Federal Funding Opportunities, New Requirements, and Updated Regulations

The information provided on this webpage does not, and is not intended to, constitute legal or tax advice.  We advise you to contact your own counsel or tax professional before taking any action. 

Federal Funding Opportunities

New and Expanded Federal Funding Opportunities in COVID Relief Laws

  • ***NEW UPDATE 5/5/21: Paycheck Protection Program loan funds have been mostly exhausted and the SBA has stopped processing new loan applications.  Two exceptions to this are noted below***
  1. The SBA has reserved approximately $6 billion in funding for lenders to finish processing pending applications that were already submitted to the agency.  (Entities whose applications have not yet been sent into the SBA for approval are likely unable to receive new loans at this point.)
  2. There is also approximately $8 billion remaining in congressionally mandated funding for PPP loans made by designated "community financial institutions" (minority depository institutions and community development financial institutions), which generally focus on lending to businesses run by women, minorities, and other underserved communities.  Those lenders will be allowed to process applications until that money runs out.  To the extent that entities still hoping to submit loan applications can submit them via community financial institutions, that may be a viable path to approval.

The Paycheck Protection Program:   Provides forgivable loans via the Small Business Administration (SBA).  Following enactment of the Coronavirus Response and Relief  Supplemental Appropriations Act on December 27, 2020, an additional "second draw" loan was added to the program and new application forms were issued.  Following enactment of the American Rescue plan on March 11, 2021, eligibility for first loans was expanded to nonprofit organizations with 500 or more employees across multiple locations, but with no more than 500 employees at a single one of those locations. Eligibility for Second Draw loans was also expanded to organizations that meet the other previous criteria and have 300 or more employees across multiple locations, but no more than 300 employees at a single one of those locations.   And as of March 30, 2021, following enactment  of the PPP Extension Act, the deadline for submitting loan applications was extended to May 31, 2021.  (The program had been set to end on March 31.) 

  • 3/15/21: Updated information from the Employment and Training Administration (Department of Labor): Guidance on Covering Unemployment Costs of Reimbursing Employers
  • 12/16/20: HHS begins distribution of funding for Phase 3 Provider Relief Fund General Distribution ($24.5B available, up from $20B expected): The Department of Health and Human Services earlier this fall announced $20 billion in new funding for providers on the frontlines of the coronavirus pandemic. Under this Phase 3 General Distribution allocation, providers that have already received Provider Relief Fund payments were invited to apply for additional funding that considers financial losses and changes in operating expenses caused by the coronavirus. Previously ineligible providers, such as those who began practicing in 2020 werealso be invited to apply, and an expanded group of behavioral health providers confronting the emergence of increased mental health and substance use issues exacerbated by the pandemic were also made eligible for relief payments.  Providers could apply for funds on the Provider Relief Fund Application and Attestation Portal between Monday, October 5, 2020 until November 6, 2020. 
    • Eligibility: HHS is making a large number of providers eligible for Phase 3 General Distribution funding, including:
      • Providers who previously received, rejected or accepted a General Distribution Provider Relief Fund payment. Providers that have already received payments of approximately 2% of annual revenue from patient care may submit more information to become eligible for an additional payment.
      • Behavioral Health providers, including those that previously received funding and new providers.
      • Healthcare providers that began practicing January 1, 2020 through March 31, 2020. This includes Medicare, Medicaid, CHIP, dentists, assisted living facilities and behavioral health providers.
  • FEMA Public Assistance Grants: Private nonprofit (PNP) organizations that provide educational, utility, emergency, medical, or custodial care, including for the aged or disabled, and other essential social-type services to the general public, and who are experiencing additional unreimbursed expenses due to having to respond to the Coronavirus pandemic, may be eligible to apply for the FEMA Public Assistance Grant Program.  Please see our more detailed summary here. 
  • Economic Injury Disaster Loans (EIDL): As of June 15, the SBA has re-opened this program for new applications.  
    • Creates emergency grants for eligible nonprofits harmed by COVID-19 enabling them to receive an emergency advance of up to $10,000 within three days of applying for an SBA Economic Injury Disaster Loan (EIDL). EIDLs are lower interest loans of up to $2 million, with principal and interest deferment at the discretion of the SBA, that are available to pay for expenses that could have been met had the disaster not occurred, including payroll and other operating expenses. The advance does not need to be repaid under any circumstance, and may be used to keep employees on payroll, to pay for sick leave, meet increased production costs due to supply chain disruptions, or pay business obligations, including debts, rent and mortgage payments.
  • Department of Treasury Economic Stabilization Fund/Main Street Business Lending Program: Gives the Treasury the authority to develop a program to provide loans to nonprofit organizations (along with other businesses) through December 31, 2020. Loans made under the program would be at an interest rate no higher than 2%, with no payments due in the first six months, and would not be forgivable.
      • Eligibility: Businesses with up to 15,000 employees or up to $5 billion in 2019 annual revenues. Funds must be used to retain at least 90 percent of the recipient’s workforce, with full compensation and benefits, through September 30, 2020. 
        • As of April 30: The Federal Reserve has published an FAQ indicating that nonprofits are NOT currently eligible (see Question E6) but has stated that they recognize "the critical role that nonprofit organizations play throughout the economy and [are] evaluating a separate approach to meet their unique needs."
        • On June 15, the Federal Reserve announced it is seeking public feedback on a proposal to expand access to the Main Street Lending Program to nonprofits, as provided for under the Coronavirus Aid, Relief, and Economic Security (CARES) ActLutheran Services in America has submitted comments on this proposal to Fed officials, calling for the agency to implement a program that offers forgivable loans for nonprofits, including those with more than 500 employees.

