South Carolina Medical Group Management Association

PPP Loan Forgiveness- Where to Start?

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Valued Friends and Clients of WebsterRogers,

Since the PPP Loan Forgiveness Application was released on Friday, we have spent time going through the calculations.  The 11-page document with instructions can seem a bit overwhelming at first, so we thought we’d walk you through our ideas on a good place to start relative to loan forgiveness.  If you plan to ultimately pursue loan forgiveness and want ideas on what you can do now, two items we believe you should focus on first are:

  1. Determine if you will use the “Covered Period” or the “Alternative Payroll Covered Period” to calculate eligible payroll costs over the 8-weeks. 
  2. Calculate your Full-Time Equivalencies (FTEs) and Payroll benchmarks that you will want to match during your covered period to avoid a forgiveness reduction (if you don’t qualify for the Safe Harbor). 

In this email we will walk you through both of these.

“Covered Period” vs “Alternative Payroll Covered Period”

To create “administrative convenience” for borrowers with biweekly (or more frequent) payroll, the PPP loan forgiveness application provides an option for borrowers to use an "Alternative Payroll Covered Period.”  This period begins on the first day of a borrower’s first pay period following the PPP Loan Disbursement Date, instead of having the first day of the 8-week covered payroll period occur in the middle of a pay period.  Using the alternative period should help companies ensure that they have a full 8 weeks of payroll costs eligible for forgiveness per the rules in the application.    We believe most businesses will want to adopt the “alternative payroll covered period” for calculating their payroll costs over the 8 weeks.

Important: If this Alternative Payroll Covered Period is used, it only applies to payroll costs.  The 8-week covered period for qualified nonpayroll expenses still begins the date a borrower receives the funds.

Consideration:  Payroll costs incurred but not paid during the Borrower’s last pay period of the 8-week covered period are eligible for forgiveness if paid on or before the next regular payroll date.  Based on our reading of this, you cannot have two pay periods outside of the covered period to pay for salary or wages incurred during the 8-week covered period.  Therefore, it is important for borrowers to consider now any “lag” in their payroll and whether or not all of the incurred pay during the 8-week covered period will be paid on the next regular payroll after the end of the 8 weeks.  In the event there is a payroll lag between incurred and paid where incurred pay at the end of the 8 weeks would not normally be paid for two payroll periods after the covered period, a borrower should move any pay incurred during the covered period forward to the first pay period after the 8 weeks.  Working with your payroll provider to address this is important.

Calculating Your Forgiveness Payroll and FTE Benchmarks

As a reminder, borrowers will have PPP loan forgiveness reduced if:

  1. “the salary or hourly wages of certain employees during the Covered Period or the Alternative Payroll Covered Period was less than during the period from January 1, 2020 to March 31, 2020.”*
  2. “average weekly number of FTE employees during the Covered Period or the Alternative Payroll Covered Period was less than during the Borrower’s chosen reference period.”*

*Note:  there are Safe Harbors related to these reductions where, if the borrower qualifies, FTEs and wages can be restored to Feb. 15, 2020 levels to avoid any forgiveness reductions.  These safe harbor situations and calculations are not addressed in this email. 

Calculating Compensation Benchmarks for each Salary Employee

For salaried employees, the compensation benchmark is each employee’s annualized salary paid in Q1.  Take the salary paid to each employee between January 1, 2020 and March 31, 2020 (Q1) and multiply times 4 to get the annualized salary. 

Important:  Salaried employees that received compensation at an annualized rate of more than $100,000 for any pay period in 2019 are excluded from this calculation.  You do not need to run this calculation for those employees. 

Example 

Employee A is a salaried employee who was paid $14,000 between Jan. 1 and March 31, 2020.

Employee B is a salaried employee who was paid $9,500 between Jan. 1 and March 31, 2020.

Calculation:

Employee A        $14,000 x 4 = $56,000

Salary Benchmark for Employee A is $56,000

Employee B        $9,500 x 4 = $38,000

Salary Benchmark for Employee B is $38,000       

Calculating Compensation Benchmarks for Each Hourly Employee

For hourly employees, the benchmark is the average hourly wage paid to each employee between January 1, 2020 and March 31, 2020 (Q1).  A simple method to make this calculation is to take the total amount paid to each hourly employee during Q1 and divide by the total hours that employee worked during Q1. 

Example 

Employee C is an hourly employee who was paid $16,000 between Jan. 1 and March 31, 2020 and worked a total of 540 hours during that time period.

Employee D is an hourly employee who was paid $10,500 between Jan. 1 and March 31, 2020 and worked a total of 510 hours during that time period.

Calculation:

Employee C        $16,000 ÷ 540 = $29.63

Hourly Wage Benchmark for Employee C is $29.63

Employee D        $10,500 ÷ 510 = $20.59

Hourly Wage Benchmark for Employee D is $20.59

*Note:  Compensation is cash compensation paid to the employee as gross wage, bonus, and commissions. 

