CARES Act - Key Takeaways for Healthcare Organizations

1. COVID-19 UPDATE
CARES ACT
KEY TAKEAWAYS FOR
HEALTHCARE ORGANIZATIONS
CITRIN COOPERMAN WEBINAR
evolutionApril 23, 2020
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PRESENTED BY:
Michael Criscione, CPA, Partner and Healthcare Co-Practice Leader
Ron Hegt, CPA, Partner
Mitzi Hollenbeck, CPA, CFE Partner
Kate Broderick, Manager

2. evolution COVID -19 UPDATE
AGENDA
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Introduction | Michael Criscione
Healthcare Provisions | Michael Criscione & Kate Broderick
Loan Provisions | Mitzi Hollenbeck
Tax Provisions | Ron Hegt
Summary and Q&A | Michael Criscione

3. 3
Healthcare Provisions:
Funding

4. 4
Healthcare Provisions:
Medicare Advance Payments
Provision Details
Medicare Advance Payment Option
• Most providers/suppliers: Up to 100% of the average Medicare payments received, determined by the
MAC, for a three-month period. 120 days following the issuance of the payment, recoupment begins
and providers have 90 days to repay the balance.
• Application: Providers can apply through their MAC’s website
• Process time: Providers should receive finding within a week of the request
Key Details
• Intended as a cash advance, versus a subsidy; should be tied to services already performed
• For most providers, any amount not repaid 31 days after the end of the 210-day payment period will begin accruing interest at 10.25%

5. 5
Healthcare Provisions:
Medicare Advance Payments
Advance
Payment Made
120 days
Recoupment
Begins
Outstanding
Balance Due
90 days
Interest Accrual
Begins on Any
Balance
Outstanding
31 days
Year 1
Most Suppliers and Providers

6. 6
Healthcare Provisions:
Provider Relief Fund
Provision Details
$100B Public Health and Social Services Fund
FEDERAL STIMULUS
$100 billion has been allocated, until expended, “to prevent, prepare for, and respond to coronavirus,
domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms,
eligible health care providers for health care related expenses or lost revenues that are attributable to
coronavirus.”
• Eligible Providers: Public entities, Medicare or Medicaid enrolled suppliers and providers, and such for-
profit entities and not-for-profit entities not otherwise described in this proviso, within the United States
(including territories), that provide diagnoses, testing, or care for individuals with possible or actual cases
of COVID-19
• Use of Funds: Lost revenues and expenses attributable to PREVENT, PREPARE AND RESPOND TO COVID-
19, including building or construction of temporary structures, leasing of properties, medical supplies
and equipment, increased workforce and trainings, emergency operation centers, retrofitting facilities,
and surge capacity
• Timing of Distribution: $30B was distributed starting 4/10/2020

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Healthcare Provisions:
Provider Relief Fund
Provider Relief Fund Initial $30B Distribution
The CARES Act appropriated $100B to HHS for the support of eligible healthcare providers. On April 10, 2020, the first $30B of that fund was distributed to healthcare providers, based on their 2019 Medicare FFS billings.
While there does seem to be flexibility around the use of these funds, there are several key requirements noted in the Terms & Conditions that accompanied the announcement of the distribution. We are continuing to
monitor guidance issued around these funds, however, we have outlined initial considerations below.
Key Questions
Q: How was the distribution amount determined?
A: Medicare based the distribution on healthcare organization’s 2019 Medicare Fee-for-Service billings. A provider can estimate their payment by dividing their 2019 Medicare FFS (not including Medicare
Advantage) payments they received by $484,000,000,000, and multiply that ratio by $30,000,000,000. Providers can obtain their 2019 Medicare FFS billings from their organization's revenue management
system. This equates to 6.2% of Medicare billings.
Q: Who is eligible?
A: All providers who received Medicare FFS reimbursement in 2019. There are, however, several conditions outlined below attached to this money.
Q: How was this money distributed?
A: It was distributed via direct deposit on April 10, 2020. Providers who do not take electronic payment from Medicare will receive a check. All payments were made according to the provider’s tax identification
number (TIN).
Q: What conditions apply to this distribution?
A: On the next slide, please find an outline of the terms and conditions that apply to this initial distribution from the Provider Relief Fund. Providers must make these certifications through an HHS online portal
available at: hhs.gov/provider-relief/index.html. This portal opened as of the morning of April 16, 2020. Not returning the payment within 30 days of receipt will be viewed as acceptance of the terms and
conditions.
Q: We have had to close due to COVID-19, but we received money from this distribution. Are we still eligible to use it?
A: According to updated guidance on the HHS Provider Relief website, if you ceased operation as a result of the COVID-19 pandemic, you are still eligible to receive funds so long as you provided diagnoses,
testing, or care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19.

