Author: Aaron Mauer

The Corporate Transparency Act (CTA) was enacted as part of the National Defense Act for Fiscal Year 2021. The CTA mandates that millions of entities report their beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN). This resource is meant to provide a preliminary overview of the provisions in the CTA. 

Who is required to report under the CTA’s BOI reporting requirements?

1. All domestic and foreign entities that have files formation or registration documents with the U.S. state (or Indian tribe), unless they meet one of the 23 exceptions (See question # 8 of FinCEN FAQs for a full list of exemptions), including:
   • EXEMPT: Large operating entities that meet the following criteria:
     • Employ more than 20 people in the U.S.
     • Had gross revenue / sales over $5 million on the prior year’s tax return
     • Has a physical office in the U.S.
   • EXEPT: Publicly traded companies that have registered under Section 102 of SOX

When must companies file?

• New entities created / registered after 12/31/2023 – must file within 30 days
• Existing entities created / registered before 1/1/2024 – must file by 1/1/2025
• Reporting companies that have changes to previously reported information or discover inaccuracies in previously filed reports – must file within 30 days.

What information do companies need to report?

• Each company must report the information below. Click or tap here for an example of the form.
  • Full legal name of the reporting company and any DBA names
  • Business addresses
  • State of formation or registration
  • IRS TIN
• In addition, each reporting company must report the following details on it beneficial owners and, for the newly created entities, its company applicants(s):
  • Name
  • Birthdate
  • Address
  • Unique Identification number and issuing jurisdiction from an acceptable identification document (and image of said document)

What are the taxpayer penalties for noncompliance with the statute?

• Civil penalties are up to $500 per day that a violation continues. 
•  Criminal penalties include a $10,000 fine and/or up to 2 years of imprisonment. 

For more information:

• Visit the AICPA aicpa-cima.com/resources/landing/beneficial-ownership-information-boi-reporting

If a provider rejects a payment and the associated Terms and Conditions in the attestation portal but decides to keep the funds after rejecting it in the attestation portal, what should the provider do in order to report on the use of funds kept? (Added 6/30/2022)

Providers who rejected one or more Provider Relief Fund payments exceeding $10,000, in aggregate, and kept the funds are required to report on these funds during the applicable reporting period per the Terms and Conditions associated with the payment(s). In order to be able to report on the use of funds, a provider must contact the Provider Support Line at (866) 569-3522 (for TTY, dial 711) to request a change to their attestation from “rejected” to “accepted.” Once the attestation status has been updated in the attestation portal, the Provider Relief Fund Reporting Portal will subsequently be updated to accurately reflect the kept payment that the provider is required to report on during the applicable reporting period.

Why would a provider not be eligible for a General or Targeted Distribution Provider Relief Fund payment? (Modified 6/30/2022)

In order to be eligible for a payment under the Provider Relief Fund, a provider must meet the eligibility criteria for the distribution and must be in compliance with the Terms and Conditions for any previously received Provider Relief Fund payments. Additionally, a provider must not be currently terminated from participation in Medicare or precluded from receiving payment through Medicare Advantage or Part D; must not be currently excluded from participation in Medicare, Medicaid, and other Federal health care programs; and must not currently have Medicare billing privileges revoked as determined by either the Centers for Medicare & Medicaid Services or the HHS Office of Inspector General in order to be eligible to receive a payment under the Provider Relief Fund.

How do I appeal or dispute a payment decision? (Modified 6/30/2022)

In the event that you would like to appeal or dispute a payment decision, first review Phase 4 and/or ARP Rural payment methodology available at https://www.hrsa.gov/providerrelief/future-payments/phase-4-arp-rural/payment-methodology. If you believe your payment was calculated incorrectly, submit a completed PRF Reconsideration Request Form available at https://powerforms.docusign.net/034c7d84-45d9-40c2-9d0bc4648f225bc3?env=na3&acct=dd54316c-1c18-48c9-8864- 0c38b91a6291&accountId=dd54316c-1c18-48c9-8864-0c38b91a6291. HRSA is only reconsidering Phase 4 General Distribution and ARP Rural applications and payments at this time. For more information, please review HRSA’s Phase 4 and ARP Rural Reconsiderations page, available at https://www.hrsa.gov/provider-relief/paymentreconsideration. Any changes to payment determinations are subject to the availability of funds.

How do I know if I am eligible for a Phase 4 – General Distribution payment? (Modified 6/30/2022)

You must meet all of the five eligibility requirements for the Phase 4 – General Distribution, which include

1. Falling into one of the following categories:

1. Must have either directly billed, or owns (on the application date) an included subsidiary that has directly billed, their state/territory Medicaid program (fee-for service or managed care) or Children’s Health Insurance Program (CHIP) for health care-related services during the period of January 1, 2019 to December 31, 2020;
2. Must be a dental service provider who has either directly billed, or owns (on the application date) an included subsidiary that has directly billed, health insurance companies or patients for oral health care-related services during the period of January 1, 2019 to December 31, 2020;
3. Must have either directly billed, or owns (on the application date) an included subsidiary that has directly billed, Medicare fee-for-service (Parts A and/or B) or Medicare Advantage (Part C) for health care-related services during the period of January 1, 2019 to December 31, 2020;
4. Must be a state-licensed/certified assisted living facility on or before December 31, 2020;
5. Must be a behavioral health provider who has either directly billed, or owns (on the application date) an included subsidiary that has directly billed, health insurance companies or patients for health care-related services during the period of January 1, 2019 to December 31, 2020; or
6. Must have received a prior Targeted Distribution payment.

