On April 14 the Small Business Administration (SBA) released a supplemental final rule providing
significant clarification on how small businesses determine their
maximum loan eligibility and the threshold under the Paycheck Protection
Program (PPP) – a program that provides small businesses with loans of
up to $10 million to cover costs during the COVID-19 pandemic and
economic downturn. Through the new clarifications, NADP has determined
that dental benefits premiums paid by employers would be considered part
of “payroll costs” in the PPP and therefore count towards the 75%
threshold for loan forgiveness.

NADP had submitted comments
to leadership of the SBA on April 10 seeking clarification that dental
plan premiums and costs paid by employers were included in the
definition of “payroll costs” in the PPP. NADP members had been
receiving questions regarding the applicability of the program to

In the
comments, NADP informed SBA that while existing legislative language was
broad enough to encompass dental benefits, it was important that SBA
clarify that the costs of all ancillary health benefits, including
dental benefits, paid by employers are included. NADP noted that 80% of
those employers that offer private dental coverage share the cost of
dental premiums with their employees and reminded SBA of the important
role that dental plays in overall health.

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