Recorded live on September 30th at 1 PM EST
COVID HR Policy Workplace Update: Vaccine Mandates, Safety, COBRA Subsidy, and More
Please note: On Saturday, November 6, the Fifth Circuit Court of Appeals placed a temporary hold on the OSHA Emergency Temporary Standard (ETS) requiring COVID vaccination or testing for employees of employers with 100 or more employees. The current ruling is temporary, but there are likely to be updates soon. MP will update our materials accordingly. In the interim, our HR services experts recommend employers continue to prepare in case these deadlines are upheld.
Healthcare: A preliminary injunction has enjoined the Centers for Medicare and Medicaid (CMS) from enforcing its COVID-19 vaccine mandate nationwide. Appeals may result in the mandate taking effect later. Employers may choose to proceed considering state-specific requirements and prohibitions, or wait for a final decision on the mandates if applicable. Based on the outcome, all affected employers should stay updated and prepare to respond quickly.
Federal contractors: A preliminary injunction has been declared, prohibiting the federal government from enforcing its COVID-19 vaccine mandate for all federal contractors and subcontractors. Appeals may result in the mandate taking effect later. Employers may choose to proceed considering state-specific requirements and prohibitions, or wait for a final decision on the mandates if applicable. Based on the outcome, all affected employers should stay updated and prepare to respond quickly.
View Transcript – Please note, this content was automatically generated by Zoom and has not been reviewed for accuracy. Please listen to the recording for complete accuracy.
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MP: Good afternoon, everyone, thank you for joining us today for an MP webinar on coven HR policy updates i’m amy women had a marketing here at NP and for those of you joining us on a webinar for the first time.
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MP: MP, is a full service human capital management company.
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MP: With a full suite of products, including HR payroll benefits administration time and attendance and compliance assistance.
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MP: We support our clients with cutting edge technical solutions, as well as proactive reliable service and deep HR and payroll expertise at NP we are wired for HR and help our clients succeed by aligning their people strategy with their business goals.
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MP: i’m excited to introduce to you, your presenter today he’s MPs VP of HR services Parker Ellis Paul has over a decade of experience in the HR consulting consulting space working across a number of industries of all sizes and.
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MP: types Paul and his team have certified HR professionals assist clients with compliance training and full circle HR guidance and support.
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MP: Just before we get started, today, if you would like to submit a question during the program please use the Q amp a feature at the bottom of the screen.
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MP: and also a recording of the webinar will be sent out later today flying the presentation, along with Paul slides and with that i’m going to hand the MIC off to Paul.
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Paul Carelis: Great Thank you so much amy welcome everyone today.
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Paul Carelis: As usual, very timely topic or set of topics will be talking about.
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Paul Carelis: As much as we’d like to think or believe or maybe a couple months ago really thought that we were we were post pandemic unfortunately or not, but.
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Paul Carelis: That being said, it’s a mixed bag, in terms of which forms of relief or programs either set up for employers or employees our employees are expiring, and frankly expiring other today.
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Paul Carelis: So quick legal disclaimer this training is intended, from an HR educational standpoint, not an attorney so please don’t consume anything as legal advice.
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Paul Carelis: Also, another important note is that all the information in case you’re watching a recorded or rebroadcast that version of this information that we’re discussing today is is relevant and accurate as of September 30 2021.
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Paul Carelis: So what we hope to cover in today’s session first will be an update on the vaccine mandates.
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Paul Carelis: Definitely a hot topic this month we’ll also talk about covert sickly both from the Federal Cobra typically programs as well assignment city and state levels.
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Paul Carelis: will talk about the end of the Cobra subsidy program and what you need to do as an employer.
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Paul Carelis: will discuss HR strategies around all these things will also do a quick update on the employee retention tax credit program as we’re getting a ton of questions on that and the fate of that.
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Paul Carelis: Program.
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Paul Carelis: And as amy said, if you do have any questions related to any of this stuff or anything that you feel might be related to this stuff including etc feel free to pop those in our Q amp a.
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Paul Carelis: And we will do our best to address those either here live or or follow up.
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Paul Carelis: Okay, so first let’s tackle the vaccine mandates.
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Paul Carelis: So.
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Paul Carelis: there’s been a lot of press and publicity dating back to September 9 when President Biden issued executive orders.
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Paul Carelis: The real attention grabber and the one that really captured the headlines.
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Paul Carelis: Was the mandate for all employers with 100 or more employees.
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Paul Carelis: But really there were kind of three separate orders issue that day that affect three different types of businesses, the first of which was an order for federal contractors so just the mandate for the employees of federal contractors that they would need to be vaccinated.
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Paul Carelis: There was also an executive quarter that covers medicare and medicaid certified facilities so.
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Paul Carelis: pretty much any type of medically related business that accept medicare and medicaid as forms of payment.
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Paul Carelis: nursing homes long term care facilities, hospitals, doctors, what have you employees of those organizations are also facing a potential vaccine mandates.
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Paul Carelis: And then, finally, there was the mandate for private sector employers, where the hundred or more employees 20 different differences between those three at least what we know now so we’ll talk about what we know and what we don’t.
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Paul Carelis: Based on the original kind of draft form of guidance within the executive order that’s sometimes a little bit light on detail the private sector employer mandate those have the alternative of a weekly testing requirements.
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Paul Carelis: But and less of cases of valid exemption and the details of that we don’t yet know and.
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Paul Carelis: How many exemptions are going to allow or what kind the federal contractor mandate and the medicare and medicaid certified organization mandate does not have that alternative to do weekly testing it’s simply either have to be vaccinated for me, one of the qualified exemptions or.
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Paul Carelis: kind of been a tough buck scenario there.
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Paul Carelis: So what we do know is that earlier this week I might have been like last week was interactive the time you are things moving so quickly.
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Paul Carelis: There was a federal contractor guidance issued.
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Paul Carelis: Early some initial guidance in terms of the program as it pertains to federal contractors.
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Paul Carelis: Interestingly.
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Paul Carelis: The guy did state that this mandate will apply to contractor employees, both on site, as well as remote workers, which I, at least I didn’t quite expect.