2. Having either (i) filed a federal income tax return for fiscal years 2018, 2019, or 2020, or (ii) be an entity exempt from the requirement to file a federal income tax return and have no beneficial owner that is required to file a federal income tax return (e.g. a state-owned hospital or health care clinic); and
3. Having provided patient care after January 31, 2020; and
4. Having not permanently ceased providing patient care directly, or indirectly through included subsidiaries; and
5. If the applicant is an individual that was providing patient care, having gross receipts or sales from providing patient care reported on Form 1040, Schedule C, Line 1, excluding income reported on a W-2 as a (statutory) employee.

You also:

• Must not be currently terminated from participation in Medicare or precluded from receiving payment through Medicare Advantage or Part D;
• Must not be currently excluded from participation in Medicare, Medicaid, and other Federal health care programs;
• Must not currently have Medicare billing privileges revoked; and
• Must be in compliance with the Terms and Conditions for any previously received Provider Relief Fund payments.

In addition, your billing or filing TIN must be included in the list of providers that HRSA has determined to be eligible or your application must pass additional validation by HRSA. Some providers may be eligible for a payment but the payment calculation will be $0 due to risk mitigation and cost containment safeguards.

This notice provides clarification to nursing facilities (NFs) regarding the provider notices issued June 2, 2022, and June 21, 2022.

The Department of Healthcare and Family Services (HFS) continues to work with industry representatives and other stakeholders to implement the new pay-scale subsidy program that was adopted by the legislature in April and signed into law in Public Act 102-1035 earlier this month. Resolution of some basic questions regarding data submission and potential facility flexibility in the timing of pay-scale adoption remains under discussion. Nevertheless, HFS encourages facilities to continue to collect information and submit it on SharePoint (as addressed in the two previous notices) even if their participation in the pay-scale program remains uncertain.  Submission of CNA experience and promotion information using the CNA Incentive Payment templates that were posted in each facility’s SharePoint folders earlier this week does not obligate a nursing home to participate in the program if the facility does not also sign the included attestation. As conveyed in those templates, questions may be submitted via email addressed to ILNF@mslc.com. The Department is already using this feedback to improve the pay-scale program’s technical design and implementation.

To support its rapid rollout of this new program, HFS plans to host a webinar for NFs and interested parties that will provide an overview of the CNA pay-scale program and address related questions. The webinar will occur on Monday, June 27, 2022, from 9:00 -11:00 a.m. Please use the following link to access the webinar:

June 27 Webinar on CNA Template and Payments

In addition to announcing the webinar, HFS would like to provide in this notice some additional explanation regarding the optional pay-scale program being implemented July 1, 2022. As a reminder, this program offers Medicaid subsidies to NFs that choose to implement experience-based and/or promotion-based wage increments to their qualifying certified nursing assistant (CNA) employees.

This new pay-scale initiative is intended to provide funding to NFs if, and when, they choose to implement qualifying wage increases for CNAs. The program’s subsidies are designed to compensate NFs for Medicaid’s share (based on Medicaid’s share of resident days in the facility) of minimum qualifying pay-scale wage increments. These subsidies are only available for an NFs’ employed CNAs. Participating NFs may choose larger CNA wage increments for experience and/or promotional role, but Medicaid will pay its share of only the minimum amounts, which are as follows:

For CNAs in one of the following promotional roles (which may include those defined by a facility; see “Other”) the minimum qualifying wage increment is $1.50 per hour:

• CNA II (with Advanced Nursing Aide Training)
• CNA Trainer, Preceptor, or Mentor
• CNA Scheduling Captain
• CNA Dementia or Memory Care Specialist
• CNA Behavioral Health Specialist
• CNA Geriatric Specialist
• CNA Infection Control Specialist
• CNA Activities Specialist
• CNA Cardiopulmonary Resuscitation (CPR) Educator
• Other (as specified)

NFs are free to choose to implement an experience pay-scale, a promotional pay-scale, both or neither. If they implement both, the increments must be additive for the employee. HFS will begin subsidizing qualifying CNA pay-scales beginning July 1, 2022, although NFs may choose to implement at a later date. To qualify for the subsidy, pay-scales must be posted for employees to view.

Calculating Eligible Expenses and Lost Revenue Can a Reporting Entity use a different lost revenues methodology for each reporting period? (Added 1/27/2022) Yes. However, it is important to note that due to the overlapping periods of availability, each time a Reporting Entity changes the method used to calculate lost revenues, the system will recalculate total lost revenues for the entire period of availability. It is important to note that due to the overlapping periods of availability, if a Reporting Entity changes the method used to calculate lost revenues, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues. The system will also require that the Reporting Entity submit a written justification to support and explain the change in lost revenues methodology. Please refer to the Post-Payment Notice of Reporting Requirements for information on the three available methodologies for calculating lost revenues.

In subsequent reporting periods, will Reporting Entities be able to change the lost revenues methodology used in a previous reporting period? (Added 1/27/2022) Yes. Reporting Entities that previously reported will be able to choose a different methodology for calculating lost revenues during Reporting Period 2 and any subsequent reporting periods. However, if the Reporting Entity decides to use a different methodology, they must then use the new methodology to calculate lost revenues for the entire period of availability. The Reporting Entity will be required to submit a justification for the change. If a Reporting Entity chooses a different methodology, lost revenues by quarter will not pre-populate from the previous reporting period. It is important to note that due to the overlapping periods of availability, if a Reporting Entity changes the method used to calculate lost revenues, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues. Please refer to the Post-Payment Notice of Reporting Requirements for information on the three available methodologies for calculating lost revenues.