Calculating FTE Benchmark

The full-time equivalency (FTE) benchmark is your average weekly FTE during the period of either (1) February 15, 2019 to June 30, 2019, (2) January 1, 2020 to February 20, 2020, or (3) in the case of seasonal employers, either of the preceding periods or a consecutive twelve-week period between May 1, 2019 and September 15, 2019.  The time period used is up to the Borrower.  To make the calculation, determine the average number of hours paid per week for each employee during the selected time period.  Divide these average hours paid by 40 and round the total to the nearest tenth.  The maximum for each employee is capped at 1.0.  A simplified method option was provided in the loan forgiveness application which allows a borrower  to assign a 1.0 FTE for employees who are paid an average of 40 hours or more per week, and 0.5 FTE for employees who are paid fewer than an average of 40 hours per week during the selected period.  Whether to use the simplified method or not is at the election of the Borrower.  Once you have the FTE calculation for each employee, add them all up to get your FTE benchmark for the covered period.

Example (for this example we will use a selected period of January 1 – February 29, 2020)

Employee A was paid an average of 47 hours per week Jan 1 – Feb 29, 2020

Employee B was paid an average of 40 hours per week Jan 1 – Feb 29, 2020

Employee C was paid an average of 34 hours per week Jan 1 – Feb 29, 2020

Employee D was paid an average of 13 hours per week Jan 1 – Feb 29, 2020

Calculations:

Employee A        47 ÷ 40 = 1.175

Employee A Average FTE = 1.0

Employee B        40 ÷ 40 = 1.0

Employee B Average FTE = 1.0

               

Employee C        34 ÷ 40 = 0.85

Employee C Average FTE = 0.9

Employee D        13 ÷ 40 = 0.325

Employee D Average FTE = 0.3

FTE Benchmark = 1.0 + 1.0 + 0.9 + 0.3 = 3.2 FTE

The borrower’s total average FTE for the period is 3.2

Simplified Method (avg hours per week ≥ 40 = 1.0 FTE, avg hours per week < 40 = 0.5 FTE)

Employee A Average FTE = 1.0

Employee B Average FTE = 1.0

Employee C Average FTE = 0.5

Employee D Average FTE = 0.5

FTE Benchmark = 1.0 + 1.0 + 0.5 + 0.5 = 3.0 FTE

The borrower’s total average FTE for the period using the simplified method is 3.0

This table illustrates these calculations.

Since there are options for how these calculations are made, it may be best to run your benchmark calculations several ways to help you choose the best compensation period and FTE calculation method for your company. 

Just to reiterate, the first step before calculating these benchmarks is to ensure that your payroll cycles coordinate with your covered period selection so that it includes a full 8 weeks of payroll eligible for forgiveness. 

We will be following up with another email detailing the safe harbor options.

If you need assistance with your loan tracking or you would like to discuss your situation relative to PPP loan forgiveness, we are here to help.  Reach out to your WR Partner or you relationship manager.  You can also email our COVID-19 task force for assistance:  This email address is being protected from spambots. You need JavaScript enabled to view it..

In case you missed any of our previous updates, you can find them all posted on the News Updates page of our website.

Check out our Resource Library for online video content.

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As a reminder, you are receiving this email because you are a valued client of WebsterRogers  For more information about our firm, please visit our website.

 

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Regulatory Alert

MGMA
April 16, 2020
 
 
Regulatory alert: HHS CARES Act grant funding Attestation Portal now open
 
The Attestation Portal for the initial $30 billion general distribution from the Department of Health & Human Services (HHS) is now open. Providers that received a payment from HHS as part of the Provider Relief Fund authorized under the CARES Act must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions within 30 days of receiving payment.
 
To complete the attestation, billing entities must provide their Taxpayer Identification Number. Should you choose to reject the funds, you must also complete the attestation to indicate this. The Portal will guide you through the attestation process to accept or reject the funds.
 
Group practices with questions about the grant funds can call the Provider Relief hotline at (866) 569-3522. Please note that the terms and conditions are subject to further clarification by HHS, and MGMA will pass along any additional guidance if it is made available.
 
 
 
 
 
 
 
 
Stay Updated!
 
Visit the MGMA COVID-19 Action Center for the latest developments impacting medical practices
 
 
Questions?
 
Contact MGMA Government Affairs by emailing This email address is being protected from spambots. You need JavaScript enabled to view it. or calling 202.293.3450, 877.275.6462 toll-free
 
 
 
 
 

MGMA Regulatory Alert

MGMA
April 10, 2020
 
 
Regulatory alert: HHS distributing initial $30 billion in grant funds for provider relief under CARES Act
 
The Department of Health & Human Services (HHS) announced today it is beginning distribution of $30 billion in grants to hospitals and providers as part of the $100 billion fund authorized by the CARES Act; more information on the initial disbursement can be found here. These are payments, not loans, that have no repayment obligations and could be delivered via direct deposit as early as today. 
 
This announcement follows MGMA advocacy urging HHS to provide immediate financial support to group practices in order for them to sustain operations and continue treating patients. We will continue to press HHS to disburse remaining funds directly to medical group practices in an expeditious, efficient manner. 
 
Healthcare entities eligible for the initial $30 billion include all facilities and providers that received Medicare fee-for-service (FFS) payments in CY 2019. Importantly, this is only the first wave of funds under the $100 billion, and MGMA expects forthcoming distributions will focus on providers with lower shares of Medicare FFS reimbursement or who predominantly serve the Medicaid population.
 