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Paul Carelis: In addition to the vaccine mandate in terms of those who are working on site at contractor workplaces and there will be mapping and social thing requirements as well, and that applies to both employees, as well as visitors to those work sites.
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Paul Carelis: It also it and it’s important to note, they also noted that it does not only apply to employees working on T government contract a federal contract, it would apply to all the employees working at that at that site as well.
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Paul Carelis: there’s also a requirement.
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Paul Carelis: For the company that doesn’t need either you know as an individual to someone like a safety officer or have a committee to ensure that the Federal contractor is acting safely when it comes to Kobe 19 precaution and to monitor compliance with with the regulations that they roll out.
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Paul Carelis: Some other key aspects of the federal contractor vaccine mandates and again this is simply the federal contractor piece, this is not necessarily apply to.
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Paul Carelis: The others the medicare and medicaid nor the private employer.
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Paul Carelis: So this doesn’t necessarily apply to existing federal contracts, but it will apply to all eligible federal contracts awarded on or after or renewed after November 14 this year.
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Paul Carelis: There will be a deadline for compliance with with all the aspects of the mandate of December 8 of this year.
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Paul Carelis: has a right now contracts with a value of less than a quarter of million dollars will seemingly be exempted, although they will be encouraged to still follow the guidance and then the mandate.
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Paul Carelis: In terms of the types of federal contracts, they generally focused on on contract providing some sort of service.
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Paul Carelis: If it’s a federal contract that is solely providing products manufacturing things like that those as of right now are also excluded.
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Paul Carelis: And, as I mentioned a few minutes ago, as of right now for the Federal contract and mandate, there is not an option to to waive the vaccine requirement instead do the weekly testing like there is for private sector.
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Paul Carelis: Okay, so what other remaining questions well there are countless once but but among the remaining questions.
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Paul Carelis: Definitely we’re waiting on guidelines for the medicare and medicaid certified organization, as well as private sector employers.
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Paul Carelis: We can’t.
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Paul Carelis: We can’t gain or gather too much insight based on the the federal contractor regulation because they’ll apply to these other groups.
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Paul Carelis: mainly because there are different governing body issue and their rules and regs so the federal contractor guidelines were issued by what’s known as the safer federal work Task Force.
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Paul Carelis: The private sector rule they’re going to be coming from ocean, the Department of Labor so when it comes to things like remote workers and whether or not they’ll be required to meet the.
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Paul Carelis: The guidelines and the mandate for vaccination we don’t know and while it is in place for the Federal contractors OSHA might see things differently so that isn’t necessarily a slam dunk.
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Paul Carelis: One of the real burning questions and what people are already really innovating department of Labor with is when it comes to.
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Paul Carelis: Those who are opting for testing rather than vaccine who’s going to be responsible for the cost of that testing will that be an obligation on employers will they be allowed to have the employees bear that cross and then from a wage in our perspective.
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Paul Carelis: You know is that testing going to be considered compensable time well employers need to pay employees or allow for time at the beginning of a shift or ahead of a shift or otherwise compensate for the time that it will take for the employees to undergo that coven 19 testing.
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Paul Carelis: And then we’re you know we’re also really hoping for the clear guidelines for exemptions most cases that have come up so far have really narrowly defined what what is the true.
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Paul Carelis: Medical or religious exemption many religious organizations are distancing themselves from being included, as is counting as an exemption so.
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Paul Carelis: We imagined the list will be very narrow and small, but that does remain to be seen so we’re not ready to make a clear definitive statement on that just yet.
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Paul Carelis: Other remaining questions include the timeline and the effective date so for those federal contractors, it looks pretty certain that December 8 will be will be that.
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Paul Carelis: start date, although that could change if if there is a core challenge that has some success and create a stay of the of the mandate or what have you.
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Paul Carelis: There are sure to be an already have been some core challenges on this, I believe, Arizona is challenging the private sector employee mandate, I will say that individual cases where employees have have sued for delays or.
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Paul Carelis: Food based on the constitutionality of a vaccine mandate at an employer, the ones that i’ve seen and study have have always sided with with the mandate or what the employer, so there was a big landmark case.
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Paul Carelis: In Houston with one of their hospital system where the hospital network did have a vaccine mandate.
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Paul Carelis: The employees challenge that but they lost their case in the appeals court and the District Court so that that mandate was was approved, more recently.
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Paul Carelis: Some Massachusetts State police state troopers to to delay the state police’s vaccine mandates that set to take an effect and just this week, the Court.
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Paul Carelis: sided against them in that so has these cases pile up to date, just about all and I don’t know of anywhere, where a mandate has been ruled or shot down the mandates have stayed in effect obviously something that’s.
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Paul Carelis: covering every employee of a company that has 100 or more employees is a lot more far reaching them an individual institution or company so we’ll see if any of these have legs, but as of now we’re proceeding as if these mandates will take effect, once the rules have been issued.
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Paul Carelis: We don’t have too much clarity, also on penalty mechanisms and amounts a number that was originally floated up there were penalty for the private sector sector employers up to $14,000.
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Paul Carelis: there’s also been some rumors within the last 24 hours that something has to be included in the reconciliation bill currently in Congress.
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Paul Carelis: could have those penalties increased quite dramatically into the 10s of thousands of dollars not hundreds of thousands of dollars, but.
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Paul Carelis: Again, how those how those will be what the mechanisms will be for those penalties or it’ll be a complaint system or an audit system or.
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Paul Carelis: Reporting System and what those actual amounts will be and if there will be a sliding scale, like many harsher penalties are when they can be greatly multiplied and magnified when it’s found to be willful.
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Paul Carelis: Violations of safety rules versus accidental or administrative violations of of safety rules will that remains to be seen as well.
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Paul Carelis: We also don’t know what will be in place in terms of aggregation rules.
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Paul Carelis: So.
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Paul Carelis: When there is an entity that has multiple multiple federal ID multiple locations.
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Paul Carelis: And the ownership stake in those as.
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Paul Carelis: If goes employee Council need to be aggregated for terms of determining side.
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Paul Carelis: There are also state and city level level regulations that may differ in certain key ways from the Federal vaccine mandate.
