On April 1, 2020, we issued an initial, high-level summary of key provisions of the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act affecting healthcare providers and their practices. Since our first article was published, the Small Business Administration and the Internal Revenue Service have issued additional regulatory guidance regarding the CARES Act, including (without limitation):
- Interim Final Rule on the Paycheck Protection Program
- Interim Final Rule on Affiliation for purposes of the Paycheck Protection Program
- Frequently Asked Questions on the Paycheck Protection Program (regularly updated)
- IRS Guidance on Employment Tax Deferrals
As of now, the Small Business Administration has promised, but not yet issued, regulatory guidance regarding loan forgiveness under the Paycheck Protection Program. We have also been providing updates regarding HHS payments from the Provider Relief Fund under the CARES Act.
To keep you updated while avoiding confusion, moving forward we will be posting cumulative updates regarding the CARES Act at the following links:
- Updates regarding the Paycheck Protection Program, Unemployment Insurance Benefits, and Employee Retention Payroll Tax Credits.
- Updates regarding the Provider Relief Fund.
We will continue to provide separate updates as appropriate.
The COVID-19 pandemic and response is an evolving situation. All levels of government are engaged in the process of preparing new legislation, regulations and orders both to stem the spread of the virus and to provide relief to employers and employees. We will continue to monitor the situation and provide updates as applicable, especially as such updates affect healthcare providers and their practices.
For more updates on this topic and other legal updates related to the COVID-19 pandemic, please visit our COVID-19 Legal Resource Page by clicking here.
