Articles and Blogs

As part of the CARES Act,[1] the Paycheck Protection Program (“PPP”) granted vulnerable small businesses the ability to seek forgivable loans from the federal government to help prevent closures during the COVID-19 crisis and to ensure employees remain on payroll. The Small Business Administration (“SBA”) and the Department of the Treasury have published and updated…Read More

Earlier today, the Small Business Administration (“SBA”) issued an updated Interim Final Rule (the “Rule”) that supplements and provides clarification on the types of businesses that are eligible for the Paycheck Protection Program (“PPP”) loans. Under the Rule, governmental hospitals that (a) have 500 or fewer FTEs, and (b) receive less than 50 percent of…Read More

On April 21, 2020, CMS issued explanatory guidance clarifying the scope and application of the previously issued Stark blanket waivers related to COVID-19 physician arrangements (“Waivers”). Our previous alert on the Waivers can be found here. Action and Timing The Waivers can be relied upon retroactive to March 1, 2020 but will terminate upon the expiration…Read More

Thursday, April 23 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ Congressional Outlook Today, the House approved an interim emergency spending measure that includes…Read More

On April 23, 2020, the Department of Treasury and the Internal Revenue Service issued proposed regulations related to the ‘silo’ rules for Unrelated Business Taxable Income (“UBTI”). Under Internal Revenue Code (“Code”) Section 512(a)(6), as added to the Code through the Tax Cuts and Jobs Act in 2017, tax-exempt organizations must calculate their UBTI separately…Read More

On April 23, the Department of Health and Human Services (“HHS”) outlined the basic framework for a new program to reimburse hospitals and other providers and suppliers for services provided to uninsured COVID-19 patients (for purposes of this article we refer to both providers and suppliers as “providers”). The framework for the program is available…Read More

The Coronavirus Aid, Relief, and Economic Security Act (H.R. 748) (“CARES Act”) contains numerous provisions aimed at the response to the Coronavirus or COVID-19 pandemic, including $100 billion in reimbursement to hospitals and other health care entities for COVID‑19-related expenses and lost revenue (“Fund”). The First Tranche of the Fund was distributed on April 10,…Read More

On Wednesday, April 22, 2020,  President Trump signed an executive order regarding immigration policies and enforcement amidst the COVID-19 pandemic titled “Suspension of Entry of Immigrants Who Present a Risk to the United States Labor Market During the Economic Recovery Following the 2019 Novel Coronavirus Outbreak” (the “Executive Order”). As we discussed with President Trump’s…Read More

The Department of Treasury (“Department”) and Internal Revenue Service (“IRS”) have confirmed that tax-exempt organizations have an extension until July 15, 2020 to file their Forms 990-series annual information returns, as well as various other returns. While certain aspects of this relief are automatic, tax-exempt hospitals and other tax-exempt organizations should consider their particular circumstances…Read More