In March of this year, President Biden signed into effect the American Rescue Plan Act (ARPA). The Act put forth extensions to existing policies, as well as new policies to consider. For example, the Families First Coronavirus Response Act (FFCRA) was extended as a part of the ARPA. This key element is set to expire at the close of the quarter: September 30, 2021. To best understand the impact this may have on you and your employees, we will first review the policy.
Paid Sick and Family Leave Credits
- ARPA does not mandate employers continue to allow the use of COVID Sick or COVID Leave benefits.
- Should employers choose to continue these benefits, the 10-day limit for paid COVID Sick leave restarted on April 1, 2021, and the tax credits set forth by the Families First Coronavirus Response Act (FFCRA) will be extended to September 30, 2021.
- ARPA extends the COVID Sick eligible criteria to include time for individuals to receive the COVID vaccination and/or recover from the COVID vaccination.
- ARPA extends the aggregate amount of COVID Leave pay an individual is eligible to receive from $10,000 to $12,000. In addition, the 10-day waiting period to utilize COVID Leave will be waived.
- COVID Leave eligibility should be applied the same as COVID Sick eligibility.
What does the end of the paid sick and family leave credits mean to you? For starters, your employees’ time away from work related to the COVID illness or vaccination is a decision to be made by you as the employer, barring any state, local, or future government mandates (see below). It is important to note that states and localities are aggressively adding mandates for paid sick leave or extended COVID leave as a result of the pandemic. It is critical to look at all requirements: local, state, and federal, before finalizing your sick or paid time off policies.
Resourcing Edge is here to help you navigate the compliance complexities associated with sick leave as you consider updates to your policy. It is also important to note the tax credits extended to employers through FFCRA will be coming to an end effective September 30, 2021.
On September 9, 2021, the Biden administration announced that the Department of Labor’s Occupational Safety and Health Administration (OSHA) is developing a rule that will require all employers with 100 or more employees to ensure their workforce is fully vaccinated or require any unvaccinated employees to produce a weekly negative COVID-19 test result before coming into work. The White House also announced that employers subject to the new rule will be required to provide paid time off for the time it takes for employees to get vaccinated or to recover if they are “under the weather” post-vaccination.
As of now, neither the White House nor OSHA has provided any further details on this rule. As guidance is released, Resourcing Edge will continue to keep you up to date with how this interacts with other COVID-related acts coming to an end.
Should you have any further questions, please contact your Client Account Manager for support.
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