In response to COVID-19, VFS has provided several communications to our members/participants regarding changes or new requirements. All communications will be posted here:
Updated 4/20/2020
VFS has created an Election Form and Instructions:
Click here to view the Families First Coronavirus Response Act Paid Leave Election Form Instructions.
Updated 4/13/2020
The President recently signed into law The Families First Coronavirus Response Act (FFCRA). This act gives protection to employees who may be impacted by COVID-19 and are unable to work. We wanted to provide some information about the act and the impact it has on self-directing employers.
Why is VFS sharing this information about the FFCRA?
As an employer with fewer than 500 employees, employers are required to comply with this law. There may be exemptions employers could apply for if you wish not to comply with the law. We would recommend seeking outside legal counsel to document those exemptions.
What do employers need to do to comply with the law?
Minimally employers are required to post or provide the poster to their employees explaining their rights under this law. This poster outlines the types of employee payments provided under the FFCRA and the qualification requirements. Here is a link to the poster on the Department of Labor website for quick reference (you must copy and paste the link to your browser) https://www.dol.gov/sites/dolgov/files/WHD/posters/FFCRA_Poster_WH1422_Non-Federal.pdf
Where can employees get the employee paid leave election form?
VFS is in the process of creating the form and the instructions. Employers will receive an email from VFS with the form and instructions in the coming weeks. The form will also be posted on the VFS website. Please do not contact VFS about this form until it is posted to the VFS website. Thanks in advance for your patience.
What is the effective date under the FFCRA if an employee qualifies?
The FFCRA effective date is April 1st if the employee qualifies for the leave.
It is after April 1st, why is VFS just communicating this now?
Even though the effective date is April 1st, the Department of Labor and the IRS just issued the guidance on this law. There is a non-enforcement period so organizations can prepare to implement the law. VFS is reviewing the guidance and laws and is in the process of creating forms and internal processes for these payments. Once we have these in place we will communicate them. Thank you for your patience.
Is there anything employers need to do to get the tax credit so employees can get paid?
Once VFS releases the employee paid leave election form, the employer and employee must complete the form. This form can be rather complex and will require an attention to detail to submit the form correctly and to comply with the regulations. Once the form is received by VFS correctly and all supporting documents are received, then VFS will apply for the tax credit on your behalf and will pay the funds to the employee.
How long will it take for employees to receive payment?
Employees can anticipate approximately a 30-45 day processing time for all payments from the date VFS receives a properly completed paid leave election form including all supporting documentation.
Where can employers and employees learn more about the FFCRA?
There are a number of helpful websites with information about the FFCRA as well as the IRS guidance on the tax credit. Here are just a few for quick reference:
Department of Labor Summary of the FFCRA: https://www.dol.gov/agencies/whd/pandemic/ffcra-employer-paid-leave
Department of Labor Q&A: https://www.dol.gov/agencies/whd/pandemic/ffcra-questions
IRS: https://www.irs.gov/newsroom/covid-19-related-tax-credits-for-required-paid-leave-provided-by-small-and-midsize-businesses-faqs
Will this impact CCO program funds?
These payments will not impact program funds and will not be paid out of the program allocations. The law allows for a 100% refund of these payments through a tax credit and are in addition to your program funds/authorizations. Employees can only receive the FFCRA payments if they are unable to provide service to you due to the COVID-19 requirements listed on the poster.
IOWA CCO members only: Please do not add these payments to member budgets.
We know there is a lot of information contained in the links above and the FFCRA requirements can be complicated. We are working diligently to provide our Employers/members/participants with the necessary forms and instructions so employees can apply for these payments if needed. Please let us know if you have any questions. Please stay safe and take care of yourself during this COVID-19 pandemic. Thank you.
