As of July 10th, the Department of Health and Human Services (“HHS”) has made the Cares Act Provider Relief Fund available to dental practices who were in operation as of January 31, 2020 and are still operational.  The payment is similar to a grant (doesn’t have to be repaid) and is awarded at 2% of annual revenue (collections from patient care) as reported on the most recently filed tax return. The payment is intended to supplement the increased costs and reduced revenue of dental practices due to the pandemic.  

Please note that if you work as an associate/independent contractor for a practice, it appears that you generally are NOT eligible for these funds.  In order to be eligible, it appears you must bill patients directly.   The same would apply if you are a partner in a partnership and you or your S corp. is paid by the practice.   

As with all government funds, these come with certain terms and conditions. It is important that you read these carefully and are comfortable with the terms.  Assuming you are, you should apply ASAP for these funds.  The due date for application is Monday, August 3rd.     

Eligibility Requirements: 

To be eligible to apply, a dental provider must meet all of the following requirements: 

1. must not have received payment from the initial $50 billion Medicare-focused General Distribution; and 
2. must not have received payment from the $15 billion Medicaid and CHIP Distribution; and 
3. must have either (i) filed a federal income tax return for fiscal years 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 
4. must have provided patient dental care after January 31, 2020; and 
5. must not have permanently ceased providing patient dental care directly, or indirectly through included subsidiaries; and 
6. 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.  

How to Apply:    

• Create your Optum ID or use your existing Optum ID to access the application portal.  
• Once signed in, enter your EIN, Dental License Number, NPI Number, and Provider Organization Name to get started. 
• Your EIN will go through a verification process, and once verified you will be provided further instructions to continue the application process.  
  • Note: HHS has developed a curated list of dental practice TINs from third party sources and HHS datasets.  Providers with TINs on the curated list must meet other eligibility requirements (see above) including operating in good standing and not be excluded from receiving federal payments.  As a next step, HHS will work with states and its vendors to authenticate dental providers not on the curated list.  

You Will Need the Following Items for the Application:  

Documentation:   

• Your most recent federal income tax return (2018 or 2019 is acceptable) 
• Tax Forms 941 for Q1 2020, Form 940, or a statement explaining why the applicant is not required to submit either form 
• The applicant’s FTE Worksheet  

Numbers to Have Handy:  

• Gross Revenues (current year–to–date collections) 
• Prior Fiscal Year of Gross Revenues (full year gross collections from most recent federal income tax return – use 2018 if 2019 taxes have not been filed) 
• Percentage of Gross Revenue from Patient Care 
• Lost Revenues due to COVID-19 
• Increased Expenses due to COVID-19 
• Total Amount(s) received from Treasury SBA and/or PPP 

  Other Details to Note: 

• Applicant will have to certify to terms and conditions and adhere to the regulations of the stimulus package.  
• Funds cannot be used for expenses otherwise covered under PPP or EIDL loans. 
• Once received, the funds will have to be reported, and terms and conditions must be approved on the HHS site.  Further reporting requirements are likely. 
• It is our understanding this will be taxable income to the business. 
• If you received an initial Medicare-focused General Distribution or the Medicaid and CHIP General Distribution payment and rejected the payment, you are not eligible for an additional payment at this time. 
• Payments will be disbursed on a rolling basis as the HHS validates information.  If needed, you may be contacted by the HHS to provide additional information. 
• Please let us know when you have successfully applied for the funds. 

 We hope you find this information helpful, and, as always, please let us know if you have any questions.    

Resources: 

• HHS.gov – Dental Distribution FAQs 
• Instructions for the Medicaid Provider Distribution 
• CARES Provider Relief Fund