At Concordia Plan Services we care deeply for the well-being of the ministries and members we serve. This is true at all times, but our concern is especially heightened as we work to understand the impact of COVID-19. Please use the following resources to answer some of your questions about the impact of COVID-19. God bless you and your ministry during this challenging time.
Guidance for Federal Contractors
1/20/22 update: This mandate for federal contractors is currently put on hold per the court and is not being enforced until further action by the court.
This mandate requires all federal contractors (entities that receive certain federal funds) to require vaccines for all employees no later than January 4, 2022.
Employers subject to the mandate are those that have any new, renewal or extension of a federal contract in excess of $250,000 for services. Potential funds that could make this mandate applicable to an organization include ROTC funding, research funded through federal dollars and federal student aid funds (although it is not clear if federal student aid would be sufficient to trigger this requirement on its own).
There are three main components to this mandate to consider.
- All covered contractor employees must be fully vaccinated by January 18, 2022, meaning the employees must have their second dose of the Pfizer or Moderna vaccine or single dose of the Johnson and Johnson vaccine by January 4, 2022. Specific accommodations should be made on an individual basis for disability, medical or religious reasons under existing federal and state laws.
- The employer must enforce masking and physical distancing at covered contractor workplaces for employees and visitors.
- Each contractor or subcontractor must designate someone to coordinate workplace COVID safety.
Contact your legal counsel for specific guidance on the applicability of this mandate to your organization. For more information see this article from the Society of Human Resources Management as well as additional information from the American Council on Education on the applicability of the mandate to colleges and universities. The federal government’s official Guidance for Federal Contractors and Subcontractors can be found here.
OSHA Requirement for Large Employers
1/13/22 update: On Jan. 13, the Supreme Court granted an injunction against the Biden Administration's mandate that requires employers with 100 or more workers to either create a policy mandating vaccines for all employees or create a policy offering employees the option of vaccination or testing and masking. The court indicated those trying to stop this mandate, which has commonly been referred to as the OSHA mandate, are likely to succeed. There is currently no requirement for a vaccination or testing and masking policy for these employers.
- OSHA Mandatory Vaccination Sample Policy Template
- OSHA Vaccination or Testing and Face Covering Sample Policy Template
The Occupational Safety and Health Administration (OSHA) mandate requires employers with 100 or more employees to create a policy requiring full vaccination of all employees or weekly testing and mask wearing.
Part-time and remote workers are included in the count of 100 workers, but those who work exclusively at home or outdoors do not. The employee count also does not include independent contractors or temporary workers employed through a staffing agency.
For more information see our Vaccine Mandate Q&A document or contact your legal counsel for specific guidance on the applicability of this mandate to your organization. This article from law firm K&L Gates is an additional resource on the topic.
Paycheck Protection Program Guide: In March 2020, Congress passed the Coronavirus Aid, Relief and Economic Security Act (CARES Act) which added a temporary program called the Paycheck Protection Program (PPP) to the loan programs administered by the Small Business Administration (SBA). PPP loans were created to provide economic relief to small businesses nationwide that were adversely impacted by COVID-19 and are available to religious organizations. PPP loans were originally only available from February 15, 2020 through June 30, 2020, but the Paycheck Protection Program Flexibility Act, passed in June 2020, extended the deadline to December 31, 2020.
Forgiveness Application Form 3508S for loans $50,000 and under
IRS Updates Guidance on Reporting for Paid Family, Sick Leave
The Internal Revenue Service guidance (Notice 2021-53) builds on a directive released in July 2020 on how employers should comply with requirements for reporting on W-2 forms or separate statements the amount of sick leave and family leave wages paid to individuals under the Families First Coronavirus Response Act. Under the updated guidance, employers are required to report qualified leave wages either on a 2021 Form W-2, Box 14, or on a separate statement. The guidance also provides information for self-employed individuals to claim qualified sick leave equivalent or qualified family leave equivalent credits for the 2021 taxable year.
ARPA Q&A Document: On March 11, President Biden signed the American Rescue Plan Act of 2021. This bill is the latest COVID-19 stimulus legislation and includes changes to the Families First Coronavirus Response Act. ARPA continues the tax credit for employers who voluntarily provide paid sick leave and family medical leave, and were subject to the FFCRA, through September 30, 2021. ARPA also expands the reasons for qualifying leave and provides new allotments of paid time that can qualify for tax credits.
- Paycheck Protection Program loans: Organizations that received a PPP loan in 2020 are, in some cases, eligible to apply for and receive a second loan. See the Q&A document for more information, including the additional types of expenses that loan proceeds can be used to cover.
- A resource document detailing additional provisions of the act, including those related to pandemic unemployment assistance, recovery rebates for individuals and tax credits for paid sick and family leave. The document includes links to the original information on these topics from the CARES Act and Families First Coronavirus Response Act.
- FSA flexibility through the Consolidated Appropriations Act: The December 2020 appropriations act has provisions that provide temporary relief for health and dependent care flexible spending arrangements (FSAs). This relief is especially impactful as many workers were not able to use all of their FSA funds in 2020 and are at risk of losing those funds. See the document to learn about the relief options available to employers.
- Employee Retention Tax Credits: Employers that received a Paycheck Protection Program (PPP) loan in 2020 were previously barred from taking advantage of the Employee Retention Tax Credit (ERTC), a refundable credit against applicable employment taxes for qualified wages paid. The Consolidated Appropriations Act, passed at the end of 2020, changed this rule, and now employers can retroactively claim the ERTC for 2020 even if they received a PPP Loan, subject to some limitations. The act also extended the ERTC through June 30, 2021 and changed how the credit will work for 2021. See the document for more details.
- Signed into law 3/27/20
Who it applies to
- Small business loans as described in act available to employers with fewer than 500 workers.
CARES Act Topics
- Main Street Lending Program
- The Federal Reserve Board recently announced the availability of new loans for tax-exempt organizations through their Main Street Lending Program. These loans are separate and different from the Paycheck Protection
Program loans that were made available earlier this year.
There are several requirements for an organization to be eligible, including that it employs at least 10 employees and that non-donation revenues are equal to or greater than 60% of expenses for the period from 2017 through 2019. This requirement may make it challenging for churches to qualify. Loans through this program are not forgivable. For more information, click here.
- The Federal Reserve Board recently announced the availability of new loans for tax-exempt organizations through their Main Street Lending Program. These loans are separate and different from the Paycheck Protection Program loans that were made available earlier this year.
- Economic Stabilization Loans (for ministries with 500+ employees)
- Pandemic Unemployment Assistance Program (expands unemployment eligibility)
- Charitable Contributions Incentives
- Recovery Rebates for Individuals
- Student Loan Relief
- Retirement Plan Changes (403(b) distributions)
The CARES Act provides opportunities to access funds from your 403(b) account or other retirement savings accounts if you have suffered serious financial harm due to the economic effects of COVID-19.
If you are experiencing financial stress, this may seem like a quick fix. But before making any decisions to tap into your 403(b) savings, it is important to understand the consequences of a distribution and consider alternatives. To help you make an informed decision, click here to view important considerations before you make a withdrawal from your CRSP account or other retirement savings accounts.
To learn more watch the webinar on the CRSP and CARES Act or contact one of our financial wellness educators:
- Health Plan Changes (COVID-19 coverage)
- HHS and Dept. of Education Funding (available to non-public schools)
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