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Healthcare Provisions:
Provider Relief Fund
Category Terms & Conditions Considerations
Eligibility Certifications  Recipient certifies that it provides, or provided after January 31,2020, diagnoses, testing, or care for individuals with possible or actual cases of COVID-19
The provisions here for general eligibility are extremely broad. Based on this guidance from HHS, most providers
who received funds through the initial distribution is likely to eligible to keep it for application to eligible
expenses and losses.
Patient Billing
 For all care for a possible or actual case of COVID-19, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that
are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.
 Providers are obligated to abstain from "balance billing" any patient for COVID-related treatment.
It seems clear, from this language along with statements made by President Trump, that appropriations with this
fund will be used to cover the uninsured, which could reduce funds available to cover extraordinary
expenses/losses associated with COVID-19. As a reminder, HHS has clarified that it “broadly views every patient
as a possible case of COVID-19.”
Medicare Standing
Certifications
 Recipient billed Medicare in 2019
 Recipient is not currently terminated from Medicare participation
 Recipient is not currently excluded from participation in Medicare, Medicaid, and other federal health care programs
 Recipient does not currently have Medicare billing privileges revoked
CMS has indicated that it is aware that many providers do not receive a large proportion of their reimbursement
from Medicare, such as pediatricians, and will focus on those providers in the next tranche of funding.
Use of Funds Certifications
 Payment will only be used to prevent, prepare for, and respond to coronavirus
 Payment shall reimburse the Recipient only for healthcare-related expenses or lost revenues that are attributable to coronavirus
 Payment will not be used to reimburse expenses or losses that have been reimbursed for other sources or that other sources are obligated to reimburse
It is unclear how broad the interpretation of these conditions will be. It does seem, however, that these funds
cannot be used to cover costs/lost revenue coved by mechanisms like business interruption insurance.
Reporting Requirements
 Recipient will submit reports HHS deems are needed to ensure compliance with conditions imposed on the payment
 No later than 10 days after the end of each calendar quarter, recipients that received more than $150k total in funds under the CARES Act, the Coronavirus
Preparedness and Response Supplemental Appropriations Act, the Families First Coronavirus Response Act or any other Act primarily making
appropriations for the coronavirus response and related activities, shall submit a report containing:
o Amount of funds received from HHS
o Amount of funds received that were expended/obligated for each project or activity
o A detailed list of all projects or activities for which large covered funds were expended/obligated, including the name of the project, description, and
estimated number of jobs created/retained by the project, where applicable
o Detailed information on any level of subcontracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees
Careful tracking of all funding secured through the various acts enacted to address the COVID-19 crisis and its
use will be critical. This tracking will need to include funding from Medicare Advance Payments, PPP, the Main
Street Lending Program, the FCC COVID-19 Telehealth program, and others. One key question that remains
unclear is whether these funds will be considered taxable income.
Note: At this point, it is unclear whether the $150k threshold includes funds from other mechanisms put into
place by the CARES Act to improve reimbursement, such as the suspension of the Medicare Sequester.
Record Keeping
 The recipient shall maintain appropriate records and cost documentation, including documentation required by Section 75.302 of Title 45 of the Code of
Federal Regulations:
o Identification in its accounts of all federal awards received and expended, including the CFDA title and number, federal award identification number
and year, and the name of the HHS awarding agency
o Accurate, current, and complete disclosure of the financial results of each federal award. If the HHS awarding agency requires reporting on an accrual
basis from a recipient that does not maintain its records on an accrual basis, the recipient must not be required to establish an accrual accounting
system. This recipient may develop accrual data for its reports on the basis of an analysis of documentation on hand.
o Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining
to federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source
documentation
o Effective control over and accountability for all funds, property, and other assets.
o Comparison of expenditures with budget amounts for each federal award
o Written procedures to implement internal controls, per requirements of section 75.303
o Written procedures for determining the allowability of costs
 The recipient shall promptly submit copies of such records and cost documentation upon the request of HHS
 The recipient agrees to fully cooperate in all audits HHS, the Inspector General, or the Pandemic Response Accountability Committee conducts to ensure
compliance with Terms & Conditions
Here again, careful record keeping will be critical to ensure compliance and prepare for any potential future
audits. Additionally, documentation of internal controls and for determining the allowability of costs will need to
be developed if not already in place.
Other Terms & Conditions
In addition to the terms outlined above, general provisions of FY2020 consolidated appropriations also apply, including prohibition of the use of funds for highly
compensated individuals, lobbying, abortions, gun control advocacy, and needle exchange programs, among others.
Recipients should be sure to review all terms and conditions included in this section.