Payment distribution amounts are determined by the eligible provider’s share of 2019 Medicare FFS reimbursements. HHS is partnering with UnitedHealth Group and Optum Bank to assist in the delivery of the initial $30 billion; funds will be distributed to the eligible provider’s billing tax identification number (TIN) using direct deposit information on file with United, Optum, or Medicare (with “HHSPAYMENT” or “HHS Stimulus” as the payment descriptor), or via paper check for those that normally receive reimbursement this way. Within 30 days of payment, HHS requires providers to attest to receipt of the funds and agree to certain terms via a portal opening on April 13. 
 
The $30 billion being distributed was authorized under the CARES Act, which was the third COVID-19 economic stimulus bill passed by Congress. The CARES Act designates $100 billion in funding through the Public Health and Social Services Emergency Fund and requires HHS to distribute capital through grants or “other mechanisms” to eligible healthcare entities, which include hospitals and group practices that are experiencing financial losses due to COVID19. Unlike the small business loans authorized under CARES, there are no employer size limitations.
 
 
 
 
Stay Updated!
Visit the newly revamped MGMA COVID-19 Action Center for the latest developments impacting medical practices
Questions?
Contact MGMA Government Affairs by emailing This email address is being protected from spambots. You need JavaScript enabled to view it. or calling 202.293.3450, 877.275.6462 toll-free

Letter from the Governor SCMGMA

 SCMGMA Logo

April 2, 2020

My Fellow Members,

I am certain that I speak for all of us when I say “We could have done without this”!  

Though we didn’t ask for it we are gaining valuable experience in dealing with an “unprecedented” situation that has many unforeseen variables and outcomes.   We are all doing our best to study this problem all the way through, making us better prepared as a result.  Our SCMGMA membership has some of the most intelligent, innovative and shrewd minds in the medical community and why you are "Leaders". 

I am sincerely humbled in witnessing how our members are successfully and safely navigating their hospitals, hospital systems, ASC’s and private practices through this wicked storm.  However, sharing your brave and inventive failures is just as important.  We are here to celebrate these victories and help you get to yours.  There is no problem that we cannot collectively solve.  So, share them and let's all get involved.

If your chapter is faced with whether or not to cancel or postpone your meeting below are a couple of pointers to move forward on making a decision:

1. Get up-to-date information about local COVID-19 activity from the World Health Organization (WHO). The WHO provides specific guidance on how to prepare your chapter for issues relating to COVID-19.

2. Review the recommendations from your local or state department of public health.

3. Utilize the webinars that are being forwarded to us from MGMA or other MGMA States that are “free” to our membership.

4. Note that the webinars, slides, and handouts are being saved to our website at www.scmgma.com

Your Executive and State Committee members are working on and sharing virtual meetings for the Local Chapters.  Same concept as the live streaming exercise class that now must substitute your visit to the gym/studio.   If you have live-streaming educational opportunities we welcome the opportunity to get these to our members.

The whole world’s population is looking to each other for guidance which is a rather encouraging sight.  This is history in the making and YOU have a part in it.

Be Safe and Healthy,

DeAna Duffey, Governor

South Carolina Medical Group Management Association

We are in this together

We are in this together

covid 19

We understand you have unique needs during this unprecedented time. As we navigate these new circumstances, MGMA will continue to regularly offer resources, tools and updates to help you.*
 
COVID-19 Webinars 
Two of the most-pressing topics for practice leaders will be addressed, each with an hourlong webinar: 

April 7: Rapidly Launching, then Optimizing Telehealth during the COVID-19 Health Crisis>> 
April 9: SBA Paycheck Protection Program: What Practices Need to Know>> 
 
Navigating Federal Changes 
If you’re looking for information on the CARES Act or if your practice has Medicare patients, don’t miss our newest resources. 

Access the Medicare Telehealth Waiver resource>> 
Review key provisions in the CARES Act>> 
Visit the COVID-19 Action Center for the latest updates>> 

COVID-19 Practice Communication Templates 
From patient outreach to staff teleworking policies, these templates help ensure clear communications in response to the pandemic. 
Download Today>>  

Shared Expertise in Our Member Community 
One of the most popular threads right now is surrounding a question of how to obtain patient consent for telehealth services. Learn how MGMA members across the country are addressing this question among hundreds of others. 

View the thread>> 
Access the COVID-19 Community>> 
 
MGMA20 | The Operations Conference
Join us for The Operations Conference Online April 16-17. Several sessions will be directly speaking to COVID-19 information and solutions. 
Register here>>

"I’ve always maintained that medicine is the most noble profession there is, and I think you’re seeing that nobility play out across the country." - Halee Fischer-Wright, MD, MMM, FAAP, FACMPE, President and CEO, MGMA

Continue to communicate with MGMA and your fellow members. Our best resource is each other.

ACCESS THE RESOURCE CENTER >

*In response to the urgent need of resources MGMA has made all COVID-19 resources available to all. Please share these tools, checklists and insights with your peers. 
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