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

*** UPDATE 9/28/21: Phase 4 Provider Relief Fund General Distribution and American Rescue Plan rural payments ($17B for PRF #4, $8.5B for rural payments): The U.S. Department of Health and Human Services (HHS) has announced $25.5 billion in new funding for health care providers impacted by the COVID-19 pandemic. This includes $17 billion in Provider Relief Fund Phase 4 funding for providers who have experienced changes in operating revenues and expenses, as well as $8.5 billion in American Rescue Plan Rural funding for providers who provide Medicare, Medicaid, or Children’s Health Insurance Program (CHIP) services to rural beneficiaries. PRF Phase 4 payments will be based on providers' lost revenues and expenditures between July 1, 2020, and March 31, 2021.  ARP rural payments will be made to providers based on the amount of Medicaid, CHIP and/or Medicare services they provide to patients who live in rural areas as defined by the HHS Federal Office of Rural Health Policy.   Providers may apply for both programs via a single application on the Provider Relief Fund Application and Attestation Portal beginning Wednesday, September 29, 2021 through the final deadline of October 26, 2021.

    • Eligibility:  
      • PRF: Providers or suppliers who bill Medicare fee-for-service (Parts A and/or B) or Medicare Advantage, Medicaid (fee-for service or managed care) or CHIP
        • Phase 4 will also include new elements specifically focused on equity, including reimbursing smaller providers for their changes in operating revenues and expenses at a higher rate compared to larger providers, and bonus payments based on the amount of services providers furnish to Medicaid/CHIP and Medicare patient.
      • Rural payments: Providers who serve Medicaid, CHIP, and Medicare patients who live in rural communities are eligible for the ARP Rural payments
        • HRSA will price payments at the generally higher Medicare rates for Medicaid/CHIP patients.
    • Required documentation:
      • Applicant TIN and TINs for any subsidiaries included in the applicant TINs IRS tax filing.
      • Internally-generated financial statements that substantiate operating revenues and expenses from patient care in 2019 Q1, Q3, and Q4; 2020 Q3 and Q4; and 2021 Q1.
      • Form 990
    • More information from HRSA is available at this link.

The Paycheck Protection Program officially ended for new applications on May 31, 2021.

  • On August 4, 2021, the Small Business Administration launched a new "forgiveness portal" through which borrowers of $150,000 or less whose lenders are participating will apply directly for loan forgiveness, rather than beginning the process with their lenders.
      • Review the list of lenders participating in direct forgiveness to determine whether you must apply via SBA.  (Direct forgiveness borrowers MUST use the SBA forgiveness portal.)
      • The questions you will be asked in the portal correspond to those asked on SBA form 3508S.

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 September 8, 2021, the SBA has updated some of the details of this program.  
    • Two types of funding are available: 
      • 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. 
      • Emergency advances of up to $15,000 in funding from SBA that does not need to be repaid. These "advances" are similar to a grant, but without the typical requirements that come with a U.S. government grant.  To receive an advance, you must first apply for a COVID-19 EIDL. You do not need to accept the loan or be approved for the loan to receive an advance. Once you apply for the loan, SBA will invite you via email to apply for one of the advance programs if your business is located in a low-income area.
        • Eligibility: The law includes as eligible applicants “private non-profits” with 500 or fewer employees.  An employer can apply for and receive both a Paycheck Protection Program loan and EIDL loan, but the funds obtained cannot be used for the same purpose.  
        • Access: Access the application for the standard EIDL or the map to determine eligibility for the Advance payment.
  • Department of Treasury Economic Stabilization Fund/Main Street Business Lending Program: This program ended January 8, 2021.
  • Public Health and Social Services Emergency Fund: $100 billion in CARES 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. 

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.