Deadline Approaching For Dental Provider Relief Funds

Husch Blackwell LLP

On July 10, 2020, the U.S. Department of Health and Human Services (HHS) announced dentists and other dental providers are eligible to apply for relief from the Provider Relief Fund. The Provider Relief Fund General Distribution FAQs outlined the eligibility requirements and payment methodology for calculating distribution amounts. The deadline for applying is July 24, 2020.


Dental providers must not have billed Medicare or Medicaid for services rendered (and therefore did not receive a Medicare-focused General Distribution Fund payment) and must meet additional requirements to be eligible for funding from the Provider Relief Fund, as follows:

  • The provider’s practice is operating in good standing;
  • The provider’s practice is not excluded from receiving federal payments; 
  • The provider’s practice has not previously received Provider Relief Fund payments for Medicare-focused, Medicaid, or CHIP Distribution programs; 
  • Filed a tax return with the IRS for FY 2017, 2018 or 2019 or is exempt from filing a tax return (as well as a beneficial owner), e.g. state-owned provider. If the applicant is an individual, he or she must also have gross receipts, or the dollar amount of patient care sales indicated on Form 1040, Schedule C, Line 1, excluding income reported on a W-2 as an employee; and 
  • Provided patient care on February 1, 2020, and after without permanently ceasing to provide patient care directly or indirectly through included subsidiaries.

In order to identify dental providers who did not receive the Medicare-focused distribution, and therefore are eligible for this Provider Relief Fund distribution, HHS obtained the TINs of eligible dental providers, including those who do not participate in the Medicare and Medicaid programs, and created a curated list. HHS plans to work with states and vendors to authenticate providers not included on the list. 

Unfortunately, there is no efficient way for dental providers to determine whether it is on the eligibility list without attempting to complete the online Provider Relief Fund application. Providers not on the list will be notified by HHS after it attempts to apply for funding and will have to undergo additional review by HHS before being permitted to continue the application process. Because it is possible to be eligible for the relief payment and not be on the HHS curated list, it is important to begin the application process early, to allow time for the possible additional review.

Payment calculation

Payment will be approximately 2 percent of the dental provider’s patient care revenue reported on the most recent tax filing.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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