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Additional Funding Opportunity:
FEMA Public Assistance
Provision Details
Eligible Providers
• State, Local, Tribal, and Territorial entities
• Public and non-profit entities which must:
o Be a 501(c), (d), or (e) tax-exempt nonprofit or owned or operated by one;
o Operate an eligible facility, such as a medical facility;
o And provide eligible services such as clinics, in-patient acute care, in-patient convalescent and chronic care, nursing homes, facilities that
support the provision of health care such as central services facilities, extended-care facilities, laboratories, long-term care facilities,
outpatient facilities, ambulance operations and rehabilitation facilities.
Eligible Expenses
1. Efforts to manage, control or reduce immediate threats to public health and safety
2. Emergency Medical Care and Activities
3. Medical Sheltering Related to Patient Surges
4. Other Eligible Costs, including purchase and distribution of medicine, household pet sheltering, overtime costs, and security and law enforcement
Restrictions
• Inpatient care
• Follow-up treatments beyond the duration of the Public Health Emergency
• Insured care, including care insured by Medicaid and Medicare
• Healthcare administration and business costs that are not directly linked to COVID-19, including revenue and business disruption
• FEMA cannot duplicate assistance provided by HHS, including the CDC and other federal agencies
Application
• Applications will be accepted throughout the duration of the Public Health Emergency, until 30 days after its conclusion
• Applications can be made through grantee.fema.gov – STATE FEMA AGENCY - $ available and timing is unknown or provided during initial
application
• FEMA requires detailed documentation for all reimbursable expenses, including specifics about the pressures the emergency is placing on the facility
• Detailed accounting of estimates, bids, expenditures, invoices, payments, and receipts is critical
More information is available at: https://tinyurl.com/FEMA-COVID
As part of the COVID-19 Public Health Emergency, FEMA has made public assistance funding available to eligible State, Local, Tribal,
and Territorial governments as well as eligible private non-profit organizations.

10. 10
Healthcare Provisions:
Regulatory & Reimbursement Changes

11. 11
Healthcare Provisions: Coverage
Provision Details
Testing
Section 3202: Group health plans and health insurance issuers shall reimburse providers for COVID-19
tests at an agreed-upon rate with providers, or if not agreed to, then at the cash price for such service
as listed by the provider on a public internet website (which is now a mandated requirement)
Preventative Services
Section 3203: Group health plans and health insurance issuers are required to cover all qualifying
coronavirus preventative services (any item or service meant to mitigate or immunize against the virus)
Vaccine Cost-Sharing Section 3713: Eliminates cost sharing for COVID-19 vaccine under Medicare Part B
Medicare Sequester Suspension
Section 3709: Ends the Medicare sequester from May 1 through December 31, 2020, boosting
Medicare payments by 2%
FMAP Increase
Section 3720: Increases the Federal Medical Assistance Percentage by 6.2% for each qualified state and
territory from January 1, 2020 through the end of the quarter in which the public health emergency for
COVID-19 ends. Rhode Island and Connecticut have passed temporary increases to Medicaid
providers of 10% for the months April – June 2020.
On March 30, CMS issued sweeping regulatory changes pursuant to these and other provisions of the CARES Act

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Post Acute Care Provisions & Funding
Provision Details
Flexibility for Post-Acute Care
CARES Act - Section 3711:
• Waives 3-hour rule for inpatient rehabilitation facilities.
• Waives site neutrality rules for LTCHs
• Suspends 50% rule for LTCHs.
CARES Act - Section 3811
• Extends the Medicaid Money Follows the Person demonstration, occurring in 44 states; extends approximately $75M in funding
through November 30, 2020
Additional Waivers
• CMS has waived the 3-day hospital stay requirement for coverage of SNF stay
• For some beneficiaries, CMS also authorizes renewed SNF coverage without first having to start a new benefit period
• CMS is allowing non-SNF buildings to be temporarily certified for use by a SNF to support isolation protocols
• CMS is allowing rooms in long-term care facilities not typically used for patients to be used to accommodate beds and residents
• CMS is waiving the requirement for physicians and non-physician providers to perform in-person visits; these may be conducted via
telehealth, as appropriate
• CMS is also permitting physicians to delegate a broader scope of tasks to appropriate providers at SNFs
• Additional waiver pertaining to transfers and patient grouping
• Additional waivers pertaining to reporting requirements and data submission
LTCH Waivers
• CMS has issued a blanket waiver to LTCHs to exclude patient stays where an LTCH admits or discharges patients in order to meet the
demands of the emergency from the 25-day average LOS requirement. This will also apply, during the waiver period, to facilities
seeking LTCH classification.
Potential Funding for Nursing
Home Facilities
CARES Act - Title III: Earmarks $100M of a $200M appropriation for “necessary expenses of the survey and certification program,
prioritizing nursing home facilities in localities with community transmission of coronavirus”. Details have not been released as of the
date of this webinar.

