“Ask” to expand eligibility in the PPP to orgs who employ 500+ individuals

May 7, 2020

We wanted to provide you with a brief update regarding the steps the National Council, with support of state associations including the NYS Council, is taking to assist nonprofit mental health and substance use providers who employ in excess of 500 individuals during this difficult time. 

In mid-April, the National Council submitted comments to the Federal Reserve regarding the Main Street Lending Program, requesting that eligibility criteria be clarified to include nonprofit organizations employing between 500-10,000 individuals.  On Tuesday, April 28, 2020 we received a response from the Federal Reserve, simply indicating that our comment is being considered. 

Our main effort to provide relief for mid to large size nonprofits pertains to SBA Paycheck Protection Program (PPP) eligibility.  Currently, the SBA PPP limits eligibility to small businesses and nonprofits who employ fewer than 500 individuals.  The National Council, in partnership with ANCOR, drafted a white paper for members of congress highlighting the importance of PPP eligibility for nonprofits employing in excess of 500 individuals and providing critical services.  On Thursday, April 30, 20202 the white paper went out to the members of congress representing all National Council members impacted by the PPP eligibility size limitation. 

On May 1, 2020 an action alert went out to the contact listed on the filed i990s for impacted National Council members, asking that they contact their members of congress requesting that PPP eligibility be expanded in the next stimulus package.  The white paper was included in that message to Congress. 

The specific ask to Congress is the following: 

We urge Congress to modify Section 1102 (D) of the CARES Act to allow non-profits employing in excess of 500 employees and providing the following specific services to be eligible for the SBA PPP and include the following language in the next stimulus bill: 

“Non-profits organizations as described in section 501(c)(3) of the Internal Revenue Code of 1986 and are exempt from taxation under section 501(a) of such Code are exempt from the size limitation on employees under Section 1102 (D)(i) and (ii) if providing mental health, substance use disorder, intellectual and developmental disability services and autism services.” 

Invaluable follow-up is needed from your members!  We encourage you to forward the Action Alert to your members who you believe have more than 500 employees and are impacted by PPP eligibility limitations.  If you need any assistance in identifying which nonprofit members in your state are impacted, please email Stephanie Katz at stephaniek@thenationalcouncil.org and she can provide you with a list. 

The Action Alert can be found here:  

In addition to this outreach, targeted efforts are being made to members of congress on committees of jurisdiction – most notably Small Business, Finance, Ways and Means, and of course the House and Senate Leadership.  

As always, if you have questions please feel free to reach out to Lauri at 518 461-8200.