When it comes to having the PPP Loan fully forgiven, what was keeping practice owners up at night was the requirement to re-staff to 2/15/20 levels by 6/30/20 to qualify for full forgiveness. The revised PPP Loan Forgiveness Application available at: https://home.treasury.gov/system/files/136/3245-0407-SBA-Form-3508-PPP-Forgiveness-Application.pdf provides much needed relief.
First, the original FTE safe harbor deadline is now 12/31/20 to re-staff your practice. Even so, there is some flexibility as to which payroll period you will use per the updated instructions: Enter the borrower’s total FTE as of the earlier of December 31, 2020, and the date this application is submitted:
Plus, the instructions now include a new “check-the-box” FTE safe harbor as follows:
FTE Reduction Safe Harbor 1: If you were unable to operate between February 15, 2020, and the end of the Covered Period at the same level of business activity as before February 15, 2020 due to compliance with requirements established or guidance issued between March 1, 2020 and December 31, 2020, by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration related to the maintenance of standards for sanitation, social distancing, or any other worker or customer safety requirement related to COVID-19, check here ☐.
With these two FTE safe harbors coupled with a 24-week Covered Period, most practices should be able to qualify for full PPP Loan forgiveness (except for the amount of the EIDL grant of course).