The U.S. Small Business Administration (“SBA”) has released its updated Loan Forgiveness Application. Additionally, certain borrowers may qualify for the new Alternative Loan Forgiveness Application.
The Loan Forgiveness Application includes the following changes (instructions available here):
- Providing for the Alternative Payroll Covered Period (a 24-week period).
- Clarifies that a position will not be included in the FTE calculation if the Borrower made a good-faith, written offer to rehire an employee who was employed on February 15, 2020 and was unable to hire similarly qualified employees for the unfilled position.
- Changes FTE documentation from the average number of FTEs per month to the average number of FTEs per week.
- Specifies that employer health insurance contributions on behalf of a self-employed individual, general partners, or owner-employees of an S-corporation should not be included in the health insurance expenditures calculation.
- Restricts retirement expenditures for self-employed individuals, general partners, or owner-employees of an S-corporation.
The Alternative Loan Forgiveness Application is a shortened forgiveness application for certain qualifying borrowers. The application and instructions are available online.
The SBA has also updated the interim final rule (“Rule”) implementing provisions of the Paycheck Protection Program Flexibility Act of 2020, which amended the CARES Act. The Rule encompasses provisions relating to the maturity of PPP loans, the deferral of PPP loan payments, and the forgiveness of PPP loans. The interim final rule is available here.
STILL AWAITING HHS GUIDANCE ON REPORTING USE OF PROVIDER RELIEF FUNDS
Healthcare providers are still awaiting release of HHS forms and other guidance relating to the quarterly reporting of the use of Provider Relief Funding. As soon as available, The Health Group, LLC will provide this information, as well as other information, regarding the completion of these quarterly submissions for providers that received over $150,000 of funding.