Dispatch #12 - Next week’s 4/1 FFCRA go-live date

As mentioned in yesterday's Dispatch #10, the new FFCRA law goes into effect on Wednesday, April 1st. Below are some additional tips to help you prepare:

1. Notify employees about their rights (for example, post the poster in workplace locations and email to employees as needed).

2. Be clear what each employee’s status is on April 1st. Broadly speaking, and assuming the distinctions between layoff and furlough hold up:

   1. Employed (working and earning regular wages)

   2. Furloughed (eligible for FFCRA benefits but ineligible for unemployment).

   3. Laid off (ineligible for FFCRA benefits but eligible for unemployment);

3. Think through the implications of #2 above with respect to paying out PTO and continuation of employees’ health care benefits.

4. Accounting, payroll, and supervisors need to be very clear on:

   1. The different types of leave that employees can request under this Act and what qualifies them to do so (find online or make a chart);

   2. The limits (caps) of each type of leave in terms of hours, rate of pay, and number of weeks’ coverage (ditto);

   3. How to track payments by type of leave to each employee, and ensure no payments are made in excess of the limits.

5. Because of the newness and complexity of this law, take time to get things in order:

   1. Don’t rush compliance and create a lot of downstream rework;

   2. There’s a non-enforcement period if a company is trying “in good faith” to comply;

   3. Being ready to comply by the week of April 6th, for example, seems reasonable;

   4. Assure employees they will receive their full benefit payout, but it might take a few more days before the funds start flowing.

6. Accounting and payroll staff need to monitor additional guidance about FFCRA as it is released, including how to be reimbursed for wages paid under this Act.

7. Document, document, document: have a thorough, well-organized “paper” trail that respects employee data confidentiality requirements.

See our full page post on this topic for more details.

Need help with this or other financial matters faced by construction contractors? Let’s talk!

David Stern CFO makes every effort to provide useful and accurate information. This content, however, is not intended as a substitute for specific business-related financial advice. We disclaim all warranties and liabilities from its use.