In a previous reporting period, a Reporting Entity reported lost revenues that were greater than the PRF payments it received. How will the system account for the unused lost revenues previously reported? (Added 1/27/2022) The PRF Reporting Portal was designed so that each subsequent report will build from the previous completed and submitted report. The Reporting Portal will calculate remaining unused lost revenues that can be reimbursed by PRF payments received during future payment periods. If a Reporting Entity had more lost revenues for the overlapping period of availability than the Entity was able to demonstrate in a previous reporting period, then the Reporting Entity will be able to reimburse the unused lost revenues with payments issued in subsequent periods. It is important to note that due to the overlapping periods of availability, if a Reporting Entity changes the method used to calculate lost revenues from one reporting period to another, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues.

In a previous reporting period, a Reporting Entity reported lost revenues that were greater than the PRF payments it received. How will the system account for the unused lost revenues previously reported? (Added 1/27/2022) The PRF Reporting Portal was designed so that each subsequent report will build from the previous completed and submitted report. The Reporting Portal will calculate remaining unused lost revenues that can be reimbursed by PRF payments received during future payment periods. If a Reporting Entity had more lost revenues for the overlapping period of availability than the Entity was able to demonstrate in a previous reporting period, then the Reporting Entity will be able to reimburse the unused lost revenues with payments issued in subsequent periods. It is important to note that due to the overlapping periods of availability, if a Reporting Entity changes the method used to calculate lost revenues from one reporting period to another, the system will recalculate total lost revenues for the entire period of availability, which may impact the previously reported unreimbursed lost revenues.

What happens when a Reporting Entity changes the lost revenues methodology from one reporting period to the next? (Added 1/27/2022) When a Reporting Entity chooses a different lost revenues methodology from one reporting period to the next, the system requires confirmation of the change by the Reporting Entity. If the lost revenues methodology changes, data submitted in the prior reporting period is not prepopulated into the current report (as it would be if the same methodology was used from one reporting period to the next).

After a change in methodology is saved in the current report, the What happens when a Reporting Entity changes the lost revenues methodology from one reporting period to the next? (Added 1/27/2022) When a Reporting Entity chooses a different lost revenues methodology from one reporting period to the next, the system requires confirmation of the change by the Reporting Entity. If the lost revenues methodology changes, data submitted in the prior reporting period is not prepopulated into the current report (as it would be if the same methodology was used from one reporting period to the next). After a change in methodology is saved in the current report, the

Can Nursing Home Infection Control payments be used to reimburse lost revenues attributable to coronavirus? (Added 1/27/2022) No. Per the payment Terms and Conditions, the Nursing Home Infection Control Distribution (including any Quality Incentive Program payments) may not be used to reimburse lost revenues.

If a nursing home or skilled nursing facility received Nursing Home Infection Control Distribution payments in addition to General Distribution payments and other Targeted Distribution payments, how may these payments be applied toward expenses and lost revenues? (Added 1/27/2022) PRF recipients have the flexibility to identify how to use their multiple payments toward expenses and lost revenues, but must abide by the Terms and Conditions associated with each of the payments and follow the requirements for determining allowable expenses and lost revenues. The Nursing Home Infection Control Distribution, which includes the Quality Incentive Program payments, may only be used to reimburse infection control expenses. This type of Targeted Distribution payment may not reimburse lost revenues. PRF payments may be used as described in the relevant payment Terms and Conditions for expenses and lost revenues, as appropriate, dating back to January 1, 2020. Because of the overlapping periods of availability, providers have the flexibility to identify which payments they will use to reimburse allowable expenses and lost revenues incurred during the period of availability. Duplication of reimbursement for expenses and lost revenues is not permitted.

When completing a report, are Reporting Entities required to submit documentation to support Nursing Home Infection Control Distribution expenses? (Added 1/27/2022) No. Documentation to support Nursing Home Infection Control Distribution expenses is not required to be uploaded to the PRF Reporting Portal at the time of reporting. However, Reporting Entities are required to maintain supporting documentation, per the Terms and Conditions, that demonstrates that any allowable expenses were incurred during the period of availability. Supporting documentation must be made available upon the request of the Secretary of the Department of Health and Human Services.

If the original recipient of a Targeted Distribution payment is a subsidiary, and the recipient transferred that payment to a parent entity, how does the original recipient (i.e., subsidiary) demonstrate the use of funds in its report? Is it sufficient for the subsidiary to report the amount transferred to the parent entity? (Added 1/27/2022) For any subsidiary that was the original recipient of a Targeted Distribution payment reporting on a payment spent by a parent entity, the expense worksheet(s) in the subsidiary report must include any expenses applied to the payment, whether those were the expenses of the subsidiary or the entity to which the payments were transferred. For any subsidiary Reporting Entity reporting on how a payment was used to reimburse lost revenues, the subsidiary Reporting Entity can use the alternative method for calculating lost revenues and demonstrate in their method how the lost revenues of the parent or other subsidiary entity to which the payment was transferred was considered in the lost revenues calculation. Using the alternative reasonable methodology will allow Reporting Entities to reduce the parent entity’s report by the amount of lost revenues accounted for by the Targeted Distribution payment originally received by the subsidiary. The subsidiary Reporting Entity that originally received the Targeted Distribution should report the exact amount of lost revenues as the Targeted Distribution payment and the same dollar amount by which the parent entity’s lost revenues were reduced. The deductions and reconciliations must be accounted for in each methodology calculation for the parent and subsidiary that originally received the Targeted Distribution payment. Both reports together should be sufficient for audit purposes.

