Second Round of Stimulus Relief for Healthcare Providers Launched Friday, April 24, 2020

by | Apr 27, 2020

April 27, 2020

The Coronavirus Aid, Relief, and Economic Security Act (CARES) that was signed into law on March 27, 2020 allocated $100 billion in financial relief targeted to hospitals and other healthcare providers.

On Friday, April 14, 2020, the Department of Health and Human Services (HHS) initiated a portion of this $100 billion through its distribution of $30 billion as part of the $50 billion general allocation fund that was established through CARES. Additional information on this first round of funding can be found here.

On Friday, April 24, 2020 HHS began its second round of funding that will spend the remaining $20 billion of the general allocation fund. This funding is intended to support healthcare-related expenses or lost revenues attributable to COVID-19 and to ensure availability of testing and treatment for COVID-19 related illnesses.

This new round of $20 billion in funding comes with certain restrictions that are similar the initial $30 billion relief. Some, but not all, of the restrictions include:

  1. The healthcare business must be able to certify that it is in good standing with Medicare.
  2. The healthcare business must be able to certify that payments will only be used to prevent, prepare for, and respond to the coronavirus AND that the payment shall reimburse for only health care related expenses or lost revenues that are attributable to coronavirus.
  3. The funds will not be used for expenses or losses that have already been reimbursed from other sources (PPP Loan, EIDL Grants, EIDL Loans).
  4. If the healthcare business receives more than $150,000 in total funds in relief from the multiple sources provided under the CARES Act, the Families First Coronavirus Response Act, and the Coronavirus Preparedness and Response Supplemental Appropriations Act, then the business will be required to report no later than 10 days after the end of each quarter detailed financial and employment information.
  5. None of the funds can be used to pay the salary of an individual whose pay is in excess of Executive Level II, which for 2020 is defined by the Office of Personnel Management as $197,300.
  6. The healthcare business will charge patients in-network charges even if their health plan is out of network.

However, there are also new restrictions added to this round of funding. Some, but not all, of the new restrictions include:

  1. The requirement to submit revenue data for calendar year 2018.
  2. The requirement to agree to this information being publicly disclosed.
  3. Submission of the most recently filed tax return; dates specified are 2017, 2018, or 2019.
  4. Submission of the provider’s estimated loss of revenue for March and April 2020 due to COVID-19. This can be in the form of a budget to actual statement or a prior year comparative financial statement.
  5. A listing of Tax Identification Numbers (TINs) with very specific instructions on the appropriateness of listing multiple TINs.

If the paperwork becomes too burdensome and the healthcare business cannot comply or prove that it is complying, the funds will be required to be repaid. It is unclear whether interest will be charged.

It appears that there will be audits. Writing collection policies and financial policies as well as keeping good accounting records will be imperative. Billing and collections will have an added layer of necessary consideration regarding patient billing. The accounting department will be required to keep additional paperwork and provide additional reporting to HHS.

KHA recommends that, similar to the PPP Loan program, the healthcare business should open a separate bank account for these funds and move the exact amount of funds into the new bank account. Additionally, set up separate chart of account items and/or classes in the accounting software to keep track of the expenses that are being supported by this program. Finally, identify expenses that are appropriate to be used for these funds and transfer that exact amount out of the bank account and maintain detailed documentation supporting such transfers.

What remains unclear is how much will be provided in relief to any individual business.  Unlike the initial round that was based on relative proportion of 2019 Medicare Fee-For-Service (FFS) payments, the second round is expected to be distributed proportionate to the providers share of 2018 net patient revenue. For those providers who have a small Medicare practice, the second round of payments could be more beneficial. Of course, it depends on the total revenue of submitted requests to determine how much of the remaining funds will be allocated to any individual practice.

It’s possible that the amount of relief will be insufficient to support the level of paperwork and new policies and procedures that will be required to be implemented. Consideration should be given to repaying these funds within 30 days of payment if the healthcare business doesn’t anticipate that it will be able to comply.

For more information on this relief, here are some useful links:

CARES Act Provider Relief Fund

Information on the Terms and Conditions

This nine-page FAQ is very helpful as well.