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Telehealth: Regulatory Changes
Provision Details
HIPAA
Due to the need for healthcare providers to scale telehealth capabilities quickly, the Office of Civil Rights (OCR) will not be
enforcing certain aspects of HIPAA to allow providers to communicate with patients using technologies that may not be HIPAA
compliant.
• There is no timeline on when OCR will begin enforcing again
• Providers must act in good faith and do their utmost to protect PHI
• Providers and patients will be able to use services like Apple FaceTime, Skype, Zoom, and Facebook video chat to communicate
via their personal devices
• Usage of certain public communication platforms, like Tik Toc or Facebook Live, will still be considered violations of HIPAA
• Some services like Skype for Business or Microsoft Teams already provide HIPAA-compliant video communications as well as
BAAs. The OCR encourages providers to use these more secure platforms where possible.
Licensing
• Under the Section 1135 Waiver issued by the Secretary of Health and Human Services, the requirement that healthcare
professionals hold a license in the state in which they provide services has been waived, so long as the provider has an
equivalent license in another state
• CMS has not issued guidance on how this will be implemented, however, the ability to provide telehealth across state lines is
critical, as patients may have travelled or may reside in a different state than the practice where they are normally seen,
particularly in areas like New York City and Washington, D.C.
• CMS is currently reviewing how the CARES Act may allow for them to relax rules around providing physical, occupational, and
speech therapies via telehealth
Additional Changes
• Medicare has expanded flexibility around telehealth, eliminating the need for a patient to have seen the provider within the
past three years and permitting audio-only visits
• Providers may also use telehealth for visits with chronic kidney disease patients who are on home dialysis
• Providers may use telehealth to recertify patients for hospice
• The Department of Health and Human Services must issue clarifying guidance on the use of telecommunications systems for
home care, e.g., remote patient monitoring services

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Telehealth: Reimbursement Changes
Provision Details
High Deductible Health Plans
Telehealth visits for patients enrolled in high deductible health plans with HSAs can be covered by payors before the patient meets
his/her deductible
CMS Reimbursement Rate Medicare will be reimbursing for telehealth visits at the same rate as face-to-face
Setting Flexibility
For the duration of the emergency, Medicare will make payment for professional services furnished to beneficiaries in all areas of the
country in all settings. This flexibility also allows providers to furnish services from their homes
Cost-Sharing Under Medicare, healthcare providers have the option to waive coinsurance and deductible requirements
Medicare Advantage &
Part D Plans
CMS has also issued flexibility to MA & Part D plans, allowing them to add services, like telehealth, that were not included in their bid

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Telehealth: Opportunities for Post-Acute
Provision Details
Additional Reimbursable
Services
In order to meet the demands of the current pandemic, CMS has expanded the number of codes covered by telehealth by
over 80 additional CPT codes. Taken in conjunction with the waivers issued by CMS to offer additional flexibility to SNFs,
telehealth can help support patients and SNFs in navigating the COVID-19 crisis. Some examples include:
• Emergency Department Visits: ED Visits are now reimbursable via telehealth, allowing patients in nursing settings to
avoid unnecessary trips to the hospital
• Evaluation and Management: Telehealth providers can provide these care under these codes, supporting nursing staff
while allowing SNFs to reduce potential patient and provider exposure to COVID-19
• Specialty Support: Telehealth can also be used to provide specialty care, such as wound care
Remote Patient Monitoring
In addition to telehealth visits, provision of remote patient monitoring can also help to enhance patient care, particularly
in circumstances where nursing facilities may be short staffed or where access to key specialists may be limited.
• Digital vitals monitoring
• Store and Forward consultations

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FCC COVID-19 Telehealth Program
Provision Details
Appropriation $200M through the CARES Act
Eligible Providers
Non-profit and public eligible healthcare providers in rural or non-rural areas:
• Post-secondary healthcare education providers, including teaching hospitals and medical schools
• Community health center and health centers providing care to migrant populations
• Local health departments or agencies
• Community mental health centers
• Not-for-profit hospitals
• Rural health clinics
• Skilled nursing facilities
• Consortia of health care providers consisting of one or more entities falling into the first seven categories
Eligible Expenses
• Purchase of telecommunications, information services, and connected devices
• Will provide full funding for eligible services and devices, but do not anticipate awarding more than $1M to a single applicant
• Awards will be made based on estimated cost in application, but to provide flexibility, providers will not be tied to purchases
outlined in their application
• Applicants who exhaust funds may reapply
Application
• Awarded on a rolling basis
• Will target hardest-hit areas
• Will not target toward specific conditions, patient populations, or geographic areas
• Applicants should document hardships like provider shortages or limited access to Internet in their applications
• FCC will consider programs’ ability to directly aid in the prevention of pandemic spread
• Devices and services funded must be integral to patient care
In addition to this program, the FCC is also going live with their Connected Care program, which targets projects that would
primarily benefit veteran and low-income patients

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FCC COVID-19 Telehealth Program
For more information, visit:
https://www.fcc.gov/covid-19-telehealth-program
The application for the FCC COVID-19 Telehealth Program has been posted online
as of 12PM Eastern on April 13, 2020.

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Telehealth:
Programmatic Considerations
Programmatic Considerations
• Telehealth Platform: If you do not already have a telehealth platform in place, are you able to consider standing up telehealth using readily available
technologies like FaceTime or Skype, under the relaxed regulatory environment, to provide telehealth immediately?
• Cybersecurity and Compliance: Have you consulted with counsel and cybersecurity experts to understand risk exposure and mitigation strategies?
• Malpractice Coverage: Have you checked with your malpractice provider to ensure telehealth coverage?
• Bookkeeping: Have you established a separate cost center for telehealth programming under the current emergency so you can track costs and revenues
and prepare yourself for any current or future government funding opportunities? Tracking should include any waived cost-sharing.
• Physical Footprint: If providers are able to provide care outside of the clinic setting, is there an opportunity to consolidate or repurpose space and reduce
costs or add patient rooms?
• Work Flow: If your providers are still seeing patients in clinic, how are you integrating tele-visits and face-to-face visits to maximize flexibility and fill
providers’ schedules as much as possible?
• Commercial Reimbursement: Have you worked with your top commercial payors to understand what telehealth services they are reimbursing?
• Revenue Cycle: Are you working with payors and your revenue cycle function to understand documentation requirements for telehealth to ensure
collections?
• Privacy: For providers taking tele-visits in clinic, have you designated office or exam room space to maximize privacy?

