COVID-19 Employer Playbook

Notification and Communication 5. Sick Time and Paid Family Leave Notice What

Distribute notice of paid sick time and paid family leave to workforce.

The FFCRA requires that employers provide notice to employees.

Why

Immediately. While the law doesn’t specify a deadline, employees have heard about these leaves and want to know their rights. The effective date of the law is April 1, 2020.

When

The DOL has created a model notice for distribution.

Notes

6. Courtesy Plan Change Notice What

Distribute a courtesy communication advising employees of plan changes to health plans, pre-tax plans, and retirement plans. • Free COVID-19 testing • Free COVID-19 treatment* • OTC drugs eligible under pre-tax account plans without prescription • Menstrual products eligible under pre-tax accounts • HDHP telehealth services* • Waive 10% early withdrawal penalty* • Increase maximum loan amount* • Required Minimum Distribution removed for 2020

*If adopted

Formal participant notification via a Summary of Material Modification will be necessary for all of these changes. The deadline for distribution of an SMM is 60 days and the deadline for modifying retirement plans is 2022. Notification to participants by these deadlines is not very helpful. Therefore, we are recommending a “Courtesy Plan Change Notice” to communicate key plan enhancements to participants. Vita has created a template consolidated Courtesy Plan Change Notice that incorporates notification for health plan, pre-tax plan, and retirement plan changes.

Why

ASAP. Vita has provided a template Courtesy Plan Enhancement Notice .

When

This notification does not replace the SMM. Rather, it is intended to provide important information about plan enhancements in a timely manner.

Notes

7

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