If a Reporting Entity plans to report on General Distribution payments that were transferred from a subsidiary that received the initial payment, how should patient care revenue or lost revenues be aggregated and reported in the portal? (Added 1/27/2022) HRSA does not prescribe which method Reporting Entities should use to calculate lost revenues. However, Option iii, “alternate reasonable methodology,” provides the greatest flexibility in unique circumstances.

If a Reporting Entity returned funds and the returned funds are not reflected in the “Payments to Recipients” page in the PRF Reporting Portal, what should the Reporting Entity do? (Added 1/27/2022)

There may be a delay between the time a payment is returned by a PRF recipient and the time the payment is reconciled by HRSA. If a Reporting Entity does not see a returned payment reflected in the Payments to Recipients page of the PRF Reporting Portal, the Reporting Entity should contact the Provider Support Line at 866-569-3522 (for TTY, dial 711) to provide information about the return (e.g., original payment date, amount returned, date of return, method of return) to assist HRSA in the reconciliation of the returned payment amount.

If a Reporting Entity returns unused funds in excess of the amount owed, will HRSA repay the Entity the difference between what was owed and returned? (Added 1/27/2022) HRSA will not repay Reporting Entities the difference in unused funds that were owed and the amount that was returned.

Are Provider Relief Fund recipients required to notify HRSA if they have filed a bankruptcy petition? (Added 12/9/2021)

Yes. Provider Relief Fund recipients must immediately notify HRSA about their bankruptcy petition or involvement in a bankruptcy proceeding so that the Agency may take the appropriate steps. When notifying HRSA about a bankruptcy, please include the name that the bankruptcy is filed under, the docket number, and the district where the bankruptcy is filed. You must submit this information to PRFbankruptcy@hrsa.gov. If a Provider Relief Fund recipient has filed a bankruptcy petition or is involved in a bankruptcy proceeding, federal financial obligations will be resolved in accordance with the applicable bankruptcy process, the Bankruptcy Code, and applicable non-bankruptcy federal law.

What financial transactions are Reporting Entities required to report in order to satisfy the requirement in the Terms and Conditions for Phase 4 that recipients must notify HHS of a merger with or acquisition of any other health care provider during the Payment Received Period within the Reporting Time Period? (Added 12/9/2021)

The Terms and Conditions for Phase 4 require that recipients that receive payments greater than $10,000 notify HHS during the applicable Reporting Time Period of any mergers with or acquisitions of any other health care provider that occurred within the relevant Payment Received Period. HRSA considers changes in ownership, mergers/acquisitions, and consolidations to be reportable events.

Do commercial organizations that do not submit their audit through the Federal Audit Clearinghouse get an extension to the submission due date for their audit? (Added 12/9/2021)

Yes. Both commercial organizations and non-federal entities are granted a six-month extension to the submission of audits that have a fiscal-year end through June 30, 2021. As a reminder, audits are due 30 calendar days after receipt of the audit report or nine months after the end of the audit period – whichever is earlier. On March 19, 2021, the Office of Management and Budget (OMB) Memo (M-21-20) extended the deadline for Single Audit submissions to six months beyond the normal due date, and on October 28, 2021, HHS granted the same extension to commercial organizations. If you have questions about this extension or want to inform HRSA you will be taking advantage of this flexibility, please email HRSA’s Division of Financial Integrity at PRFaudits@hrsa.gov. If you have questions about the audit in accordance with 45 CFR 75.501 for Provider Relief Fund payments, please email your questions to ProviderReliefContact@hrsa.gov.

Why is HRSA requiring Reporting Entities to report patient metrics? (Added 12/9/2021)

HRSA is requiring Reporting Entities to report patient metrics to gather information on the number of patients treated by Provider Relief Fund recipients. Depending on recipient type, these patients may be treated in either inpatient, outpatient, or residential settings. These metrics enable HRSA to quantify respective volumes of inpatient, in-person, and virtual outpatient visits, as well as emergency visit patients.

What if a Reporting Entity does not believe their patient encounters align with one of the patient visit type options? (Added 12/9/2021)

If a Reporting Entity cannot identify a fitting patient visit type for their patient encounters, the entity should count the distinct encounters or visits in the category that is the most fitting category available.

Should state and federal tax credits (e.g., employee retention tax credits) be reported as “other assistance received?” (Added 12/9/2021)

No. Tax credits are not considered a revenue source for purpose of reporting within the Provider Relief Fund report.

If a merger or acquisition was planned before receiving Phase 4 General Distribution payments, will health care providers still need to report these activities? (Modified 12/9/2021)

If a Reporting Entity that received a Phase 4 General Distribution payment undergoes a merger or acquisition during the Payment Received Period, as described in the Post-Payment Notice of Reporting Requirements, the Reporting Entity must report the merger or acquisition during the applicable Reporting Time Period.

What type of review will HRSA do after a merger or acquisition has been reported by recipients of a Phase 4 General Distribution payment? (Modified 12/9/2021)

If a Reporting Entity that received a Phase 4 General payment indicates when they report on the use of funds that they have undergone a merger or acquisition during the applicable Payment Received Period, this information will be a component that is factored into whether an entity is audited.

What financial transactions are Reporting Entities required to report in order to satisfy the requirement in the Terms and Conditions for ARP Rural payments that recipients must notify HHS of a merger with or acquisition of any other health care provider during the Payment Received Period within the Reporting Time Period? (Modified 12/9/2021)

The Terms and Conditions for ARP Rural payments require that recipients that receive payments greater than $10,000 notify HHS during the applicable Reporting Time Period of any mergers with or acquisitions of any other health care provider that occurred within the Payment Received Period. HRSA considers changes in ownership, mergers/acquisitions, and consolidations to be reportable events.

