Issues with qualifying for the Small Business Covid Hardship Grant

It should be straight forward.

But it isn’t.

Whether you qualify or not depends on which state government publication you read.

Let me explain why first before I set out how we plan to navigate conflicting government announcements.

The qualifying test is a 70% fall in turnover over a minimum two week period as compared to 2019 as measured by your GST turnover method.

Now the fun begins.

The Program Guidelines states that:-

Select a … period where the impacted period…was most impacted by Covid.
Select a … period as a comparison point.
The comparison period for businesses should generally be the same time of year {it’s bad enough they use a vague word as should but adding generally is open to liberal interpretation}.
And goes on to state that … unless there are exceptional reasons as to why a different time is chosen noting that slight adjustments for trading days are acceptable. Exceptional reasons are not defined which probably helps more than hinders.
With the overriding statement being that …as a direct consequence of Covid.

The application form contains statements such as:-

You must identify a date range … in turnover compared to a similar date range in the benchmark period.
You must choose similar dates for the benchmark period … unless there are exceptional reasons as to why a different period is chosen.
If you choose a starting date in 2019 that is more than 3 days earlier than the starting date in 2019 …. This makes sense as 27^th May in 2019 was a Monday and a Thursday in 2021 – so it is simply a way to align the weeks.
It then goes on to state that … your application may require further information to substantiate the exceptional circumstances.
With one of the attestations being … that the benchmark period selected is representative of normal business operations.
Another attestation is that … as a direct consequence of Covid.

But when you get to the FAQ sheet (not that any questions had been asked by the time this was released early on the afternoon of Thursday 12^th August as the program was nothing more than a name by noon on that day despite it being heralded some 3 weeks beforehand).

The FAQs start clearly with a statement that:-

As a direct consequence of Covid.
But then goes on to state that … businesses should compare their best consecutive two week trading period … 2019 … with their worst consecutive … period … 2021.
And then states later that … this two week period can be any two consecutive weeks within the benchmark period. This cannot be read in isolation nor definitive given the comments in the guidelines that there must be exceptional circumstances.

It is all unnecessarily inconsistent.

So we are going to proceed as follows:-

We will first seek a period/periods of two weeks or longer where there is a drop in turnover in 2021 compared to the same period in 2019. The test period is a minimum of two weeks but can be longer. We have built a rolling spreadsheet to test for this. If you satisfy this test, we will then seek your assurance that the decline is due to Covid and then proceed to application.
If you don’t pass this then we will seek a different comparative period where turnover was sufficiently high and then we will seek your assurance that the decline is due to Covid AND that exceptional circumstances exist before proceeding to application.
As most businesses will be assessed on a cash basis, you will need to form that opinion more on the pattern of customers paying you than when the invoices were raised.

Other points to note:-

It is a tougher test than for JobKeeper – under JobKeeper, it was assumed the fall in turnover was due to Covid. With this, you have to justify your opinion as to why it is due to Covid.
There is no going back and claiming later. If you are eligible and an application is not lodged by 10^th September (or earlier if the allotted funds run out) then you miss out.
What we will be required to attest to and sign off on may well prove to be a very subjective matter. As such, we will be assessing all turnover testing ourselves and in doing so running all clients through our assessment spreadsheet. If you do appear to qualify then a separate fee will be levied for the application process.
All of this has added a couple of extra steps to the process but we will keep our prices the same as announced on Monday.
JobKeeper was an exception to what our preferred audit insurer covers as it does not cover grants such as this.
Please remember that one does not qualify for this grant if you have already received recent state industry specific government grants.
And please make sure your accounting file is up to date and the bank account reconciled.

At MRS, we will spend today planning for your success.