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Paul Carelis: So interaction with with those will be interesting, as well as interaction with with private policy, so if you go to the next slide can talk about.
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Paul Carelis: What some some larger businesses they’re currently doing when it comes to kind of being ahead of the curve here are ahead of the the actual legal mandate.
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Paul Carelis: delta’s doing something very interesting I believe they do have a vaccine mandate that they’re rolling out as well, but in addition to that.
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Paul Carelis: For employees who are not getting vaccinated and who participate in their group health insurance delta’s tacking on a $200 monthly.
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Paul Carelis: charge on top of their existing health insurance costs to employees who are not getting vaccinated saying the the cost of COPA 19 and and medical services, treating people who test positive for Cobra 19 so they’re doing a $200 surcharge on their health insurance.
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Paul Carelis: Cisco is is taking the route where even if you want to be in person or be doing anything within their offices, you need to be vaccinated they are allowing remote or.
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Paul Carelis: Employees who otherwise don’t come into the company’s offices to not have to be subject to the vaccine mandates obviously that may change depending on.
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Paul Carelis: What how the OSHA rules end up coming out in terms of treating remote workers.
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Paul Carelis: For its current policy.
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Paul Carelis: Is a vaccine mandate, but only for those who are doing international travel so again, that that will change as the rules for the vaccine mandate rollout and then Tyson I think was a couple months ago now announced the more kind of traditional vaccine mandate for all their workers.
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Paul Carelis: there.
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Paul Carelis: believe their office workers had to be vaccinated by tomorrow the field and factory workers had to be vaccinated by November 1 so there’s still a month ago there.
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Paul Carelis: And they just actually I had this slide in here anyway, but, as I was reading the news I saw they did just kind of report their their results so far so before they issued the mandate.
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Paul Carelis: Tyson said that that fewer than half of their employees were were vaccinated and, as of today, they’re saying that 91% of their workforces vaccinated so.
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Paul Carelis: Definitely, a huge increase in vaccination rates they didn’t talk about any potential turnover or people who left as we doubled the mandate, but they did say that over 91% of their their workforce is now vaccinated.
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Paul Carelis: i’m gonna take a quick look at some looks like we’ve got a question in here.
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Paul Carelis: Alright, so in the ambulance service that accept medicare payments, the quarter was written for federal contractors has the language of any organization that the contract like instrument qualify for the Program.
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Paul Carelis: So the question is is someone technically has a federal contract and accept medicare payments which rule, where they fall over if the rules are different.
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Paul Carelis: So.
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Paul Carelis: We don’t yet know, I think, once the once the medicare and medicaid rules are released, which should be fairly soon.
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Paul Carelis: There should be a discussion because I believe there are a number of businesses who undergo categories ambulance service is a great example of one.
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Paul Carelis: But there should be some directive within the regulations in terms of of which rules would need to be followed.
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Paul Carelis: But we will be sure to update folks once once the kind of second hand or falls there.
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Paul Carelis: Okay, another question just came in, please confirm all mandates currently apply only to those private businesses over 100 employees what, if any mandates apply to small businesses under 100.
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Paul Carelis: So, in terms of vaccine, at least at the federal level yeah as of right now, it will only apply to.
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Paul Carelis: private businesses over 100 employees again different story potentially if you are a medicare medicaid certified organization again we’re waiting for the rules on that to come out but that could could affect smaller employers.
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Paul Carelis: You do also want to check wherever you have employees located both at the city and state level as.
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Paul Carelis: As those smaller governments decide or start to pass localized vaccine mandates or rules or regulations, because those would supersede.
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Paul Carelis: Any any exemption, you have a smaller business potentially depending on on the rules, but as of right now, at least from a federal standpoint, not knowing where you’re located.
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Paul Carelis: There is not a not a vaccine mandate in place for for any businesses and, frankly, even for the larger ones, the rules are not yet so there’s nothing, nothing in place right now, where you’re in any type of violation, as of today.
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Paul Carelis: Okay, so.
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Paul Carelis: question here, will the employer be responsible to pay for the test and the employee time taking their see the test actually so that is one of the most burning question.
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Paul Carelis: We posed that question of the Department of Labor and OSHA we haven’t gotten an answer, yet, but we do almost guarantee that that will be discussed when when the rules early so when the executive order was was signed on to December night.
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Paul Carelis: They said the OSHA rules would follow in the next several weeks so really we’re hoping that sometime here.
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Paul Carelis: Tomorrow will be October so we’re counting on those hopefully be released sometime in the month of October here, but we haven’t been given any sign of a date that those rules will be published.
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Paul Carelis: Okay, so an electronic distributors subcontractor.
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Paul Carelis: yeah if you can make the argument that your your federal contract is simply for the her solely for the provision of products.
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Paul Carelis: You should technically be exempt at least under this initial initial guidance and, if anything, if you take anything away from today’s presentation, whether it be about this or any of the other programs we’re going to talk about.
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Paul Carelis: I just really, really urge you to stay up to date, before you make any decisions they’re just you know stay on our mailing list keep attending the Thursday webinars.
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Paul Carelis: because all of these things have to change it’s really important to know either fear accurate as of you know, probably noon time today September 30 but.
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Paul Carelis: Then you can change in the blink of an eye so it’s really important that that we stay on top of this, collectively, and that you keep yourself updated, especially when it comes to things like the city regulations which can pass very quietly.
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Paul Carelis: Okay, so all right so Massachusetts yes so Massachusetts is not currently have a vaccine mandate for for employers, we will be talking about the requirements here for for covert sick leave.
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Paul Carelis: Massachusetts did Jeff extend their cool basically talked about that in a few minutes and we’re also going to take a really deep dive into that program in next week’s webinar.
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Paul Carelis: Okay, so question about locations.
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Paul Carelis: That is that’s going to be resolved within the dll guidance of the OSHA guidelines when it comes out in terms of.
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Paul Carelis: If you have you know if it’s going to be like la where it’s so many employees and 75 mile radius whether it’s 100 employees across.