19. 19
Loan Provisions

20. 20
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PPP Overview: PPP Loan Forgiveness:
For small Businesses < 500 employees
No collateral / no personal guarantee
Determination of loan size:
 Your max loan is equal to the lower of 250% of your average monthly
“payroll costs”, or $10M.
 Borrowers will be reviewing average monthly payroll costs for the preceding
calendar year (2019)
Payroll Costs:
 Employee compensation (not to exceed $100,000, or $8,333.33 per month).
 Group health care coverage, including health insurance premiums, net of
employee contributions
 Payment of any retirement benefit
 Payments to Independent Contractors are not included
Loan Terms:
 The interest rate of the PPP loan will be 1%
 The maturity date of the PPP loan is 2 years from the loan origination date.
6 month deferral period to begin making payments.
Loan Administration and Application:
 Administered through banks under the SBA 7(a) loan program.
 Currently, SBA issued “Interim Final Rule”, subject to interpretation and
change.
Eligibility for Loan Forgiveness:
Up to a business’ costs during 8 weeks following date of loan’s origination for the
following categories:
 Compensation to employees
 Group health benefits
 Rent and utility payments
No less than 75% of the loan proceeds need to be used on payroll costs in 8 week
period following receipt of the loan in order to be eligible for full loan forgiveness.
Criteria for Loan Forgiveness:
 FTE Headcount: The portion of the loan that will be forgiven will be based
on a ratio of your full-time equivalent employee headcount during the 8
week period compared to the FTE headcount during the test period
February 15, 2019 - June 30, 2019 or from January 1, 2020 until February 29,
2020.
 Salaries and wages: Employee salaries must be maintained to at least 75%
of the test period salary in order for the employee to be counted.
Declines in headcount or wages between February 15, 2020 and April 26, 2020
will not trigger a reduction in loan forgiveness if the business reverses the decline
and returns to pre-decline levels by June 30, 2020.
***Loan forgiveness will not be included in a business’s taxable income***
Section 1102:
Paycheck Protection Program (“PPP”)

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 Qualified small businesses (as defined by the SBA, less than 500 employees)
 Loan proceeds up to $2M for working capital funding
 The SBA will determine the exact amount a business can borrow based on cash flow projections and demonstrated need
 Collateral required for loans over $25,000
 Personal guarantees for loans over $200,000
 Proceeds can be used for working capital, including payroll, accounts payable, inventory, equipment and machinery purchases,
real estate payments, and other operating expenses
 This program is not eligible for loan forgiveness
 Interest rate is 3.75%, and borrower can defer principal and interest for the first 11 months of the loan.
 Administered through SBA website
 Short form application for $10,000 advance, convertible to a grant – capped at $1,000 per employee
 If applying for EIDL grant and/or loan and applying for PPP, the PPP loan will be less the EIDL grant amount and the EIDL loan
amount will be added, not to exceed $10M
Economic Injury Disaster Loan (“EIDL”)

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Main Street Lending Program Overview
Term
New Loans
(Main Street New Loan Facility – MSNLF)
Expanded Loans
(Main Street Expanded Loan Facility – MSELF)
Eligible Loans New, unsecured term loan originated on or after April 8, 2020
Term loan made by an Eligible Lender to an Eligible Borrower, originated
before April 8, 2020, provided the upsized tranche has the following
features:
Interest Rate Adjustable rate of SOFR plus 250-400 basis points Adjustable rate of SOFR plus 250-400 basis points
Term 4-year maturity 4-year maturity
Repayment Terms
• 1-year deferral of principal and interest payments
• Prepayment permitted with no penalty
• 1-year deferral of principal and interest payments
• Prepayment permitted with no penalty
Minimum Loan Size $1 million $1 million
Maximum Loan Size
Maximum loan size that is the lesser of (i) $25 million or (ii) an amount
that, when added to the Eligible Borrower’s existing outstanding and
committed but undrawn debt, does not exceed four times the Eligible
Borrower’s 2019 earnings before interest, taxes, depreciation, and
amortization (“EBITDA”)
Maximum loan size that is the lesser of (i) $150 million, (ii) 30% of the
Eligible Borrower’s existing outstanding and committed but undrawn bank
debt, or (iii) an amount that, when added to the Eligible Borrower’s
existing outstanding and committed but undrawn debt, does not exceed
six times the Eligible Borrower’s 2019 earnings before interest, taxes,
depreciation, and amortization (“EBITDA”)
Participation in Other
Programs
• Borrower cannot participate in the MSNLF and MSELF simultaneously
• Borrower cannot participate in the MSNLF and Primary Market
Corporate Credit Facility
• Borrower can participate in MSNLF and PPP
• Borrower cannot participate in the MSNLF and MSELF simultaneously
• Borrower cannot participate in the MSELF and Primary Market Corporate
Credit Facility
• Borrower can participate in MSELF and PPP
Fees
• An Eligible Lender will pay the SPV a facility fee of 100 basis points of the
principal amount of the loan participation purchased by the SPV. The
Eligible Lender may require the Eligible Borrower to pay this fee.
• An Eligible Borrower will pay an Eligible Lender an origination fee of 100
basis points of the principal amount of the Eligible Loan.
• An Eligible Borrower will pay an Eligible Lender a fee of 100 basis points
of the principal amount of the upsized tranche of the Eligible Loan at the
time of upsizing.
The Federal Reserve has announced an initiative that will enable up to $600 billion in new financing for eligible borrowers. This program will permit eligible
lenders to originate new loans to eligible borrowers or increase the size of existing loans, for loans originated before April 8, 2020.

