 60-day grace period (Oct. 1-Nov. 30) to allow for additional time to complete reporting for period 1, if needed.

Are there additional opportunities to receive relief funds?

Yes, HHS announced new relief funding opportunities that will be available later in September 2021.

I need step-by-step help on how to report.

Review AOA’s webinar on reporting.

How do I know when I need to report?

For reporting purposes, you will just need to look at when you received the relief and identify when to report at hrsa.gov/provider-relief/reporting-auditing.

I sold my practice in December 2020, do I need to return HHS relief funds I received in April 2020?

HHS has provided some information about situations when practices are sold. They have indicated that all recipients will be required to substantiate that funds were used for health care-related expenses or lost revenues attributable to coronavirus up to the date of the sale, and to also ensure that those expenses or losses were not reimbursed from other sources and other sources were not obligated to reimburse them. If a doctor used the funds for acceptable uses prior to the sale, the doctor should report that information The FAQs address these situations at hhs.gov/sites/default/files/provider-relief-fund-general-distribution-faqs.pdf.

What is the maximum salary that can be paid with HHS relief funds?

HHS indicates, “The Terms and Conditions state that none of the funds appropriated in this title shall be used to pay the salary of an individual, through a grant or other mechanism, at a rate in excess of Executive Level II. The salary limitation is based upon the Executive Level II of the Federal Executive Pay Scale. Effective Jan. 5, 2020, the Executive Level II salary is $197,300. For the purposes of the salary limitation, the direct salary is exclusive of fringe benefits and indirect costs. The limitation only applies to the rate of pay charged to provider Sept. 14, 2021, Relief Fund payments and other HHS awards. An organization receiving Provider Relief Funds may pay an individual's salary amount in excess of the salary cap with non-federal funds.”

This limit includes staff and owners.

Is it allowable to use Paycheck Protection Program funds and HHS provider relief funds during the same period of time?

You can use PPP funds and HHS provider relief funds during the same time period, but the funds must be used for different purposes. For example, you could use PPP funds to pay payroll for June, July and August 2020, and you could use HHS provide relief funds to pay for personal protective equipment and rent during June, July and August.

In reporting on use of PRF funds, should doctors include loans received through the Small Business Administration Economic injury disaster loans as “other assistance.” These loans have to be repaid.

HHS has indicated if the EIDL loan is forgiven, that amount would be considered a revenue source. Based on this guidance, our interpretation is that if your EIDL loan was not forgiven and was a standard loan, it would not count as a revenue source.

Can you clarify the HHS frequently asked question from Oct. 20, 2020, regarding glasses and contact lens sales?

On Oct. 20, 2020, HHS posted a frequently asked question clarification about the sale of glasses and contact lenses. It’s new clarification indicates that your calculations of revenue or expenses related to the sale of prescription glasses or contacts may not be included in your reports. They further clarify that only patient care revenues from providing health care services in a medical setting, at home, or in the community may be included. This would mean that when reporting your revenue or expenses to HHS, you should only report revenue from services rendered and not from product sales like glasses and contact lenses. HHS would expect your good-faith effort in your attempts to most accurately reflect your revenue and expense reporting.

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