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Paul Carelis: All the control groups organizations if it’s across everyone under the same federal ID across all locations under that that ID we don’t quite know just yet, but.
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Paul Carelis: We are working hard to get a determination there and get a ruling from promotion, the Department of Labor.
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Paul Carelis: Okay, so some questions coming in, about some of the other stuff will be talking about so i’ll kind of leave it at that and we’ll start talking about about Cobra so.
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Paul Carelis: Something that’s kind of you know, in talking with businesses, something that they kind of forgot about we started this Cobra subsidy program back in April, where anyone who was still eligible for Cobra and who was basically.
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Paul Carelis: terminated and voluntarily.
00:26:32.970 –> 00:26:45.360
Paul Carelis: and did not was not eligible for coverage elsewhere was eligible to get you know fully subsidized insurance to Cobra, but that is ending, as of today, September 30 and has not been extended.
00:26:49.560 –> 00:26:59.070
Paul Carelis: One one requirement that businesses do have, if you do use a Cobra administrator they they should have taken care of this for you, but if you’re doing all of your Cobra in house.
00:26:59.940 –> 00:27:09.960
Paul Carelis: it’s something that you’ll want to do as soon as possible, part of the regulations for the Cobra sub speak to do require the business to send out a notice of exploration of premium assistance.
00:27:10.590 –> 00:27:17.670
Paul Carelis: So basically saying that as of September 30 the premium assistance or the the subsidies, those are.
00:27:18.240 –> 00:27:30.060
Paul Carelis: identical terms just different words for it, but that is ending as December 30 and then depending on the situation, either the Cobra eligibility can continue at full cost or you no longer eligible for Cobra either.
00:27:31.380 –> 00:27:42.660
Paul Carelis: So again, if you use a Cobra administrator double check with them to make sure that they’re fulfilling their requirements they are your requirements to get those out if you’re doing it in house.
00:27:43.470 –> 00:27:49.140
Paul Carelis: You want to get your hands on on a sample form of that notice of exploration and then make sure those gets sent out.
00:27:51.000 –> 00:27:52.800
Paul Carelis: And then, when it comes to.
00:27:54.600 –> 00:28:10.890
Paul Carelis: Cleaning because, while many employers and it depends on size but many companies to kind of have to bear the cost of others Cobra subsidies, initially, and then kind of pay for the premiums, you are able to get that money back through tax credits.
00:28:12.240 –> 00:28:16.770
Paul Carelis: But you need to get those reported on on a 941 and something that’s important.
00:28:18.330 –> 00:28:31.200
Paul Carelis: They are expecting those to be Queens on on the correct 941 so in the case of right now, or we’re about to file quarter three 940 ones for businesses in the next few weeks, so that would cover.
00:28:33.840 –> 00:28:43.710
Paul Carelis: The last three months July August September, but if you had Cobra subsidy that applied to April May or June or second quarter.
00:28:44.820 –> 00:28:53.340
Paul Carelis: The irs is really expecting to be reported on the second quarter 941 and not the third quarter they don’t want to all just lumped together and grouped into one.
00:28:54.060 –> 00:29:12.360
Paul Carelis: So if if that is the case, if you did have Cobra subsidy that you haven’t yet claimed for insurance coverage and subsidies that we’re covering covering second quarter, you may want or need to amend your 941 file and 941 text to claim me the subsidy credits on on that relative quarter.
00:29:22.890 –> 00:29:25.620
Paul Carelis: Alright, so let’s talk about Cuba typically.
00:29:27.600 –> 00:29:30.990
Paul Carelis: From a federal standpoint, as well as several steep.
00:29:33.000 –> 00:29:40.770
Paul Carelis: arpa American rescue plan at cobo typically ends, as of today, September 30 that has not been renewed so.
00:29:41.970 –> 00:29:51.900
Paul Carelis: After today, there will be no more there will be no more new claims for covert sick leave as a reminder this this has an optional all year.
00:29:52.650 –> 00:30:04.890
Paul Carelis: It hasn’t been a requirement business and nothing required to offer federal code sick leave, but it has been has been available and many businesses have taken advantage of it, especially since they reimburse through tax credits.
00:30:06.270 –> 00:30:12.540
Paul Carelis: If you do have an employee who’s currently on our believe if they started on September 30 or earlier and it carried over.
00:30:12.990 –> 00:30:28.560
Paul Carelis: Past September 30 they are still allowed to be on that we’ve and you still being reimbursed for the leaf it’s just that there can’t be any arpa copacetic leaves or any other federal co basically starting after October 1 October 1 or later.
00:30:33.150 –> 00:30:49.590
Paul Carelis: And one other important note on this from the Federal standpoint, it is important to note that the American rescue plan act co would leave and the FF CRA could leave from last year and from I believe the beginning of this year as well are technically different programs so.
00:30:51.180 –> 00:31:01.620
Paul Carelis: In whatever payroll system you use you’ve been reporting time identically you know, under the same earnings columns for fs era, as aarp a code leave.
00:31:02.310 –> 00:31:19.800
Paul Carelis: you’re going to want to double check that you really should have been using a separate field a column for that there are some slight but significant differences between the two programs in terms of a you know what those earnings are taxable for on the on the employer tech side.
00:31:21.030 –> 00:31:31.650
Paul Carelis: and be also what they serve as a mechanism as a credit against when when you’re getting reimbursed, so it is important that if you use both the old kind of old school ffc reiko believe.
00:31:32.310 –> 00:31:43.530
Paul Carelis: And, as well as the newer harper from April on code leave that those are those are differentiated in your payroll system, because they are slightly, but significantly different.
00:31:50.820 –> 00:31:56.580
Paul Carelis: Okay, so when it comes to the other coven sickly programs out there.
00:31:57.870 –> 00:32:05.910
Paul Carelis: It really is a mixed bag, so you really need to take a look at what stage, you have employees and and what cities, you have employees and frankly.
00:32:07.140 –> 00:32:14.940
Paul Carelis: Because you know kind of without without much fanfare a lot of locations past some some version of covert leave.
00:32:15.720 –> 00:32:24.510
Paul Carelis: There are a lot of states and the growing number of states that you know either expired or never had a State specific or as a specific coven sick leave.