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Main Street Lending Program Overview
Term
New Loans
(Main Street New Loan Facility – MSNLF)
Expanded Loans
(Main Street Expanded Loan Facility – MSELF)
Required
Attestations
• The Eligible Lender must attest that the proceeds of the Eligible Loan will not be
used to repay or refinance pre-existing loans or lines of credit made by the Eligible
Lender to the Eligible Borrower.
• The Eligible Borrower must commit to refrain from using the proceeds of the Eligible
Loan to repay other loan balances.
• The Eligible Borrower must commit to refrain from repaying other debt of equal or
lower priority, with the exception of mandatory principal payments, unless the
Eligible Borrower has first repaid the Eligible Loan in full.
• The Eligible Lender must attest that it will not cancel or reduce any existing lines of
credit outstanding to the Eligible Borrower. The Eligible Borrower must attest that it
will not seek to cancel or reduce any of its outstanding lines of credit with the
Eligible Lender or any other lender.
• The Eligible Borrower must attest that it requires financing due to the exigent
circumstances presented by the coronavirus disease 2019 (“COVID-19”) pandemic,
and that, using the proceeds of the Eligible Loan, it will make reasonable efforts to
maintain its payroll and retain its employees during the term of the Eligible Loan.
• The Eligible Borrower must attest that it meets the EBITDA leverage condition stated
in section 5(ii) of the paragraph above specifying required features of Eligible Loans.
• The Eligible Borrower must attest that it will follow compensation, stock repurchase,
and capital distribution restrictions that apply to direct loan programs under section
4003(c)(3)(A)(ii) of the CARES Act.
• Eligible Lenders and Eligible Borrowers will each be required to certify that the entity
is eligible to participate in the Facility, including in light of the conflicts of interest
prohibition in section 4019(b) of the CARES Act.
With respect to the upsized tranche:
• The Eligible Lender must attest that the proceeds of the upsized tranche of the Eligible
Loan will not be used to repay or refinance pre-existing loans or lines of credit made by
the Eligible Lender to the Eligible Borrower, including the pre-existing portion of the
Eligible Loan.
• The Eligible Borrower must commit to refrain from using the proceeds of the upsized
tranche of the Eligible Loan to repay other loan balances. The Eligible Borrower must
commit to refrain from repaying other debt of equal or lower priority, with the exception
of mandatory principal payments, unless the Eligible Borrower has first repaid the Eligible
Loan in full.
• The Eligible Lender must attest that it will not cancel or reduce any existing lines of credit
outstanding to the Eligible Borrower. The Eligible Borrower must attest that it will not
seek to cancel or reduce any of its outstanding lines of credit with the Eligible Lender or
any other lender.
• The Eligible Borrower must attest that it requires financing due to the exigent
circumstances presented by the coronavirus disease 2019 (“COVID-19”) pandemic, and
that, using the proceeds of the upsized tranche of the Eligible Loan, it will make
reasonable efforts to maintain its payroll and retain its employees during the term of the
upsized tranche of the Eligible Loan.
• The Eligible Borrower must attest that it meets the EBITDA leverage condition stated in
section 5(iii) of the paragraph above specifying required features of Eligible Loans.
• The Eligible Borrower must attest that it will follow compensation, stock repurchase, and
capital distribution restrictions that apply to direct loan programs under section
4003(c)(3)(A)(ii) of the CARES Act.
• Eligible Lenders and Eligible Borrowers will each be required to certify that the entity is
eligible to participate in the Facility, including in light of the conflicts of interest
prohibition in section 4019(b) of the CARES Act.
The Federal Reserve has announced an initiative that will enable up to $600 billion in new financing for eligible borrowers. This program will permit eligible
lenders to originate new loans to eligible borrowers or increase the size of existing loans, for loans originated before April 8, 2020.

