Explained: Coronavirus Assistance Programs
First and foremost, please know that our thoughts are with you, your employees and their families to stay safe from the Coronavirus/COVID-19 crisis we are all confronting. These are challenging times for all of us, our families and our businesses. Our number one priority is and will remain the welfare, health and safety of our employees, friends, and families.
In a time when there is so much in our country that we do not know, we choose to focus on what we do know: you have a team of experts who are here to help support your business. We are getting new updates from state and federal programs on what seems to be an hourly basis. With that in mind, I wanted to share the following updates with you regarding this very fluid situation.
1. Employer provided Health Coverage
The Families First Coronavirus Response Act (FFCRA) was signed into law on March 18, 2020. The FFCRA requires group health plans to cover COVID-19 screening without cost-sharing; This includes High Deductible Health Plans.
2. Paid leave and continuation of STD/LTD coverage
The FFCRA requires employers with fewer than 500 employees to provide: (1) up to 12 weeks of job-protected leave related to caring for a child via an expansion of the Family and Medical Leave Act (FMLA), and (2) up to 80 hours of emergency paid “sick” leave to full-time employees (with special rules for part-time employees).
If an employee went out on short- and long-term disability prior to the recent COVID-19 quarantines, we believe those policies should continue to pay benefits in the ordinary course.
3. Employer tax credits for paid leave
To assist employers in paying for the cost of the new federally mandated paid leave requirements, the FFCRA provides a series of refundable tax credits. The refundable tax credits apply against the employer portion of Social Security taxes and are equal to 100 percent of the “qualifying” paid leave wages paid by the employer, up to a certain amount that varies based on the type of leave. The FFCRA also provides for an increase in the tax credits associated with “qualified health plan expenses” related to paid leave. A Joint Committee summary of the FFCRA states that the employee portion of the 6.2 percent Social Security tax is not collected on qualifying paid leave wages, although this does not appear to be supported by the language of the Act itself. The IRS is expected to issue guidance detailing how these tax credits are to be reported and obtained.
4. Continuation of health coverage during furloughs and mandated leaves of absence
Health benefits generally do not continue during an extended unpaid leave of absence (including temporarily layoffs, reduced hours or furloughs).Most Health Insurance Carriers have stated they will not be looking to enforce any eligibility requirements during this time.
Employers should also consider implications under the Consolidated Omnibus Budget Reconciliation Act (COBRA), under which furloughed employees may elect to continue group health coverage upon loss of such coverage as a result of a reduction in work hours. Some employers might want to subsidize COBRA continuation coverage but will need to think through administrative logistics of collecting a furloughed employee’s share of the premium. If furloughed employees are receiving payments from their accrued time-off banks, then it may be possible to collect premiums from these payments.
5. Florida Small Business Emergency Bridge Loan Program COVID-19
The Florida Small Business Emergency Bridge Loan Program is currently available to small business owners located in all Florida counties statewide that experienced economic damage as a result of COVID-19. These short-term, interest-free working capital loans are intended to “bridge the gap” between the time a major catastrophe hits and when a business has secured longer term recovery resources, such as sufficient profits from a revived business, receipt of payments on insurance claims or federal disaster assistance. Small businesses are 2-100 Employees, Loan term is 1 year.
6. Coronavirus Aid, Relief, and Economic Security Act
Last night, March 25, 2020, the Senate approved legislation known as the Coronavirus Aid, Relief and Economic Security Act (the "CARES Act"). The Act contains a provision authorizing $350 billion of federally guaranteed forgivable loans to businesses with 500 or fewer employees. The amount of each loan is limited to the lesser of (a) $10 million or (b) the borrower’s average total monthly “payroll costs” for the 1-year period ending on the date the loan is made multiplied by 2.5.
In addition, A borrower may apply for forgiveness of a portion of the loan. The maximum eligible forgiven amount is equal to the cumulative amount of payroll costs, rent, utility payments, and interest paid on mortgages on real or personal property paid during the eight-week period following origination of the loan.
Coronavirus (COVID-19): Small Business Guidance & Loan Resources
7. Unemployment Benefits for Employees (Florida)
While we're waiting for some details it appears that Employees filing unemployment either for being layed off or furloughed will be able to receive up to $275 for 12 weeks from the State of FL AND in addition a Federal supplement of $600 weekly for 4 months. The federal supplement for FL has not been finalized and due to high traffic the FL Unemployment website appears to currently be down.
Florida Unemployment Coronavirus FAQs
The Department of Labor has just made this poster regarding employee rights for Corona Virus, it is required for all employers under 500 to post in a high traffic area. Get the poster here -
County Specific Coronavirus Updates
Insurance Carrier Coronavirus Responses
We are here for you! Please reach out with any questions.