The last week or so has been full of new Coronavirus related information, and it can be a lot to digest. Our team at J&D is making every effort to focus on questions our clients have contacted us about so we can share that research with all our customers. Below is a summary of new information we hope will be helpful to you and your employees.
United Benefit Advisors (UBA) has created the attached UBA Compliance Advisor: Families First Coronavirus Care Act (FFCRA), focusing on the Emergency Family Medical and Leave and Emergency Paid Sick Leave portions.
The U.S. Treasury, the Internal Revenue Service (IRS) and the Department of Labor (DOL) have released guidance on the paid leave and tax credits, available to small and mid-size employers. Details Here on the IRS website.
The California Labor & Workforce Development Agency created a Leave Chart that includes how COVID-19 leaves integrate with existing California programs:
Furloughs, Layoff and Benefits:
Furlough: Temporary reduction in hours of work or weeks of work. This could be, “we only need you 10 hours this week” or, “we’re closing for two weeks, see you all soon.” Probably involves an estimated date of reopening.
Temporary Layoff: A layoff with the intention of rehire, generally within six months. (WARN notice does not apply if six months or less. Requirement waived for now in California.)
Permanent Layoff: A layoff with no anticipated rehire date.
Depending on which of the above actions you may need to take, how you handle benefits will vary. Contact your Johnson & Dugan team to determine if there is an option for employees to remain active on the plan during a furlough period. Your J&D team has been gathering information on carrier policies that apply to your plans.
The attached sample COVID-19 Furlough letter can be customized to communicate the details of a company furlough.
For either type of layoff, COBRA (or the applicable state continuation coverage) should be offered. Employers are able to establish a policy to pay the COBRA premium for a set period of time, if desired.
This Furlough FAQ from Armanino Accountants has helpful information for employers: https://www.armaninollp.com/articles/furlough-faq-what-employers-need-to-consider/
Insurance Premium Payments:
The California Insurance Commissioner, Ricardo Lara, issued a Notice calling for a 60-day grace period due to the COVID-19 outbreak. Click Here for details.