      • Access: The Treasury and the Federal Reserve have issued initial guidance indicating that banks will be approving and issuing these loans, with the government assuming much of the risk.
  • HHS funding for Medicaid providers via CARES Act's Provider Relief Fund:  The deadline to apply for Phase 2 general distribution funding was extended to September 13, 2020The Department of Health and Human Services announced the next round of targeted funding via the CARES Act’s $100 billion Provider Relief Fund, of $15 billion for eligible Medicaid providers who participate in state Medicaid programs and haven't received a payment from the Provider Relief Fund General Distribution.  HHS will launch an enhanced Provider Relief Fund Payment Portal that will allow eligible Medicaid providers to report their annual patient revenue, which will be used as a factor in determining their Provider Relief Fund payment. The payment to each provider will be at least 2 percent of reported gross revenue from patient care; the final amount each provider receives will be determined after the data is submitted, including information about the number of Medicaid patients providers serve.  Examples of eligible providers include home and community-based services providers (including those serving people with intellectual and developmental disabilities), and assisted living facilities . 
  • Public Health and Social Services Emergency Fund: $100 billion in CARES plus for a new program to provide grants to hospitals, public entities, nonprofit entities, and Medicare and Medicaid enrolled suppliers and institutional providers that provide diagnoses, testing, or care for individuals with possible or actual cases of COVID–19, to cover unreimbursed health care related expenses or lost revenues attributable to the coronavirus public health emergency.
      • Eligibility: "Hospitals and health care providers." While hospitals right now are the main focus of this funding, other providers should be eligible depending on availability of funds.
      • Access: HHS has begun awarding some of these funds directly to Medicare providers and hospitals who have been strongly impacted by the coronavirus. HHS has also said that "there are some providers who will receive further, separate funding, including skilled nursing facilities, dentists, and providers that solely take Medicaid," but has not made clear yet how that funding will be distributed or specifically to whom. 
  • $50 million for Section 202 Housing for the Elderly to make up for reduced resident rent payments as a result of the coronavirus, maintain housing stability, and to help communities pay for costs associated with the coronavirus. Allows up to $10 million to be used for Service Coordinators and the continuation of existing congregate service grants.
      • Eligibility: The funds are to be used to prevent, prepare for, and respond to the coronavirus. This includes funds to “maintain normal operations” and take “other necessary actions” and for “assistance to owners or sponsors” of the Section 202 program.
      • Access: It is not yet clear how these funds will be distributed. On March 25, HUD’s Office of Multifamily Housing said that that they will put out guidance soon on how these funds will be accessed. For now, HUD officials said they believe HUD-assisted owners may be able to access these funds via the normal voucher process.
  • Department of Housing and Urban Development 
    • In July, HUD announced the initial request period for COVID-19 Supplemental Payments via the CARES Act.  Now, a new HUD notice establishes a second request window and updates the submission requirements. The filing deadline for multifamily housing owners was December 11, 2020 for expenses incurred through November 30; properties that did not receive payments for the earlier timeframe (March 27-July 31) may resubmit for that period as well.

  • $800 million (of $1 billion total approved in the CARES Act) from the Department of Housing and Urban Development for Project-Based Rental Assistance:
      • On June 1, HUD published a funding allocation update.
      • HUD completed $800 million in funding allocations during the week of June 1 to help communities prevent, prepare for, and respond to the coronavirus through regular operations.
  • $200 million dollars for Home and Community Based Services (HCBS) under Title III-B of the Older Americans Act via the Administration for Community Living (ACL).  The HCBS services are those funded under the Older Americans Act, which can help seniors with personal care assistance; help with household chores and grocery shopping; transportation to essential services (such as grocery stores, banks, or doctors) when necessary; and case management.
      • Eligibility: This money is specifically for “support services” and for “existing grantees.”
      • Access: Per statutory requirements, those funds were issued from ACL via formula to grantees, the State Units on Aging.  The grantees are then required to distribute service funding through their intrastate funding formula to their Area Agencies on Aging to administer the Title III Supportive Services program. 
  • HHS funding for SNFs via CARES Act's Provider Relief Fund: The Department of Health and Human Services announced the next round of targeted funding via the CARES Act’s $100 billion Provider Relief Fund, with directed funding for SNFs. The money will be distributed automatically to qualified skilled nursing facilities, who will then be required to submit an attestation about how they’re using the money. Each SNF will receive a fixed distribution of $50,000, plus a distribution of $2,500 per bed. All certified SNFs with six or more certified beds are eligible for this targeted distribution. More information is expected to come.

State Grant Opportunities

Find state grant opportunities available to faith-based and nonprofit organizations with COVID-19 expenses.

Requirements & Regulations

New requirements or updated regulations stemming from the Coronavirus crisis.

  • Families First Coronavirus Response Act: The bill includes a complex set of temporary paid leave mandates and employer reimbursement provisions, as well as funding for free coronavirus testing, food nutrition security, and unemployment insurance enhancements. It also suspends work requirements for the supplemental nutrition assistance program (SNAP).
  • 1135 Waiver Guidance: 1135 waivers can be issued by the Secretary of Health and Human Services in response to an emergency situation like the COVID-19 pandemic and allow certain requirements in Medicaid to be modified or waived to ensure that sufficient health care items and services are available to meet the needs of Medicaid enrollees in affected areas. Our providers should review these flexibilitie, determine whether their state has already applied for a waiver, and be sure to work directly with their state Medicaid director and Governor to communicate their needs.