Payroll News: DOL Updates FFCRA Provisions for Reopening Schools & More

Payroll News: DOL Updates FFCRA Provisions for Reopening Schools & More

Written by Certified Payroll Specialist, Kristen O'Connell, CPP

The COVID-19 pandemic has indirectly caused numerous headaches for professionals who prepare and process payroll. In this article, I have highlighted some of the recent updates you should know.

Form 941 to Reflect Additional Changes
The IRS will be releasing a revised version of Form 941 to be used for Quarters 3 and 4 of 2020. The most recent version of the form will include a line item for the Employee Social Security Tax Deferral program. If you are participating in this program, please be mindful of this change and reporting this information.

W-2 Reporting Issues
As we approach year-end, the IRS is currently working through the specifics of W-2 reporting for 2020 and is close to providing additional guidance for year-end reporting procedures.

DOL Updates FFCRA Provisions for Reopening Schools
On September 11, 2020, the Department of Labor (DOL) added three provisions to the Families First Coronavirus Response Act (FFCRA) related to the reopening of schools and how it affects paid leave requirements under the FFCRA.

Scenario 1: Hybrid Learning Option Only 

The employee has a child(ren) and their school is operating on a hybrid learning model (alternate day basis – students alternate between attending school and remote learning). If this is the case, then the employee is eligible to take paid leave under FFCRA on days when their child is not permitted to attend school in-person as long as they need to actually care for their child during that time. For purposes of FFCRA, the school is effectively closed to their child on days they cannot attend in-person.

Scenario 2: In-person Learn or Remote Learning Options Are Given

The employee has a child(ren) and their school is allowing parents to choose between in-person and remote learning. If the family selects the remote learning option, then that employee is not eligible to take paid leave under FFCRA because the child’s school is not actually closed due to COVID-19.

Scenario 3: School is Currently Remote Learning Only

The employee has a child(ren) and their school is currently operating under the remote learning but will continue to evaluate local circumstances about reopening for in-person attendance later in school year. In this scenario, the employee is eligible to take paid leave under FFCRA while their child’s school remains closed.

 

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