00:32:25.440 –> 00:32:40.350
Paul Carelis: But they do have vaccine we’ve so paid time for employees to go obtain a vaccine and many of those are extended, either through the end of this year, or sometimes at the end of 2022 so you do want to take a look at that.
00:32:45.150 –> 00:32:53.010
Paul Carelis: So telephone is a tricky one, and I know we do have people on the call here who do have a presence or do you have employees in California so.
00:32:54.360 –> 00:33:00.300
Paul Carelis: The kind of traditional California cool basically is ending, as of today, September 30.
00:33:01.710 –> 00:33:08.850
Paul Carelis: But there are other things in place there, so they do have this California code exposure Lee so.
00:33:09.900 –> 00:33:13.140
Paul Carelis: If the employee can prove or probably more importantly, unless.
00:33:14.250 –> 00:33:24.960
Paul Carelis: has an employer, you can prove that an employee who contract Kovac got it outside of work, there is a covert exposure, we have available to them, that is continuing as of right now.
00:33:27.630 –> 00:33:33.240
Paul Carelis: New York co vertically there’s an interesting one, and I know we get people on the call here with a presence in New York, as well, so.
00:33:34.170 –> 00:33:45.150
Paul Carelis: Interestingly, the way New York drafted, they are co vertically, rather than having kind of a start and stop date was they really drafted and drafted the reasons around coven 19 so.
00:33:45.720 –> 00:33:55.020
Paul Carelis: If someone is under a coven 19 quarantine order or they test positive or otherwise have some covert related condition or need to miss work.
00:33:56.520 –> 00:34:06.930
Paul Carelis: The New York leave law is its kind of evergreen and that it doesn’t have an expiration date so as long as code is a factor and affecting your employees in New York and the second their ability to come into work.
00:34:08.550 –> 00:34:10.020
Paul Carelis: Within the limits of the Program.
00:34:11.040 –> 00:34:13.680
Paul Carelis: The New York coven we will will continue on.
00:34:17.250 –> 00:34:21.300
Paul Carelis: Here, where i’m sitting in Massachusetts just a couple of days ago.
00:34:24.690 –> 00:34:37.200
Paul Carelis: Massachusetts just extended their their covert typically for another six months so that was set to expire today, along with the Federal leave but Massachusetts did extend through April of 2022.
00:34:39.900 –> 00:34:46.380
Paul Carelis: As I, as I said, we’re going to do a really deep dive into the Massachusetts secrete next week on next week’s webinar it is something we’re.
00:34:46.770 –> 00:35:01.590
Paul Carelis: starting to get a lot of questions about and it’s important to understand a i’m like arpa nsf CRA or the latter portion portion of fs era, this is not an optional program from Massachusetts employers, they are mandated and required to make this leap available to workers.
00:35:03.150 –> 00:35:06.360
Paul Carelis: It is different from the Federal program and several key ways, there are.
00:35:07.560 –> 00:35:17.100
Paul Carelis: K okay when it’s it’s limited to 40 hours or a prorated amount of hours for part time workers basically a week of leaf, there are also.
00:35:17.760 –> 00:35:29.490
Paul Carelis: earnings limits on the lead as well, and then the mechanism for being reimbursed for messager co believe are quite different than than other places it doesn’t really an automatic tax credit.
00:35:31.170 –> 00:35:37.290
Paul Carelis: If it’s on on gross wages it doesn’t factor, an employer taxes or anything like that, like some of the cooler typically does.
00:35:38.610 –> 00:35:45.000
Paul Carelis: And also it’s a it’s a fairly manual process for claiming reimbursement employers have to go into mass text connect.
00:35:46.230 –> 00:35:57.600
Paul Carelis: log into their account going to the special section fill in the information regarding the employee and the amount paid and clean the reimbursement that way it’s really outside of payroll or a payroll tax function so.
00:35:59.250 –> 00:36:11.160
Paul Carelis: Both in response to and anticipating all the questions that are going to come in, and this is for Massachusetts employers really be the only avenue for employees to use covert time with those federal program expiring.
00:36:12.480 –> 00:36:18.600
Paul Carelis: There are a lot of questions and concerns and really important things to understand about this, so we will be covering that next week.
00:36:22.770 –> 00:36:24.870
Paul Carelis: So, in terms of an action plan.
00:36:28.290 –> 00:36:40.650
Paul Carelis: You want to double check all your work location so, for instance, while, while the California state level co vertically programs expiring, there are several cities, including Los Angeles, and others whose programs are continuing so.
00:36:42.120 –> 00:36:49.560
Paul Carelis: More than just knowing what state your employees are in your city there and as well, because there are several cities that do have a covert sickly designation.
00:36:50.910 –> 00:36:55.920
Paul Carelis: want to make sure that your federal leave is reported on your 941 so that you get reimbursed for those expenses.
00:36:58.620 –> 00:37:08.580
Paul Carelis: If you are in a situation where either the covertly that that you’ve been using has expired, or you have employees who have exhausted believe available to them.
00:37:09.120 –> 00:37:21.570
Paul Carelis: You really want to strategize and have a plan in place for what you’re going to do, should employees have a need to if they’ve been exposed if they test positive if they otherwise need to isolate a quarantine.
00:37:24.750 –> 00:37:31.440
Paul Carelis: what’s what’s the plan, going to be what what time off policies you have in place, you have traditional sickly the pto.
00:37:32.490 –> 00:37:39.570
Paul Carelis: Are you subject to have MLA with Emily apply you really kind of want to have a game plan and the strategy in place to make sure that.
00:37:40.950 –> 00:37:50.310
Paul Carelis: As the pop up, as unfortunately they’re very likely to end with that kind of federal safety net gone what options are there going to be for employees.
00:37:51.750 –> 00:38:01.020
Paul Carelis: Can kind of and once you do have that plan in place, it is really advisable to send a communication proactively to your employees, especially regarding the hand of the federal programs so.
00:38:01.890 –> 00:38:14.190
Paul Carelis: If you are in a state where there is no state level cool vertically program in place any longer, it would be advisable to notify your employees to know that the arpa cool but typically has ended.
