Families First Coronavirus Response Act and Paid Leave

Effective April 1, 2020, the Families First Coronavirus Response Act (FFCRA) requires certain employers to provide their employees with paid sick leave or expanded family and medical leave for specified reasons related to COVID-19. FFCRA includes two types leave as defined in the following Acts:

• Federal Emergency Paid Sick Leave Act (EPSLA): This Act provides all employees up to 80 hours of paid or partially paid sick leave for COVID-19 related reasons. Qualified sick leave wages are wages subject to withholding of federal income tax and the employee’s share of Social Security and Medicare taxes but are exempt from employer taxes for Social Security. Districts must also ensure that EPSL will not change the employee’s pre-existing leave balances.

• Federal Emergency Family and Medical Leave Expansion Act (EFMLA): This Act provides eligible employees up to twelve weeks of job protection leave related to school or daycare closure. Employees employed for at least 30 days are considered eligible. The first two weeks (10 days) are unpaid unless the employee elects to use other paid leave. EPSL can be used in combination with EFML. Qualified sick leave wages are wages subject to withholding of federal income tax and the employee’s share of Social Security and Medicare taxes but are exempt from employer taxes for Social Security.

Follow these links to learn more about how to comply with FFCRA regulations:

• Families First Coronavirus Response Act: Employee Paid Leave Rights
• New Federal Paid Leave Legislation - WASBO

WSIPC Guidance for SMS 2.0

To help school districts meet the impacts of FFCRA, WSIPC has put together the following guidance for SMS 2.0:

Tracking EPSL and EFML Leave: To better manage and keep compliance with FFCRA regulations, track EPSL and EFML leave separately.

Time Off Setup: To manage this new federal leave, consider adding new types of Time Off Codes and corresponding Reason Codes. Separate codes will assist with monitoring balances and better managing payout amounts. Ultimately, FFCRA wages will be processed as a time off cash out transaction.

Pay Codes: To process the payments of the FFCRA time off transactions, consider building new Pay Codes. The Department of Retirement Systems (DRS) has provided guidance to determine if the payments paid to employees per FFCRA are reportable to DRS (DRS FFCRA Communications). Not all FFCRA leave payments are reportable to DRS, so this will require setup of at least three new Pay Codes.

Payroll Transactions: Generally speaking, processing COVID related payroll transactions will involve the following:

• Sale of FFCRA Time Off: To reduce time off balances and create pay transaction(s). This will allow you to reduce the corresponding FFCRA time off balances, allow the system to provide the correct hourly rate, and ultimately create the pay transaction.
• LWOP Transaction: To reduce the contract amount.
• Time Off Transaction: In some cases, districts may allow employees to use existing sick or vacation time off to supplement their pay. This is a district decision and may not apply to all.

FFCRA FICA Tax Processing: Employer FICA tax may be overstated when processing FFCRA pay. SMS 2.0 will calculate employee (EE) and employer (ER) FICA tax on all processed pay for an employee when at least one of the pay items has a FICA deduction and benefit associated. To process accurate tax amounts, your district can do one of the following:

• Run separate payrolls for FFCRA pay and Non-FFCRA pay OR
• Run a combined payroll with a FICA Amount type adjustment benefit code to reduce FICA benefit amounts
• Run a combined payroll with a FICA adjustment benefit code to reduce FICA benefit amounts

WSIPC Guidance for Qmlativ

To help school districts meet the impacts of FFCRA, WSIPC has put together the following guidance for Qmlativ:

Tracking EPSL and EFML Leave: To better manage and keep compliance with FFCRA regulations, track EPSL and EFML leave separately.

Time Off Codes: To manage this new federal leave, consider adding a Time Off Type Code that is specific to FFCRA leave. Time Off Reason Codes can then be used to further define the FFCRA qualifying reason for their absence. Keep in mind that the payout for Emergency Paid Sick Leave (EPSL) and Emergency Family Medical Leave (EFML) wages is different if the employee is sick themselves, or if they are taking time off to take care of a dependent. Using different Reason Codes can more efficiently track what the appropriate pay is for the corresponding situation.

Pay Type Codes: To process the payments of FFCRA time off transactions, consider building new Pay Type Codes. The Department of Retirement Systems (DRS) has provided guidance to determine if the payments paid to employees per FFCRA are reportable to DRS (DRS FFCRA Communications). Since not all FFCRA leave payments are reportable to DRS, contracted employees will require dock pay and different pay rate options. This will require setup of at least four new Pay Type Codes.

Timesheet Groups: Depending on the number of COVID-19 pay transactions, districts may consider creating a specific Timesheet Group to allow the district to mass process employees’ pay transactions corresponding to COVID-19 pay.

Pay Transactions: Your district can allow employees to use paid time off to supplement the portion of their FFCRA leave that is unpaid.

FFCRA FICA Tax Processing: Employer FICA tax may be overstated when processing FFCRA pay. Qmlativ will calculate employee and employer FICA tax on all processed pay for an employee when at least one of the pay items has both FICA deduction and benefit associated. FFRCA pay amounts are not excluded from FICA benefit calculation as anticipated. To process accurate tax amounts, your district can do one of the following:

• Run separate payrolls for FFCRA pay and Non-FFCRA pay OR
• Run a combined payroll with a FICA adjustment benefit code to reduce FICA benefit amounts

To learn more about how to comply with FFCRA, contact your Information Service Center.

WSIPC is a non-profit public agency that provides technology solutions (including SMS 2.0 and Qmlativ), services, and support to K-12 schools. WSIPC’s purpose is to help schools do more with every dollar and to empower them with the tools to work smarter. To learn how your district can become part of the WSIPC Cooperative, contact us at info@wsipc.org or 425.349.6600.

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