24. 24
Tax Provisions

25. 25
into
Section 2301: Employee Retention Credit for Employers Subject to Closure or Experiencing Economic Hardship Due to COVID-19
• Refundable payroll tax credit for 50&% of wages paid by employers to employees during the COVID-19 crisis
• The credit is available to employers whose (1) operations were fully or partially suspended, due to a COVID-19-related shut-down
order, or (2) gross receipts declined by more than 50% when compared to the same quarter in the prior year
• The credit is based on qualified wages paid to the employee. For employers with greater than 100 full-time employees, qualified
wages are wages paid to employees when they are not providing services due to the COVID-19-related circumstance.
• The credit is provided for the first $10,000 of compensation, including health benefits, paid to an eligible employee
• The credit is provided for wages paid or incurred from March 13, 2020 through December 31, 2020.
Section 2302: Delay of Payment of Employer Payroll Taxes
• Allow employers to defer paying the employer portion of certain payroll taxes from 3/27/2020 to 12/31/2020, with deferred amounts
due in two equal installments:
• 50% at December 31, 2021
• 50% at December 31, 2022
• Payroll taxes that can be deferred include the employer portion of Social Security taxes
• 50% of payroll taxes incurred by self-employed individuals (i.e. partners) also qualify for the deferral.
• Employers who have applied for a PPP loan or received a PPP loan that is not yet forgiven, may defer deposit and payment of their
share of social security tax without penalties until the time that the employer receives a decision from its lender that the PPP loan is
forgiven.
Key Tax Provisions

26. 26
into
Section 2303: Modification of Net Operating Losses (NOLs)
• Modification of the treatment of NOL carrybacks
• In the case of taxable years beginning before 2021, taxpayers will be eligible to carry back NOLs to the prior five taxable years
• Effectively, this delays the 80% taxable income limitation until 2021 and temporarily extends the carryback period from zero to five years
• C corporations may elect to file for an accelerated refund to claim the carryback benefit
• This provision would modify the treatment of NOL carry forward
• For taxable years beginning before 2021, taxpayers will be entitled to an NOL deduction equal to 100% of taxable income (rather than the 80% limitation in present
law)
• In the case of taxable years beginning after 2021, taxpayers will be eligible for: (1) a 100 percent deduction of NOLs arising in tax years prior to 2018, and (2) a
deduction limited to 80% of modified taxable income for NOLs arising in tax years after 2017
Section 2304: Modification of Limitation on Losses for Taxpayers other than Corporations
• Retroactively turn off the excess active business loss limitation rule implemented with 2017 Tax Law by amending the provision to apply to tax years beginning after
December 31, 2020 (rather than December 31, 2017)
Section 2306: Modification of Limitation on Business Interest
• This provision generally allows businesses to elect to increase the interest limitation from 30% of Adjusted Taxable Income (“ATI) to 50% of ATI for 2019 and 2020,
and allows businesses to elect to use 2019 ATI in calculating their 2020 limitation
Section 2307: Qualified Improvement Property Technical Correction
• The CARES Acts corrects a Congressional oversight by defining Qualified Improvement Property as 15-year property, thus allowing 100% of improvements to be
deducted in the year incurred.
• The change was made as if it included in the original TCJA and, thus, is effective for property acquired and placed in service after September 27, 2017
Key Tax Provisions (continued)

27. 27
Summary & Questions

28. 28
COVID-19 Public Health Emergency
Funding MechanismsThe federal government has made monies available to eligible provider organizations through several mechanism. Below, please find an overview of the
funding mechanisms available to date. Please note that most of these mechanisms have additional terms and conditions that cover eligibility, use of funds,
and reporting requirements.
Funding Mechanism
Form of
Distribution
Purpose Agency Eligible Groups
Provider Relief Fund
Grant
(note: assuming subsequent
tranches follow same methodology
as initial tranche)
Cover costs associated with the preparing
for, preventing, and responding to COVID-19
HHS/CMS
• Hospitals/Health Systems
• Physician Practices
• Some Post-Acute
PPP Forgivable Loan
Support payroll expenses to reduce need for
layoffs/furloughs
SBA
• Some Hospitals (<500 employees)
• Physician Practices
• Some Post-Acute (<500 employees)
EIDL Loan
Provides working capital infusion at a low
interest rate
SBA
• Some Hospitals (<500 employees)
• Physician Practices
• Some Post-Acute (<500 employees)
Main Street Lending Facility Loan Providing needed liquidity to businesses Federal Reserve
• Most Hospitals/Some Health Systems (<10,000 employees)
• Physician Practices
• Most Post Acute (<10,000 employees)
Medicare Advance Payments
Cash Advance (interest applies after
recoupment period ends)
Provide needed liquidity to Medicare
providers
CMS • All Medicare Providers
FCC COVID-19 Telehealth Program
Reimbursement
(invoices/documentation required
for disbursement)
Provide funding for providers looking to
enhance telehealth capabilities
FCC
• Most Hospitals/Health Systems
• Some Physician Practices
• Some Post-Acute
FEMA Public Assistance Grant
Support costs associated with provision of
emergency response
FEMA
• Some Hospitals/Health Systems
• Few Physician Practices
• Some Post-Acute