00:38:15.630 –> 00:38:25.080
Paul Carelis: per per the federal law, not your choice as of September 30 and that and what what time off they may have available to you, should they need to see you some time.
00:38:27.750 –> 00:38:30.030
Paul Carelis: Okay, so before we move on i’ll.
00:38:31.080 –> 00:38:32.370
Paul Carelis: Look at some of the more.
00:38:33.960 –> 00:38:36.300
Paul Carelis: Recent questions as they pertain to some of this stuff.
00:38:47.790 –> 00:38:59.700
Paul Carelis: Okay, so question about full time versus part time when it comes to the Massachusetts sickly as far as I know, unless the extension change something and again that’s just passed yesterday so we’ll double check but.
00:39:00.780 –> 00:39:11.820
Paul Carelis: The the provisions and my original coven sick plan called for all employees to be eligible, they just get a prorated amount they wouldn’t get a full 40 hours if that if that wasn’t their common weekly schedule.
00:39:19.500 –> 00:39:34.920
Paul Carelis: Necessary Massachusetts has not mandated a specific number of hours for vaccination time it is one of the allowable purposes of the coven sickly which provides up to 40 hours, obviously, hopefully, someone wouldn’t need that much time unless they had some severe reaction to the vaccine.
00:39:40.890 –> 00:39:45.750
Paul Carelis: chatter we get reimbursed for sickly from SF era, so that would be claimed.
00:39:47.100 –> 00:39:53.010
Paul Carelis: The 941 or if it pertains to a previous period and amended 941 so.
00:39:54.030 –> 00:40:06.150
Paul Carelis: If you’re if you are a empty client and use the iPhone system, you want to speak with your account coordinator and account manager, we have a a business credit screen, where we could enter in those figures.
00:40:07.470 –> 00:40:10.890
Paul Carelis: If they haven’t been entered through those and the normal methods.
00:40:11.970 –> 00:40:16.140
Paul Carelis: Most providers, including high salt, if you are tracking things.
00:40:17.400 –> 00:40:31.620
Paul Carelis: In the correct field and correct code those credits should should populate correctly based on on the taxation on the field comparable we just want to double check with your payroll provider to make sure that they are being credited for those figures and getting the tax benefits.
00:40:35.100 –> 00:40:40.140
Paul Carelis: Have you sent out the registration for next week’s training, based on the message, she says code sickly know so.
00:40:40.710 –> 00:40:49.980
Paul Carelis: We were originally scheduled to have a webinar on on marijuana and marijuana in the workplace and changing laws we are postponing that there are.
00:40:50.730 –> 00:41:01.050
Paul Carelis: A lot of balls up in the year when it comes to the marijuana laws, those are moving more slowly than than we anticipated, especially at the federal level where there are there’s so much infighting over the.
00:41:02.670 –> 00:41:08.880
Paul Carelis: Reconciliation bill and the infrastructure bill and all the various and the debt ceiling and all that fun stuff it’s.
00:41:10.050 –> 00:41:16.860
Paul Carelis: There hasn’t been as much progress as we anticipated a couple months ago that there would be on marijuana so or postponing the marijuana session.
00:41:17.610 –> 00:41:30.960
Paul Carelis: But I believe, by the end of the day, the registration for the Massachusetts coven sickly should be up on our website and be going out to people on our list so either late today or tomorrow, you should see an invite for that or a registration opportunity.
00:41:36.630 –> 00:41:50.280
Paul Carelis: Okay, so some requests for information about the California exposure and the New York week, so I will gather some some information about that and will will pass that along to you guys, along with the recording of today’s session.
00:41:58.500 –> 00:42:01.170
Paul Carelis: So, and in terms of Center some resources.
00:42:04.920 –> 00:42:12.300
Paul Carelis: At amp T we have developed a vaccine mandate checklist kind of for the three different scenarios and considerations and strategy points.
00:42:13.140 –> 00:42:25.350
Paul Carelis: will be sending that out to to everybody, again, if I can stress nothing more than please know that that is a living breathing document Center to change, especially you know it’s.
00:42:26.760 –> 00:42:34.560
Paul Carelis: You know right on right on the details are big on the speculation, when it comes to the private sector and the medicare medicaid categories.
00:42:35.220 –> 00:42:42.750
Paul Carelis: We are updating it so it might not come out with the recording we’re doing some updates dates on the federal guidance federal contractor titles just released.
00:42:44.370 –> 00:42:49.830
Paul Carelis: But we are making that resource available and then constantly updating it with the latest and greatest news.
00:42:51.180 –> 00:42:59.160
Paul Carelis: You do want to make sure you get your hands on all the coupons related Coco performs again if unless you’re using a Cobra administration that’s taken care of it for you.
00:42:59.550 –> 00:43:07.080
Paul Carelis: do make sure, especially you get out that exploration of the subsidy notice that anybody on Cobra currently in receiving the subsidy.
00:43:08.520 –> 00:43:19.740
Paul Carelis: And, as we said before you do want to keep people abreast of notifications when it comes to code leave that may be available to them, depending on their State there may be requirements for you to notify employees of.
00:43:20.490 –> 00:43:28.290
Paul Carelis: Of the Cobra the that’s available to them, so again double check double check your state and if you’re if you’re working with us in HR capacity check with your HR partner.
00:43:28.860 –> 00:43:36.420
Paul Carelis: or otherwise check with HR legal counsel in terms of your requirements in your states for notifications or covertly or perfectly.
00:43:41.340 –> 00:43:50.370
Paul Carelis: Okay, then I quickly wanted to do just an er T cfd we’re doing a ton of work with employee retention tax credits it’s been really great.
00:43:52.050 –> 00:43:57.390
Paul Carelis: For those of you who who haven’t been keeping up to date with it the Program.
00:43:58.560 –> 00:44:03.240
Paul Carelis: Was through are assigned to run through all four quarters of this year.
00:44:04.920 –> 00:44:10.260
Paul Carelis: But within the infrastructure bill that that’s currently being debated and coming close the passage.