If a merger or acquisition was planned before receiving ARP Rural payments, will health care providers still need to report these activities? (Modified 12/9/2021)

If a Reporting Entity that received an ARP Rural payment undergoes a merger or acquisition during the Payment Received Period, the Reporting Entity must report the merger or acquisition during the applicable Reporting Time Period.

What type of review will HRSA do after a merger or acquisition has been reported by recipients of an ARP Rural payment? (Modified 12/9/2021)

If a Reporting Entity that received an ARP Rural payment indicates when they report on the use of funds that they have undergone a merger or acquisition during the applicable Payment Received Period, this information will be a component that is factored into whether an entity is audited.

Can a provider that purchased, merged with, or consolidated with another entity (purchaser/new owner) in 2019, 2020, 2021, or 2022, accept a Provider Relief Fund payment from a seller/previous owner, and complete the attestation for the Terms and Conditions? (Modified 12/9/2021)

The answer depends on the status of the TIN that received the PRF payment. The purchaser/new owner cannot accept the payment directly from another entity nor attest to the Terms and Conditions on behalf of the seller/previous owner in order to retain the Provider Relief Fund payment, including payment under the Nursing Home Infection Control Quality Incentive Payment Program, unless the seller’s Medicare provider agreement and TIN was accepted by the purchaser in the transaction. However, the purchaser/new owner may apply for and/or receive future funds.

The Internal Revenue Service has announced annual inflation adjustments for tax year 2022, meaning new tax-rate schedules and tax tables and cost- of-living adjustments for various tax breaks. Most numbers are up more than in recent years because of higher inflation. Note: These numbers, for the tax year beginning January 1, 2022, are what you’ll use to prepare your 2022 tax returns in 2023.

If you do not anticipate any significant changes like getting married or starting a new job, for example you can use the new numbers to estimate your 2022 federal tax liability. If you’re expecting major changes, make sure you check your tax withholding and/or make quarterly estimated tax payments.

There still is one large caveat to the 2022 numbers:

Democrats are still trying to pass the now $1.85 trillion Build Back Better Act, and the latest (November 3) legislative text includes income tax surcharges on the rich as well as an $80,000 cap—up from $10,000—for state and local tax deductions. Earlier versions included cutting the estate-tax exemption in half and increasing capital gains taxes. So stay tuned.

2022 Tax Bracket and Tax Rates 

There are seven tax rates in 2022: 10%, 12%, 22%, 24%, 32%, 35% and 37%. Here’s how they apply by filing status:

Married Individuals Filing Joint Returns and and Surviving Spouses (Joint) Tax Rates 2022

2022 Standard Deduction Amounts 

The standard deduction amounts will increase to $12,950 for individuals and married couples filing separately, $19,400 for heads of household and $25,900 for married couples filing jointly and surviving spouses.

The additional standard deduction amount for the aged or the blind is $1,400 for 2022. The additional standard deduction amount increases to $1,750 for unmarried aged/blind taxpayers.

The standard deduction amount for 2022 for an individual who may be claimed as a dependent (including “kiddies”) by another taxpayer cannot exceed the greater of $1,150 or the sum of $400 and the individual’s earned income (not to exceed the regular standard deduction amount).

Personal Exemption Amount

The personal exemption amount remains zero in 2022. The Tax Cuts and Jobs Act suspended the personal exemption through tax tax year 2025, balancing the suspension with an enhanced Child Tax Credit for most taxpayers and a near doubling of the standard deduction amount.

Alternative Minimum Tax Exemption Amounts

Here’s what the alternative minimum tax (AMT) exemption amounts look like for 2022, adjusted for inflation:

Child Income Tax 

A child’s unearned income is taxed at the parent’s marginal tax rate; that tax rule has been dubbed the “kiddie tax.” The kiddie tax applies to unearned income for children under the age of 19 and college students under the age of 24. Unearned income is income from sources other than wages and salary. For example, unearned income includes dividends and interest, inherited Individual Retirement Account distributions and taxable scholarships.

For 2022, the standard deduction amount for an individual who may be claimed as a dependent by another taxpayer cannot exceed the greater of (1) $1,150 or (2) the sum of $400 and the individual’s earned income (not to exceed the regular standard deduction amount). If your child’s only income is unearned income, you may be able to elect to include that income on your tax return rather than file a separate return for your child. This is allowed for 2022 if the child’s gross income is more than $1,150 but less than $11,500. But the tax bite may be less if your child files a separate return.

Capital Gains Tax

Capital gains tax rates remain the same for 2022, but the brackets for the rates will change. Here’s a breakdown of long-term capital gains and qualified dividends rates for taxpayers based on their taxable income:

Section 199A deduction (also called the pass-through deduction)

As part of the Tax Cuts & Jobs Act, sole proprietors and owners of pass- through businesses are eligible for a deduction of up to 20% to lower their tax rate for qualified business income. Here are the threshold and phase-in amounts for the deduction for 2022:

Federal Estate Tax Exemptions

The federal estate tax exemption for decedents dying in 2022 will increase to $12.06 million per person or $24.12 million for a married couple.

Gift Tax Exclusion  

The annual exclusion for federal gift tax purposes jumps to $16,000 for 2022, up from $15,000 in 2021.