29. evolution COVID -19 UPDATE
Q & A
actioninto

30. evolution COVID -19 UPDATE
FOR MORE INFORMATION:
actioninto
Kate Broderick, MBA, MSIS
Manager
kbroderick@citrincooperman.com
419.367.6334
Ronald Hegt, CPA
Partner
rhegt@citrincooperman.com
914.949.2990
Mitzi Hollenbeck, CPA, CFE
Partner
mhollenbeck@citrincooperman.com
401.421.4800
Michael Criscione, CPA
Partner
mcriscione@citrincooperman.com
401.421.4800

31. 31
Appendix

32. 32
FCC COVID-19 Telehealth Program:
Application Preparation
Step Details
Step 1: Obtain eligibility
determination from the Universal
Service Administrative Company
• Provider sites that have already secured a USAC eligibility determination may rely on that eligibility determination for the COVID-19
Telehealth program
• Interested providers who have not received a previous eligibility determination must submit FCC Form 460
• Applications that do not yet have an eligibility determination from USAC can still nonetheless file an application with the FCC for
the COVID-19 Telehealth program while their FCC Form 460 is pending
• Consortium applicants may file an FCC Form 460 on behalf of member health care providers if they have a Letter of Agency. The
Letter of Agency should be submitted as an attachment to FCC Form 460
Step 2: Obtain an FCC Registration
Number
• All applicants must register for an FCC Registration Number (FRN), which is unique to the business and used to identify the
registrant’s dealings with the FCC
• To register for an FRN, visit: https://apps.fcc.gov/cores/userLogin.do
• Users will need to provide their taxpayer identification number
Step 3: Register with System for
Award Management
• To receive payments through the program, applicants must be registered with the federal System for Award Management
• Applicants who are already registered do not need to re-register
• Registration can take up to 10 business days
• To register, go to: https://www.sam.gov/SAM/
• To register, applicants will need to provide: (a) Data Universal Number System; (b) Taxpayer Identification Number (TIN) or
Employment Identification Number (EIN); (c) Bank routing number, bank account number, and bank account type
• Only applicants registered through the System for Award Management will be able to received COVID-19 Telehealth Program
funding
Other Requirements
• Applicants will need to submit their Data Universal Number System Number (DUNS). To register for a DUNS number if an
organization does not already have one, visit https://fedgov.dnb.com/webform/displayHomePage.do or call 1-866-705-5711
The FCC has issued additional guidance on its COVID-19 Telehealth Program, including steps interested organizations should be taking
prior to the application process opening and additional detail on the content of the application.

33. 33
FCC COVID-19 Telehealth Program:
Additional Application Detail
Requirement Details
Medical Services to be
Provided
Applicants will check all that apply:
• Patient-Based Internet-Connected Remote Monitoring
• Other Monitoring
• Video Consults
• Voice Consults
• Imaging Diagnostics
• Other Diagnostics
• Remote Treatment
• Other Service
Conditions to be Treated
with COVID-19 Telehealth
Funding
• Whether the applicant will treat COVID-19 patients directly
• Whether the applicant will treat patients without COVID-19 symptoms or conditions (applicants will check all that apply):
o Other infectious diseases
o Emergency/Urgent Care
o Routine, Non-Urgent Care
o Mental Health Services (non-emergency)
o Other conditions
• How using COVID-19 Telehealth Program funding to treat patients without COVID-19 symptoms or conditions would free up resources that
will be used to treat COVID-19

34. 34
FCC COVID-19 Telehealth Program:
Additional Application Detail, continued
Requirement Details
Additional Information
Concerning Requested
Services and Devices
• Goals and objectives for use of the COVID-19 Telehealth Program Funding
• Timeline for deployment of the proposed service(s) or devices funded by the COVID-19 Telehealth Program
• Factors/metrics the applicant will use to help measure the impact of the services and devices funded by the COVID-19 Telehealth Program
• How COVID-19 has affected health care providers in your area
• Any additional information about the geographic area and population serve by the applicant. Indicate whether the geographic area you serve
has been under any pre-existing strain (e.g., large underserved or low-income patient population; HCP shortages; rural hospital closures;
limited broadband access and/or Internet adoption). If so, describe such factors
• Whether the applicant plans to target the funding to high-risk and vulnerable patients. If so, describe how
• Any additional information to support the application and request for funding
Requested Funding Items
• Total amount of funding requested
• Whether funding for devices is being requested. If so:
o How are the devices integral to patient care?
o Are the devices for patient use?
o Are the devices for the health care provider’s use?
Supporting Documentation
An applicant should provide supporting documentation for the costs indicated in its application. Such supporting documentation should
summarize the expected costs of the eligible services and devices requested and may include documentation such as an invoice or quote from a
vendor or service provider (or similar information). Such information should be specific enough to identify line-items to facilitate swift review of
the application, and we encourage applicants to include information such as a description of the service or device, its eligibility category, the
quantity ordered, the upfront and monthly expenses, and the service dates for recurring services