Back to School and COVID FFCRA Pay to Your Staff

This blog post applies for any dentists with employees that:

  1. Are requesting time off in order to be at home to care for their children that are enrolled in online school or for whom day care is not available.
  2. Are requesting time off to care for themselves or a family member that have been affected by COVID.

With virtual school starting, and parts of the economy opening back up, there may be a renewed interest in the Family First Coronavirus Response Act (FFCRA). After all, it dictates what you’re required to pay your employees due to coronavirus related time off.  PracticeCFO has researched the legal guidance from two dental-specific attorneys that we highly respect to determine whether you are, in fact, required to make FFCRA payment to their employee requesting COVID-related time off. Here’s what we found:

  • Attorney one: Believes that dentists are subject to FFCRA pay. Click here.
  • Attorney two: Believes that dentist are not subject to FFCRA pay: Click here.

If you’re in agreement with attorney two, nothing more for you to do.

If you’re in agreement with attorney one and you believe you’re required to issue FFCRA pay to your team, you’re able to receive a full payroll tax credit for doing so. The tax credit may be refundable as well. However, in order to receive this credit, all FFCRA wages MUST be coded separate from your employee’s regular sick and vacation time.  Your payroll provider has set up specific pay items (rows) for you when entering payroll. Most of you are with MyPay Solutions. If you need to make FFCRA payments to your employees, please contact Ginger Monroe (gingermonroe@mypaysolutions.com). She will set up the pay items, which will include:

  1. COVID 19 – Self (This pay items is used if your employees ordered to quarantine or that have symptoms of COVID and are seeking treatment. Pay is 100% of regular wages up to two weeks of pay with a maximum of $511/day).
  2. COVID 19 – Other Care (This pay item is used for employees caring for a family member that is ordered to quarantine or a child whose school or place of care is unavailable for in-person care/classes. Pay is 2/3rds of regular wages for up to two weeks with a maximum of $200/day). 
  3. COVID 19 – Extended (This pay item is used for employees caring for a child whose school or place of care is unavailable for in-person care/classes and provides an additional 10 weeks of pay. Pay is 2/3rds of regular wages for up to two weeks with a maximum of $200/day). 

MyPay Solutions has notified us that immediately upon submitting FFCRA pay using those three codes above, MyPay will remove FICA for that specific payroll and provide a credit for the remaining FFCRA pay that will be submitted for a refund on the next quarterly 941 filing.

Please note that you can claim both PPP forgiveness and the FFCRA tax credit as long as they are not used for the same wages paid. Given the 24-week PPP forgiveness period, we don’t see this being a problem. Also, for each employee you pay FFCRA wages to, be sure to have that employee attest in writing to the following:

  1. Name and age of the child;
  2. The name of the school that has been closed or place of care that is unavailable;
  3. A representation that no other person will be providing care for the child during the time periods the employee is receiving extended FMLA benefits and, if appropriate, the employee is unable to work remotely while providing child care or supervision.

As always, reach out to your PracticeCFO team with further questions!

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