00:44:11.280 –> 00:44:23.610
Paul Carelis: The most recent version of the infrastructure bill did cancel out quarter for of the employer attention tax credit so should the infrastructure bill passed on changed, and nothing else path to.
00:44:24.660 –> 00:44:25.440
Paul Carelis: override it.
00:44:26.490 –> 00:44:44.850
Paul Carelis: The rotc program would still be in place in terms of making claims, so there will be a three year window to claim credits for 2020 as well as first three quarters of 2021 it’s just that wages paid and quarter for would not be eligible for employee retention tax credits.
00:44:46.770 –> 00:44:52.890
Paul Carelis: it’s a real shame because For those of you who are familiar with attended previous educational session on er TC.
00:44:53.790 –> 00:45:05.430
Paul Carelis: There are kind of two pathways to eligibility one being a severe decline of gross receipts and the other being code related restrictions on a business that suspended their operations in some way.
00:45:06.150 –> 00:45:14.520
Paul Carelis: So while most businesses restrictions or at least those related to code or sufficient enough to qualify for etc have been lifted and most date.
00:45:16.650 –> 00:45:23.370
Paul Carelis: That would mean that companies that would continue to be eligible for er Casey otherwise in quarter for would be those businesses.
00:45:24.090 –> 00:45:32.640
Paul Carelis: who’s revenue still haven’t recovered to at least 80% of what they were at the end of 2019 before the pandemic started so really.
00:45:33.060 –> 00:45:38.550
Paul Carelis: The company that would be eligible for quarter for you actually see would theoretically be the company that really need it so.
00:45:39.060 –> 00:45:47.880
Paul Carelis: There is hope and there’s a lot of arguing and petitioning going on at Congress believe a coalition of over 20 groups that represent smaller businesses.
00:45:48.510 –> 00:45:57.420
Paul Carelis: Have petition Congress to include language that would reinstate quarter for the rtc within the reconciliation bill that’s also being debated in Congress so.
00:45:59.550 –> 00:46:05.670
Paul Carelis: not dead, yet not looking great, but there are efforts to revive the rtc in order for but.
00:46:07.020 –> 00:46:18.300
Paul Carelis: If I was guessing me and i’d say probably won’t won’t be but we don’t know and unfortunately it looks like we’re going to start quarter, for without knowing the fate of quarter for the rtc just yet.
00:46:20.010 –> 00:46:27.720
Paul Carelis: And then, lastly, for those of you who have taken advantage of vr ky C and are on are awaiting payment from the irs.
00:46:29.160 –> 00:46:36.720
Paul Carelis: Unfortunately, the irs has continued to experience pretty severe delays when it comes to turning those around and processing those and issuing checks to to businesses.
00:46:37.170 –> 00:46:47.460
Paul Carelis: Especially for those who have who had to file be amended returns we’re seeing way to have anywhere from from four to seven months on on turnaround on those checks, but.
00:46:48.570 –> 00:46:57.480
Paul Carelis: irs is working on it, they do have additional offices now processing etc returns, they are making updates to their software, they are kind of caught flat footed when it came to.
00:46:58.200 –> 00:47:08.550
Paul Carelis: came to the program and and how to process these so they are working on it, we are seeing credit start to start to be issued, but it is largely a waiting game, unfortunately.
00:47:15.180 –> 00:47:23.280
Paul Carelis: For those of you, we go to the next slide For those of you who haven’t yet explored, etc, for your organization.
00:47:24.750 –> 00:47:35.490
Paul Carelis: and would like to we do have some decision trees available, so if you’re unsure about whether or not you may qualify for employee retention tax credits.
00:47:36.210 –> 00:47:46.770
Paul Carelis: either in 2020 or 2021 we do have some decision tree that we’d be happy to share with you that kind of walk you through the process at a very high level now, certainly if if ultimately.
00:47:47.550 –> 00:48:02.580
Paul Carelis: you end up in one of these green eligible spots, you know, there are other variables, we do have certified professionals here that’d be happy to talk about these things and really help solidify your eligibility, but can give you a pretty good idea if it’s something worth pursuing or not.
00:48:05.490 –> 00:48:11.250
Paul Carelis: And for those who are interested, whether you are an empty clean or not we do offer employee retention tax credit services.
00:48:11.700 –> 00:48:20.700
Paul Carelis: Where we can work either with with your isola payroll data or other payroll providers data to help determine calculate and file for your employee retention tax credits.
00:48:21.390 –> 00:48:27.900
Paul Carelis: So that is something where we’re doing a lot of where we’re very proud of our work here to date we’ve helped you know.
00:48:28.830 –> 00:48:41.820
Paul Carelis: Several businesses with their employee retention retention tax credits and collectively we’ve helped those senses realize over $20 million in any rtc money coming their way so very proud and very rewarding work for us.
00:48:45.960 –> 00:48:53.160
Paul Carelis: Okay, yes, the presentation will be sent to participants will send a recording of today’s presentation.
00:48:57.180 –> 00:49:08.880
Paul Carelis: per State specific mandate, because it for all employers it’s somewhat of a federal guideline hundred or more or 500 or more really depends on the State, so the state has the discretion in terms of designing their.
00:49:10.260 –> 00:49:17.490
Paul Carelis: Corporate mandate or they’re cool but sickly requirements they set the threshold for what size businesses, these things are subject to.
00:49:26.190 –> 00:49:34.680
Paul Carelis: we’ve got some questions specific to Illinois i’ll have to research that to make sure that I answer those accurately I don’t want to get there.
00:49:36.870 –> 00:49:43.860
Paul Carelis: And do non met great question do non medical staff need to be vaccinated in a home care agency setting that is medicare medicaid certified.
00:49:46.500 –> 00:49:52.020
Paul Carelis: Presumably, if they’re working within the facility, but but to be completely honest that’s just a guess.
00:49:52.860 –> 00:50:06.120
Paul Carelis: We are awaiting the formal guidelines and rules on the medicare medicaid certified employer vaccine mandate, but if I was to be a guessing man or a betting man I would bet that at the very least.
