What is the Law?
The Families First Coronavirus Response Act’s (FFCRA) paid leave provisions were effective on April 1, 2020, and only apply to leave taken between April 1, 2020, and December 31, 2020.
The FFCRA provides businesses with tax credits to cover certain costs of providing employees with required emergency paid sick leave (EPSL) and expanded paid family and medical leave (PFMLA) for reasons related to COVID-19, from April 1, 2020, through December 31, 2020.
Eligible Employers may claim tax credits for qualified leave wages paid to employees under EPSL or PFMLA for reasons related to COVID-19 taken and paid between April 1, 2020, and December 31, 2020.
When do the paid leave requirements of the FFCRA expire?
Beginning on January 1, 2021, there are no requirements under the FFCRA to provide EPSL or PFMLA to employees, and checks dated on or after January 1, 2021, by law cannot provide the business with a tax credit, this is true regardless of the fact that the proper job codes are used. Wages eligible for the tax credit under the FFCRA must be paid on a payroll check dated December 31, 2020, or prior.
How can RASI assist?
RASI will remove the EPSL & PFMLA job codes below from the web as soon as possible following the end of 2020. There will be no tax credit calculated on payroll checks dated 2021 that have hours paid under the job codes below.
- Emergency Paid Sick Leave Reason 1-2-3
- Emergency Paid Sick Leave Reason 4-5-6
- Emergency Paid FMLA
Please ensure all checks with EPSL and PFMLA hours are submitted timely to RASI for processing and a check date in 2020.
This information can be found @ https://www.irs.gov/newsroom/covid-19-related-tax-credits-basic-faqs & https://www.dol.gov/agencies/whd/pandemic/ffcra-questions#1