For the remaining $50 billion in funding not currently allocated, plans are in progress. We anticipate that this funding will provide more targeted support, specific to healthcare entities that provide treatment to the uninsured, high impacted areas, rural providers, Indian Health Service, skilled nursing facilities, dentists, and providers that solely take Medicaid.

Visit the HHS website at https://www.hhs.gov/ to learn more about future relief efforts.

As your trusted advisors, we are committed to keeping you well-informed with any new legislation passed by Congress. Please do not hesitate to reach out to KHA with any additional questions you may have.  

These sources are simply included for informational purposes. KHA Accountants, PLLC, its partners and others do not provide any assurance as to the accuracy of these items or the information included therein. As such, KHA Accountants, PLLC cannot be held liable for any information derived from referenced sources. Consult your legal and business advisors prior to making financial decisions. This is intended for illustrative and discussion purposes only.

What Business Owners Must Know About Net Operating Loss Rules in 2025 and Beyond

The pandemic-era flexibility is gone, and the One Big Beautiful Bill has locked in the TCJA’s NOL rules for the foreseeable future. If your business is still planning around old assumptions — like the ability to carry losses back or fully offset taxable income — it’s time for a reset. Here’s what you need to know heading into 2025 and beyond.

Texas Limited Partners Get Good News from the Fifth Circuit — But Don’t Skip the Planning

If you are a limited partner in a Texas-based business, a January 2026 federal court ruling just changed the rules in your favor — and the savings could be significant. The U.S. Court of Appeals for the Fifth Circuit rejected the IRS’s long-standing “passive investor” test and ruled that any partner in a limited partnership with genuine limited liability qualifies for the self-employment tax exemption under IRC Section 1402(a)(13) — even if you actively work in the business. With self-employment tax running as high as 15.3%, the financial impact of this ruling can be substantial. But the law is still unsettled outside Texas, and the details matter. Read on to find out what this means for your tax strategy and what steps you should be taking right now.

Real Estate and Cost Segregation

Learn more about cost segregation studies and found out if performing one is a smart next step for your real estate portfolio.

Building a Family Limited Partnership That Lasts: What High-Net-Worth Families and Business Owners Need to Know

Most business owners think about succession planning far too late. A Family Limited Partnership, when established early and managed with discipline, gives founders something rare: the ability to transfer economic value to the next generation gradually, deliberately, and on their own terms — without giving up operational control in the process. It is one of the most effective wealth transfer and succession planning tools available. It is also one of the most scrutinized by the IRS. Before you build one, make sure you understand what it takes to make it last.

Manufacturers: A New Tax Break Could Let You Write Off Your Entire Facility on Day One

Congress just handed manufacturers one of the most significant tax incentives in decades. Under the new One Big Beautiful Bill Act, qualifying businesses can now deduct 100% of the cost of a new production building in the very first year it is placed in service — instead of spreading that deduction over 39 years. For a business investing $5 million, $10 million, or more in a new or expanded facility, that difference could be transformational. But the rules are strict, the election is irrevocable, and the clock is already ticking. Read on to find out if your facility qualifies and what you need to do before you file.

The State Tax Divide: What High-Tax State Residents Need to Know Now

Two decades ago, 21 states had top income tax rates between 5 and 7 percent. Today, only 12 do. Meanwhile, 26 states now have rates below 5 percent or no income tax at all, while six states have climbed to double-digit rates. With more low-tax alternatives than ever before, businesses and high-net-worth individuals in high-tax states need to consider their options now—before policy changes catch them off guard.

What Every Taxpayer Needs to Know About the 2026 Tax Season

The 2026 tax filing season brings several significant changes that could affect your refund timeline and filing approach. Between IRS staffing reductions, new postal service postmark rules, and a transition to electronic payments, taxpayers who wait until April to file or who rely on paper submissions may face unexpected delays and penalties. The good news? With a few proactive steps—filing electronically, mailing early, and setting up direct deposit—you can avoid these pitfalls and ensure a smooth filing experience.