Dear VRS Clients,
We have received some updates regarding the Families First Coronavirus Response Act (FFCR – Phase 2) and the CARES Act (Phase 3). As always, this situation is changing and developing daily so please continue to read our updates in detail, as some updates may be overriding prior information provided.
- The IRS has addressed our confusion regarding the effective date of the tax credits allows for paid time off under the FFCR Act. Despite the March 20th announcement to make the benefits of the Act available immediately, the IRS has decided to follow the DOL in implementing the act effective April 1, 2020. Any attempts by staff to take time off prior to April 1, 2020 will have to be treated as unpaid time or use of other PTO. The full IRS release can be found here: https://www.irs.gov/pub/irs-drop/n-20-21.pdf
- We encourage employers to periodically review the Q&A section of the U.S. DOL, as they are continuing to add scenarios that will answer most of your questions: https://www.dol.gov/agencies/whd/pandemic/ffcra-questions
- Employers – if you have not already done so, remember to put the poser regarding employee rights in a conspicuous place: https://www.dol.gov/sites/dolgov/files/WHD/posters/FFCRA_Poster_WH1422_Non-Federal.pdf
- Yesterday was a busy day for accountants and bankers trying to answer questions. Please understand that until the SBA releases guidance on the Paycheck Protection Program (PPP) loans, no one really knows for sure what will be required and when applications can be submitted. One of our Congressional representatives got back to us and said that the SBA is “shooting for Friday” but this is a massive undertaking, so stay tuned and rest assured that VRS and your banker are anxiously awaiting that guidance.
- Individual stimulus payments – the IRS has not released a definitive date yet, but you can check here for the information they have released yesterday: https://www.irs.gov/newsroom/economic-impact-payments-what-you-need-to-know
- Unemployment – the state is still waiting for instructions from the federal government on how to apply the Pandemic Unemployment Assistance included in the Phase 3 bill (extra $600 per week and inclusion of independent contractors, the self-employed, and other business owners).
VRS truly appreciates how understanding our clients have been through this difficult time. We are all in this together.