00:50:07.320 –> 00:50:15.600
Paul Carelis: folks working within that facility would need to be vaccinated and there is a chance, where this is how it went for federal contractors that even those who.
00:50:16.200 –> 00:50:23.700
Paul Carelis: Do billing or other non medical work remotely may need to be vaccinated as well, so we don’t know yet, but that eventually side on the.
00:50:24.840 –> 00:50:25.620
Paul Carelis: likelihood of yes.
00:50:28.830 –> 00:50:35.910
Paul Carelis: For the vaccine mandate how about employers that have a mix of true employees and 1099 contractors.
00:50:36.930 –> 00:50:51.150
Paul Carelis: That will be discussed in and the regulations as well, all I can say is that it might create more scrutiny for businesses that you independent contractors and whether or not those workers are truly independent contractors, or should be considered employees.
00:50:52.620 –> 00:50:58.260
Paul Carelis: remains to be seen how how the rules will go in terms of counting contractor that’s employees, sometimes.
00:50:59.040 –> 00:51:04.680
Paul Carelis: Like when it comes to here in Massachusetts the paid family medical kind of disability coverage.
00:51:05.100 –> 00:51:16.380
Paul Carelis: It all hinges on what percentage of contractors, you have as part of your total workforce if it’s more than half or not because there might be something similar to that, but, but we do not know the answer to that question just yet, unfortunately.
00:51:23.070 –> 00:51:29.850
Paul Carelis: A local health plan that contracts with cms delivering medicare to Santa Clara county and not considered a government contractor.
00:51:30.450 –> 00:51:36.600
Paul Carelis: If you are medicare or medicaid certified so basically if you collect payments for medicare and medicaid.
00:51:37.500 –> 00:51:51.120
Paul Carelis: You you don’t fall under the contract category, but as a separate executive order for a vaccine mandate for medicare and medicaid certified companies, regardless of federal contractor status but, again, it looks for that had not yet been published.
00:51:59.400 –> 00:52:07.800
Paul Carelis: we’re mapping and social distancing requirements in addition to be subject for federal contractors with those also apply to the medicare medicaid.
00:52:08.880 –> 00:52:14.490
Paul Carelis: Businesses again we don’t know yet those rules have yet to be published I would assume yeah.
00:52:23.160 –> 00:52:23.550
00:52:26.610 –> 00:52:30.810
Paul Carelis: Do you think the federal contract and mandate will begin before the private employer mandate.
00:52:31.440 –> 00:52:47.460
Paul Carelis: I would say yes, so as of right now the federal contractor mandate is is going to start in earnest on December 8 so employees or federal contractors will need to be fully vaccinated and then really be that two weeks vaccinated from their final dose as of December 8.
00:52:49.740 –> 00:52:55.650
Paul Carelis: Real realistically, given the burden, frankly, that this is going to be on on private sector employers.
00:52:56.280 –> 00:53:04.080
Paul Carelis: I would think that they’ll give them some time most you know if we look at private employers as a as a benchmark or a measuring stick and i’m not sure.
00:53:04.980 –> 00:53:16.560
Paul Carelis: What are who they consulted as part of their planning most private employer vaccine mandates that have been put in place so far have given their employees 60 days and a lot of cases to be in compliance.
00:53:17.880 –> 00:53:18.300
Paul Carelis: So.
00:53:20.550 –> 00:53:23.730
Paul Carelis: And, given the speed of rulemaking at the federal level sometimes.
00:53:25.530 –> 00:53:28.980
Paul Carelis: I would guess that the rules will probably be published sometime in October.
00:53:30.360 –> 00:53:38.250
Paul Carelis: I was like you know guess what they’ll be at least 60 days for for businesses and their employees to become compliant with that so.
00:53:38.910 –> 00:53:52.140
Paul Carelis: It might not be long after that December a timetable for federal contractors, but I eventually gave me that will be, it will be sometime after that might be a January 1 but, again, we don’t know just yet.
00:53:55.620 –> 00:54:02.130
Paul Carelis: Right, so it looks like those are the questions, or at least the questions that we can answer on today’s session.
00:54:02.970 –> 00:54:09.480
Paul Carelis: I think these are really good questions, I know there were some that require some additional substantiation So in addition to the recording.
00:54:10.140 –> 00:54:18.480
Paul Carelis: We will be sure to get those groceries horses too early for California, as well as New York over to all of you, but again, thank you so much.
00:54:18.960 –> 00:54:26.160
Paul Carelis: It wouldn’t be the same presentation without these questions, so this is what makes it exciting and fun for me hope that you earned earned a bit or learned a lot.
00:54:27.060 –> 00:54:38.760
Paul Carelis: If we can be a further as hootsuite any of this stuff please do reach out to us at amp D dash hr.com we’ve got a team of certified HR professionals ready to help out but with that I will hand things back over to amy.
00:54:39.840 –> 00:54:45.510
MP: Thank you, Paul really, really, really great relevant program today, and thank you all for asking such.
00:54:45.720 –> 00:54:53.490
MP: insightful questions as Tom mentioned, we will be sending out the link to the webinar will send out all the resources, along with paul’s.
00:54:53.820 –> 00:55:00.810
MP: slide deck today and also be sure to join us next Thursday same time same place for mass employer co basically.
00:55:01.290 –> 00:55:16.320
MP: program updates pretty critical guidance for compliance and preparation for the legislative updates so again, that will be up on our site, by the end of the day and we’ll be sending out marketing, so please register have a great day, everyone and see you next week.
Paul Carelis, SHRM-CP, PHR
VP of Client & HR Services, MP
To avoid costly lawsuits and fines, employers must stay abreast of the latest HR compliance updates on government pandemic programs. Several government programs and restrictions may sunset this fall, and HR and compliance requirements will change dramatically.
Register for the webinar to:
- Get the latest information on the vaccine mandate for employers
- Find out which programs are ending (and when), including COVID sick leave, the COBRA subsidy of 2021, and unemployment premiums
- Discover which programs may be extended and what new HR compliance regulations are pending for the rest of 2021
- Learn key employer requirements and best practices for labor poster compliance and notifications
- Uncover critical strategies for HR compliance in a pandemic workplace