Wednesday, May 6, 2020
Dear Community Partners:
We wanted to provide you with the latest information.
Late yesterday, the Small Business Administration (SBA), the federal agency in charge of administering the Paycheck Protection Program (PPP), updated their guidance (through their Frequently Asked Questions document). The response to Question 43 (link here) extends the repayment date, to Thursday, May 14th, for organizations to determine whether they believe they are required to repay their loan. As a reminder, this is only for organizations that had applied for a PPP loan prior to April 24, 2020. Within the response, the SBA also shared that they do intend to provide additional guidance on how they will review the certification, with that guidance coming prior to May 14.
Additionally, IDHS has updated our own Frequently Asked Questions, based on questions received on our DHS.PPPQuestions@illinois.gov email as well as those received by program staff. Please continue submitting questions and monitoring the FAQ page found on the IDHS Coronavirus webpage.
As it relates to the "current economic uncertainty" certification and further IDHS guidance, please see below. The information and this communication supersede the communication provided late yesterday, May 5, 2020, on the PPP:
If your organization is receiving PPP funding, retention payments from IDHS, or both, please be cautious to only use such funds for allowable expenditures, under the PPP rules or the providers' grant/funding agreements.
To the extent your PPP funding is used to cover what would otherwise be covered by IDHS retention payments, you must notify IDHS. If your PPP funding does not fully cover the retention payments, IDHS will make payments to ensure full payment over the course of the PPP funding. If this is the case for your organization, IDHS will provide you with a form so you can certify there is no duplication of funds.
While providers need to make their own, independent determinations as to their eligibility for the PPP, those who are unable to perform, either in whole or in part, due to the COVID-19 pandemic should meet the PPP "current economic uncertainty" certification requirements, making their "loan request necessary to support the ongoing operations of the applicant."
As stated previously, IDHS believes the "current economic uncertainty" for providers, IDHS, and the State due to diminishing State revenues supports providers' eligibility for this federal funding, both to support providers and to maximize limited State funds. This [updated] letter can be used in support of the "current economic uncertainty" certification requirements.
Providers whose ability to perform has not been impacted by the COVID-19 pandemic (i.e. providers who are able to fully perform and to be paid for that performance) are not required by IDHS to apply but must make their own determination as to whether they choose to do so and are responsible for meeting the PPP's eligibility and expenditure requirements and limitations.
IDHS understands that this pandemic has more than likely increased the costs for organizations and appreciates everyone's willingness to continue providing critical services day in and day out. IDHS remains grateful to each and every one of you for your ongoing commitment.
Grace B. Hou