Popular Tax Credits And Deductions 2022 

Earned Income Tax Credit. For tax year 2022, the maximum earned income tax credit amount is $6,935 for qualifying taxpayers who have three or more qualifying children. Phaseouts apply.

Child Tax Credit. Without congressional action on the Build Back Better Act, in 2022, the Child Tax Credit would revert back to $2,000 per qualifying child, subject to income phaseouts starting at $400,000 for joint filers and $200,000 for singles. Joint filers with $440,000 of income get no credit.

Adoption credit. The tax credit for an adoption of a child with special needs is $14,890 for 2022. The maximum credit allowed for other adoptions is the amount of qualified adoption expenses up to $14,890. The credit begins to phase out for taxpayers with modified adjusted gross income (MAGI) in excess of $223,410, and it’s completely phased out at $263,410 or more.

Lifetime Learning Credit. This education tax credit is phased out for single taxpayers with MAGI in excess of $80,000, and for joint filers with $160,000m for 2022.

Student Loan Interest Deduction. The $2,500 deduction for interest paid on student loans begins to phase out when modified adjusted gross income hits $70,000 ($145,000 for joint returns) and is completely phased out when MAGI hits $85,000 ($175,000 for joint returns).

Elementary and Secondary School Teachers Expenses. In 2022, qualifying teachers can claim $300 for expenses paid or incurred for books, supplies (other than nonathletic supplies for courses of instruction in health or physical education), computer equipment (including related software and services) and other equipment, and supplementary materials used in the classroom. That’s up from $250 in 2021

Commuter benefits. The monthly limit for 2022 contributions to qualified parking and transit accounts is $280. If you pay to park and ride, you get to double dip.

Flexible Savings Accounts. The dollar limit for 2022 contributions to a flexible savings account is $2,850. For plans that allow carryovers, the carryover limit is $570. There are no PEASE limits on itemized deductions. As of now, the $300 charitable deduction ($600 for joint filers) that was available to nonitemizers in 2021 has not been extended for 2022.

If a merger or acquisition was planned before receiving Phase 4 General Distribution payments, will health care providers still need to report these activities? (Added 10/26/2021) If a Reporting Entity that received a Phase 4 General Distribution payment undergoes a merger or acquisition during the Period of Availability, as described in the Post-Payment Notice of Reporting Requirements, that corresponds to the Payment Received Period, the Reporting Entity must report the merger or acquisition during the applicable Reporting Time Period

What type of review will HRSA do after a merger or acquisition has been reported by recipients of a Phase 4 General Distribution payment? (Added 10/26/2021) If a Reporting Entity that received a Phase 4 General payment indicates when they report on the use of funds that they have undergone a merger or acquisition during the applicable Period of Availability, this information will be a component that is factored into the entity’s audit risk score.

If a merger or acquisition was planned before receiving ARP Rural payments, will health care providers still need to report these activities? (Added 10/26/2021) If a Reporting Entity that received an ARP Rural payment undergoes a merger or acquisition during the Period of Availability that corresponds to the Payment Received Period, the Reporting Entity must report the merger or acquisition during the applicable Reporting Time Period.

What type of review will HRSA do after a merger or acquisition has been reported by recipients of an ARP Rural payment? (Added 10/26/2021) If a Reporting Entity that received an ARP Rural payment indicates when they report on the use of funds that they have undergone a merger or acquisition during the applicable Period of Availability, this information will be a component that is factored into the entity’s audit risk score.

If a provider received Provider Relief Fund payments and ARP Rural payments, can they use these payments for the same eligible expenses or lost revenues? (Added 10/26/2021) No. A provider may not use an ARP Rural payment to cover eligible health care expenses or lost revenues attributable to coronavirus or COVID-19 if the provider has already reported that Provider Relief Fund payments have covered the eligible expense or lost revenues. If a provider receives both types of funding, the provider should apply Provider Relief Fund payments toward eligible health care expenses and lost revenues attributable to coronavirus before utilizing ARP Rural payments to cover eligible health care expenses and lost revenues attributable to COVID19.

How will HRSA treat prior payments received from the Provider Relief Fund when calculating the Phase 4 Base Payment amount? (Added 10/26/2021) HRSA will deduct from the Phase 4 Base Payment any prior Provider Relief Fund payments received by the applicant and any of its subsidiaries/billing TINs included in its Phase 4/ARP Rural application, which were not previously deducted from the Phase 3 General Distribution payment. The Phase 4 deductions include any prior Provider Relief Fund payments that exceeded 2% of annual patient care revenue or 88% of changes in operating revenues and expenses for the first half of calendar year 2020. For example, if an entity applied to Phase 3 after receiving $100,000 in prior Provider Relief Fund payments, including a General Distribution payment that was equal to 2% of annual patient care revenue, and reported a change in operating revenues and expenses in the first half of 2020 that equaled $75,000, then the entity did not receive a Phase 3 payment. In Phase 4, the remaining $25,000 that was not yet deducted will be taken into account when calculating the Phase 4 Base Payment amount.

Why is HRSA requesting that applicants include all its billing TINS in the Phase 4/ARP Rural payments application portal? (Added 10/26/2021) Applicants must include all billing TINs under the filing TIN that provide patient care to ensure that applicants receive the maximum payment amount for which they are eligible. Applicants must include an exhaustive list of TINs and must ensure that all TINs included in the application belong to the filing TIN that is applying. HRSA will calculate the ARP Rural and a portion of Phase 4 payments based on the submitted billing TINs, as well as assess eligibility for ARP Rural payments for each of the included billing TINs.

