Employment considerations for employers making difficult decisions during this global health crisis.
Presbyterian Church (U.S.A.) congregations, employers, and affiliated organizations are making difficult decisions about staffing, including layoffs, reduction in hours, and furloughs.
When making these difficult decisions, keep in mind that the Board of Pensions has suspended the required 20-hour rule. Therefore, if you have an employee with benefits coverage working more than 20 hours, and you reduce those hours to less than 20, the employee can maintain benefits, provided the dues remain paid. However, the employer may not be eligible for federal Paycheck Protection Program (PPP) loan forgiveness, which requires that employers continue to pay at least 75 percent of salary.
With a furlough, you can reduce hours to zero and still maintain the active status of an employee for benefits purposes without the need to continue pay, provided the dues are paid on the position.
And finally, once a layoff or termination decision is made, the employee no longer remains eligible for benefits through the Board.
Understanding terms is the first step in understanding your options.
It's important to note that in the case of a layoff, employers are not eligible for any of the federal programs: Paycheck Protection Program (PPP loan), paid leave tax credit, or employee retention credits. In some cases, when an employer decides to furlough employees, if it meets certain criteria, it may be eligible for some federal programs.
This chart outlines the effect of a reduction in hours or a furlough on a member's benefits through the Board of Pensions.
|Benefits impact||Reduction in work hours or furlough without pay|
|Cafeteria plan (section 125 plan)||A reduction in work hours or a furlough that affects eligibility for coverage would qualify as a midyear event that would allow for changes in salary deductions and/or employee contributions.|
|Benefits coverage continuation||The Benefits Plan requirement to be regularly scheduled to work for 20 hours per week is suspended until further notice for those who were previously covered.|
|Employee contributions for benefits coverage||The employer may pay 100 percent of dues/premiums in situations of reduced hours or furlough. Or, the employer may reduce or elect to waive employee dues contribution (or premium) or defer payment of the employee portion for healthcare coverage for the duration of the furlough. The employer is required to pay the Board the full dues amount unless the employer has received a waiver or deferment.|
|Health savings account, healthcare flexible spending account||Reduction in work hours is a qualifying event for midyear changes in salary deductions.|
|Dependent care flexible spending account||Closures of school and daycare are qualifying events for midyear changes in salary deductions.|