COVID-19 Employer Playbook

Charges for COVID-19 Testing A cap was placed on the amount that group health plans are required to reimburse providers for the testing costs. The cap equals the negotiated rate before the public health emergency was declared, or at the amount posted by the provider on its website if no such negotiated rate exists with the provider. In addition, all providers of COVID-19 testing must post the cash price for testing of the public on their website.

Paycheck Protection Program

Overview The Paycheck Protection Program (the PPP) was established under the CARES Act in order to provide small employers with an incentive to keep workers on their payroll during the COVID-19 crisis. Initial legislation provided a $350 billion allocation for loans, and later legislation provided significant additional funding. The program was further amended by the Paycheck Protection Program Flexibility Act (PPPFA) to provide additional flexibility for employers. Under the PPP, which is an extension of the SBA Section 7(a) loan program, qualifying small businesses are eligible to borrow up to $10 million, in order to maintain their workforce from February 15, 2020, until June 30, 2020. The Paycheck Protection Program Flexibility Act extended this through December 31, 2020. All or a portion of the loan may be forgiven if the borrower follows the SBA guidelines. Eligibility The general criteria require that the business must have 500 or fewer employees (full-time, part-time, or other basis) in order to qualify for a loan. Accommodation and food service businesses that have 500 or fewer employees for each business location are eligible for a loan. In order to qualify, the business must have been in operation on or before February 15, 2020 and must have paid salaries and payroll taxes or paid independent contractors as documented by the issuance of Forms 1099. The guidance indicates that an individual with self-employment income is eligible to apply. The window for initial applications opened on April 3, 2020 with an application submission deadline of June 30, 2020. The deadline was extended to December 31, 2020 under the PPPFA. Loan Amount Eligible employers may borrow an amount equal to the employer’s average monthly payroll cost multiplied by 2.5. The average monthly payroll is determined based upon the costs incurred during the one-year period prior to the date the loan was made. For example, an employer whose average monthly payroll for the preceding 12-month period was $100,000 would multiply that average by 2.5 for a total maximum loan amount of $250,000.


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