What “exempt payee code” should I select when registering in the application portal? (Added 10/26/2021)

Applicants should select the exempt payee code based on the following information:

For reporting net patient revenue, do providers need to exclude prior year cost reports settlements? (Added 10/26/2021) No. Providers do not need to exclude prior cost report settlements when reporting patient care revenue in the Phase 4 application. Providers may use actual settlements received or their historical information to estimate the amount of cost report settlement, in line with their internal processes and procedures.

Why is HRSA requesting applicants select a provider type? (Added 10/26/2021) HRSA will employ several pre-payment risk mitigation and cost containment safeguards to ensure that application information is accurate and that HRSA is making payments equitably, including adjusting payments based on self-selected provider type, as described in the payment methodologies available at https://www.hrsa.gov/provider-relief/future-payments/phase-4-arprural/payment-methodology. HRSA will determine provider type adjustments after all applications are received. Please note, if an application is flagged, HRSA will conduct a review of the associated supporting documentation. Depending on the results of the review of the documentation, the potential payment for the application may be adjusted based on provider type-based adjustments.

On September 20, 2021, and Updated on September 21, 2021, Indiana Medicaid released a new policy increasing reimbursement for COVID-19 Ready nursing facilities. The policy is in response to the need to ease the growing stresses on the state’s hospital capacity by helping nursing facilities offset the growing and large costs for operating COVID-19 units. The effective dates for qualifying providers are dates of services between September 20, 2021 and October 16, 2021.  Facilities submitting an attestation form in the month of September will have reimbursements begin back to September 20, 2021.  Facilities that submit attestations on October 1, 2021 or after will have reimbursements start the date of the submission of the attestation.

The temporary increases are 4% per patient day (all Medicaid patients in the facility) for facilities that attest to being COVID-19 Ready and an additional $230 per COVID-19 positive resident.

Qualifying as a COVID-19 Ready Facility

Each nursing facility desiring to become COVID-19 Ready must follow and attest to the below Indiana Department of Health (IDOH) COVID-19 Ready requirements.  The COVID-19 Ready Attestation Statement is linked below.

• Follow IDOH COVID-19 Long-Term Care (LTC) Standard Operating Procedures and IDOH COVID-19 Infection Prevention (IP) Toolkit, located on the Professional Resources page at coronavirus.in.gov.
• Follow IDOH LTC hospital transfer guidance or have developed a mutually agreed upon plan with local hospitals for admission and readmission of COVID-19 patients.
• Follow IDOH, Centers for Medicare & Medicaid Services (CMS), and Centers for Disease Control and Prevention (CDC) communication guidelines.
• Accept COVID-19 new admissions, readmissions and transfers.
• Share complete COVID-19 status information with transportation providers serving residents.
• Follow IDOH, CMS and CDC reporting requirements for new COVID-19 cases and deaths involving residents and staff.
• Provide daily updates of COVID-19 bed capacity and changes in admission status (for example, admissions hold) in the EMResource system at emresource.juvare.com.
  • When making the first entry, enter the facility’s current admissions status and capacity

Attestation Process

• Facilities must complete the COVID-19 Ready Attestation Statement to Derris Harrison at Derris.Harrison@fssa.in.gov and
• Update their COVID-19 Ready status in EMResource.  The facility must enter “yes” in the LTC COVID Ready Facility Status Column.

 COVID-19 Resident Reimbursement

To obtain the temporary $230 per resident daily add-on, up to 21 days, a facility must:

• Submit the COVID-19 Ready Attestation Statement to Derris Harrison at Derris.Harrison@fssa.in.gov; and
• Bill claims for COVID-19 positive residents with the primary diagnosis code of U07.1 – COVID-19 positive.

Nursing facilities will be paid the temporary add-on for the full 21-days when the following are true:

• The resident is in a COVID-19 Ready facility.
• The resident is COVID-19 positive between Sept. 20, 2021, and Oct. 16, 2021.
• Claims had U07.1 as the primary diagnosis.
• The resident was not discharged prior to the 21 days for any reason, including death, transfer to another facility or being sent home.

EMResource Assistance

• Click here for EMResource Account Request
• Click here for the EMResource COVID-19 Ready Reporting Instructions
• Click here for EMResource Login Guide
• Facilities that already have an EMResource account should follow the instructions for resetting their password if they have trouble logging in.
• EMResource Troubleshooting – Email Eric Shelley at the Indiana Department of Health – eshelley1@isdh.in.gov

The FY 22 budget includes a total of $75 million in American Rescue Plan Act (ARPA) funding for long term care providers. Uses are outlined in corresponding language in the FY 22 Budget Implementation Act (BIMP; see 305 ILCS 5/5-5.7a(7) and (8)). There are specific pass-through percentages for July, August, and September 2021 to be paid to frontline workers as follows: 50% for July, 62.5% for August, and 75% for September 2021. The remaining funding can be used for additional COVID-related purposes, as described.

This new funding for the financial support of workers in long term care facilities comes amidst an enduring threat to nursing facility residents and staff from the COVID pandemic, as the Federal government makes plans to implement a COVID vaccination requirement for nursing facility staff, the Governor issued a vaccine mandate for all workers in Illinois health care facilities yesterday, and as nursing shortages remain a concern in Illinois and across the country.

The following outlines the formula and accompanying guidelines with which ARPA funds will be distributed to skilled nursing facilities actively serving the Medicaid program as prescribed by the Illinois General Assembly.

