Families First Coronavirus Response Act

Has anyone already mapped out how they are going to handle the new act for employers with less than 500 employees? Most of our PLs fall into this category, and I need to start building and testing how to pay affected employees.

Are you creating different LP 80-hour plans and a pay code that pays at 2/3 rate for the one plan? How about for the 100% rate plan - are you creating a specific pay code that identifies the pay as Coronavirus related?

This group was indispensable to me during the ACA setup and I hope we can get through this nightmare together as well. Anything you can share would be much appreciated.

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Comments

mark-garlen

Our legal team is saying that employer size under the act is calculated the same as for FMLA, using the "integrated employer test". This means the size of the entire organization is used, not the individual components. Do you still qualify as under 500 when using this test?

marty

Even though our legal team is advising us against claiming joint employers, our CFO is still considering it. But with the act's effective date of 4/1, and employees already getting sick, I am going to go ahead and assume the legislation applies to us. I'd rather not be caught at the last minute scrambling. Thank you for the response though!

mark-garlen

As an organization we have already created several new pay codes specific to this situation. So in response to your question of...are you creating a specific pay code that identifies the pay as Coronavirus?...the answer is yes.

marty

I've been asked to create 2 new leave plans with the 80 hour allotment, and then specific pay codes that associate with them - one that pays at 100% and another that pays at 2/3. We don't have any allotment plans so I'm just seeing if others are doing the same and whether or not anyone would share their set up, or if you have other, better ways of tracking the 80 hours so that I don't have to make new plans. We would only enroll employees as needed, and the variable/part time people we would just track outside of LP.

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