Questions and Answers regarding the Families First Coronavirus Response Act (FFCRA)
Overview
1) I was told that we need to pay some of our employees for the federally mandated sick and family leave time as it relates to COVID-19. How do I find out more about the Families First Coronavirus Response Act (FFCRA)?
The best place to become familiar with FFCRA act is to use the Department of Labor (DOL) and Internal Revenue Service (IRS) online Q&A websites. The Certiflex Software FFCRA Sick Leave Tracker application has direct links to these web pages as well as other useful research links. It is important to remember that most of these policies and rules did not exist prior to being signed into law on March 18. As of the middle of April 2020, we are just now seeing some legal and accounting professional organizations and other companies start to publish online seminars that you might also find helpful if you are just getting started. Once you have a general understanding of the basics of the FFCRA act, you should review the short help screens within the FFCRA Sick Leave Tracker application to observe the simple yet complete functionality of what the tracker will do and how it can seamlessly integrate with CertiflexDimensionUltra Payroll if you desire it to.
2) What is the primary purpose of the FFCRA Sick Leave Tracker application?
This specially created application is designed to help employers track FFCRA Sick Leave pay that they have paid to their employees in a manner that will be helpful in reconciling any applied or unapplied Employer Federal Employment Tax Deposit credits on the yet to be published IRS – Quarterly 941 reports for the second quarter of 2020 and beyond. One of the premises of the FFCRA act is that qualified Sick Pay can be 100% refunded by the federal government relief funds depending on important limitations. The refunds will only happen if the employer can provide a solid audit trail of all requested and paid qualified Sick and other related Leave Time.
3) How long will the FFCRA Sick Leave act be in effect?
The FFCRA act affects sick leave that is paid beginning on April 2, 2020, and ending on December 31, 2020. These dates are related to the actual paycheck dates, and not necessarily the dates on which the leave was taken.
Adding Employees
4) Why do I need to add employees into the FFCRA Sick Leave Tracker application when they already exist in CertiflexDimension Ultra Payroll?
It is highly likely that most FFCRA qualified employers will only have a portion of their employees qualify for paid sick leave under the act, but when they do, there are additional criteria that need to be set up and tracked for each of those employees. It is much cleaner and simpler to only have the employees in the tracker who are being paid in relation to the act.
5) Why can’t I just use the current pay rate that is already setup on an employee in Payroll instead of having to type in the same rate into the FFCRA tracking system?
Sometimes it will be the same rate, but oftentimes the FFCRA hourly rate will need to include additional pay items like average tips, bonuses, and commissions. Also, the Payroll system allows up to ten hourly pay rates, so it would not be apparent which rate to use.
Recording FFCRA Employee Hours
6) Why do I need to add hours to the FFCRA Sick Leave Tracker instead of directly into CertiflexDimension Ultra Payroll’s Record Pay Data option?
The payroll system has a very flexible pay data entry process designed to record employee pay in a wide variety of formats and rates. The specifics of the FFCRA qualified pay call for fixed pay rates as employee requested by day, and not hours (see DOL Q&A #21). We have streamlined this process in the tracker to efficiently allow time entry for an employee for an entire pay period into just a few clicks in what would take an immense amount of time to enter into the standard system. When you save your requested hours in the tracker system, it automatically updates the individual Special Pay Code (that is easily set up for you on request in the system) for the employee for the proper amount to be paid so that when you validate the pay for the employee within the payroll system, the sick leave pay is already calculated and entered. The Special Pay Code amounts are automatically reset back to $0 upon the check printing process within Payroll, and the actual individual check number and dates are seamlessly updated back to the tracker system.
7) I have already paid some of my employees for previous used sick leave hours. What do I do now?
The FFCRA Sick Leave Tracker system is designed to handle your interactive Payroll needs or optionally to run in a completely ‘after-the-fact’ mode, or in a mixture of the two modes as well. The Pay Data Entry system of the tracker has a sub option called ‘Manual Time’ that functions exactly like the regular ‘Record Time’, but when it is used, it will ask for the check number and check date for the amount that was already paid to the employee for the requested sick leave pay.
8) When I first enter a sick leave day for an employee that does not have any previous FFCRA pay, how does the system choose the default first requested date?
The first time you enter sick leave pay for an employee, the system uses the current date minus five working days assuming the most common data entry mode will be weekly on a Friday.
Tax Deposits
9) I have already paid some of my employees for previously used sick leave hours and made tax deposits. Can I still use the deposit system in the tracker to record the tax deposit?
Yes. The deposit system is not dependent upon CertiflexDimension Ultra Payroll individual paycheck runs for the calculation of payroll deposits to be made. In fact, if you make two payroll check runs inside the payroll system on the same day, the deposit system of the tracker will automatically combine the two check runs together into a single deposit amount.
10) I show a net available FFCRA tax deposit credit, but the deposit system will not allow me to apply the remaining amount to the IRS Form 7200. Why is that?
In order to apply any remaining FFCRA tax deposit credits to the IRS Form 7200, you must first use the tax deposit adjustment amount so that it will bring your after-adjustment tax deposit amount due down to $0.
Export Sick Leave Hours and Deposits
11) Why does the export system not allow me to print actual reports?
The export system is designed to allow you to create reconciliation information that the IRS will need to support the credits you are claiming to your employer tax deposits. Since there is no determined format of how they will want this information at this time, it was determined to be best to export all the information in a common format that will allow you to format the detail into whatever will best fit your needs in the future.
12) Why when I export my paycheck stub information and paste the results into my word processing system does everything go out of whack?
The pay stub export includes quite a lot of information on each line of sick leave pay. For example, many people use one-inch margins by default in Microsoft Word and for all this detail to fit properly on a page, you will need to change your left and right page margins to ½ inch instead of 1 inch, or even less depending on your default fonts. You could optionally paste the pay stub information into Microsoft WordPad, and everything would look fine without having to change your page margins. Be sure to use a font that is not “proportionally spaced” so that columns align with each other regardless of the number and size of letters being used.