• HFS has established a rate to distribute the $75 million using the latest available staffing data for total nurse hours across the state.
  • Each facility’s share of the $75 million distribution reflects its estimated share of total nursing hours for the most recently available quarter.
  • Staffing levels were based on nursing hours from the federal Payroll Based Journal for 4Q2020, where available.
  • Each facility will receive $4.43 per hour of nursing, at previously-observed nurse staffing levels, for each of the three months included in the $75 million distribution.

• Nursing facilities are required to spend the monthly percentage of pass-through to front line workers on the following pandemic-related uses:
  • Vaccine bonus(es) paid March 3, 2021 or later
  • Pandemic bonus pay to employees on or after July 1, 2021 (hazard, hero, premium pay and premium wages, or other temporary wage increases)
  • Temporary benefits such as day care, etc. provided July 1, 2021 or later
  • Signing bonuses for new hires paid out March 3, 2021 or later
• Nursing facilities may spend the remainder of their distributions on either the above  uses or on other financial support for their workers provided on or after March 3, 2021, or other purposes permitted by paragraphs (7) and (8) of 305 ILCS 5/5-5.7a which includes purposes permitted by Section 9901 of the American Rescue Plan Act of 2021 including but not limited to:
  • Payment of education expenses to enhance direct care staff recruitment
  • Enhanced and expanded training for nursing facility staff to better achieve patient outcomes, such as training on infection control, proper personal protective equipment, best practices in quality of care, and culturally competent patient communications
  • Additional forms of pandemic-related financial support for the nursing facility workforce (to be specified by the provider)
  • Costs incurred due to the COVID-19 Public Health Emergency
  • Unreimbursed costs for testing and treatment of COVID-19
  • Costs of COVID-19 mitigation and prevention
  • Medical expenses related to aftercare or extended care for COVID-19 patients with longer term symptoms and effects
• Each nursing facility will be required to complete a simple budget form reflecting its plan to utilize the awarded funds.
• All facility budgets will be posted on the HFS website.
• The total amounts of ARPA funds received by nursing facilities will be posted on the HFS website.
• The July distribution will be required to be spent by September 30, 2021. The August and September distributions must be spent by November 30, 2021.
• Payments for July and August will be distributed upon receipt of the signed subaward agreement.
• Payments for September will be released upon receipt of the budget template.
• Signed subaward agreements and budget templates must be submitted by September 30, 2021 or funding may be reallocated to other providers.

HFS will be sending out specific instructions for accessing the subaward agreements and budget templates to individual providers starting early next week. The emails will be sent to provider contacts from the CARES Act funding.

The FY 22 budget includes a total of $75 million in American Rescue Plan Act (ARPA) funding for long term care providers.  Uses are outlined in corresponding language in the FY 22 Budget Implementation Act (BIMP; see 305 ILCS 5/5-5.7a(8)). There are specific pass-through percentages for July, August, and September 2021 to be paid to frontline workers as follows: 50% for July, 62.5% for August, and 75% for September 2021. The remaining funding can be used for additional COVID-related purposes, as described.

This new funding for the financial support of workers in long term care facilities comes amidst an enduring threat to nursing facility residents and staff from the COVID pandemic, as the Federal government makes plans to implement a COVID vaccination requirement for nursing facility staff, the Governor issued a vaccine mandate for all workers in Illinois health care facilities yesterday, and as nursing shortages remain a concern in Illinois and across the country.

The following outlines the formula and accompanying guidelines with which ARPA funds will be distributed to skilled nursing facilities actively serving the Medicaid program as prescribed by the Illinois General Assembly.

• HFS has established a rate to distribute the $75 million using the latest available staffing data for total nurse hours across the state.
  • Each facility’s share of the $75 million distribution reflects its estimated share of total nursing hours for the most recently available quarter.
  • Staffing levels were based on nursing hours from the federal Payroll Based Journal for 4Q2020, where available.
  • Each facility will receive $4.43 per hour of nursing, at previously-observed nurse staffing levels, for each of the three months included in the $75 million distribution.

• Nursing facilities are required to spend the monthly percentage of pass-through to front line workers on the following pandemic-related uses:
  • Vaccine bonus(es) paid March 3, 2021 or later
  • Pandemic bonus pay to employees on or after July 1, 2021 (hazard, hero, other temporary wage increases)
  • Temporary benefits such as day care, etc. provided July 1, 2021 or later
  • Signing bonuses for new hires paid out July 1, 2021 or later
• Nursing facilities may spend the remainder of their distributions on either the above  uses or on other financial support for their workers provided on or after March 3, 2021, as outlined in the BIMP:
  • Payment of education expenses to enhance direct care staff recruitment
  • Enhanced and expanded training for nursing facility staff to better achieve patient outcomes, such as training on infection control, proper personal protective equipment, best practices in quality of care, and culturally competent patient communications
  • Additional forms of pandemic-related financial support for the nursing facility workforce (to be specified by the provider)

• Each nursing facility will be required to complete a simple budget form reflecting its plan to utilize the awarded funds.
• All facility budgets will be posted on the HFS website.
• The total amounts of ARPA funds received by nursing facilities will be posted on the HFS website.
• The July distribution will be required to be spent by September 30, 2021. The August and September distributions must be spent by November 30, 2021.
• Payments for July will be distributed upon receipt of the signed subaward agreement.
• Payments for August and September will be released upon receipt of the budget template.
• Signed subaward agreements and budget templates must be submitted by September 30, 2021 or funding may be reallocated to other providers.

HFS will be sending out specific instructions for accessing the subaward agreements and budget templates to individual providers starting early next week.  The emails will be sent to provider contacts from the CARES Act funding.