Category: Coronavirus

Withum COVID-19 Bill Update – 9/17/2020

PPP Loans – Disallowance of Expense Deductions: Withum is getting a lot of questions regarding the denial of tax deductions relating to PPP loan forgiveness. As you may recall, cancellation of debt relating to the PPP loan is not taxable income. While that is the case for the loan itself, the amount forgiven actually ends up being fully taxable because the IRS issued Notice 2020-32 to disallow the tax deductions (expenses) that gave rise to the loan forgiveness. Here is a link to a Withum article on the Taxation of PPP Loans and Loan Forgiveness. Thus, taxpayers should expect more taxable income as they will have less deductible expenses in 2020 than are reflected on their internal books and records.

This also has caused some fiscal year-end borrowers to consider whether they can choose which deductions to disallow so they can defer the taxation of the loan forgiveness amount until a later tax year. 

Consider this example: a borrower obtained a PPP loan 8 weeks before the end of its 2020 FYE. If it obtains loan forgiveness based on the first 8 weeks of covered expenses, then those expenses would be disallowed and the loan forgiveness amount would be taxable in 2020. If, however, the borrower can disregard the first 8 weeks of expenses and rely only on the last 16 weeks of covered expenses paid or incurred during the covered period, then it could defer the expense disallowance, and therefore the taxation of the loan forgiveness amount until 2021. There is no guidance on this issue from the IRS or from the SBA, and while there are reasonable arguments to be made both ways, we cannot recommend borrowers take this position because eligibility for loan forgiveness is based on “the sum of” the covered expenses paid and incurred during the covered period, according to section 1106(b) of the CARES Act.

Could Deductibility of PPP Expenses Change?  Many have speculated that denying tax deductions for PPP loan recipients was not the intent of the program.  Several members of Congress have indicated that they intend to pursue legislation that would allow for all PPP related expenses to be deductible in order to avoid having small businesses deal with an unexpected tax bill after such a difficult year.  Even though at least one bill to restore the deductions has been proposed, at this point no agreement has been reached, so taxpayers need to proceed assuming that no change is coming.  That said, it is possible that we could see this addressed in an upcoming stimulus bill ….stay tuned.

Reminder Section:  (what should I be doing):

  • Talk to your lender to find out when its PPP loan forgiveness application portal will be ready.
  • Talk to your payroll company about claiming the employer payroll tax deferral and employee retention credits (ERC) that were made available in the CARES Act.
  • Talk to your payroll company about claiming the qualified sick/family leave refundable tax credits (from FFCRA, passed prior to the CARES Act).

Treasury Department Issues Guidance on Payroll Tax Deferral

By: Jim Paretti, Michael J. Lotito, and William Hays Weissman
August 31, 2020

On August 28, 2020, the U.S. Department of the Treasury issued guidance for employers with respect to the deferral of the employee portion of certain payroll taxes.  This guidance stems from a presidential memorandum issued earlier in the month authorizing employers to defer payment of these taxes.  That memorandum allowed for the deferral of the employee portion of federal payroll taxes (6.2% for Social Security and 1.45% for Medicare) from September 1, 2020 until December 31, 2020.  The memorandum allows employers to defer payment of the employee portion of these payroll taxes for workers earning less than $4,000 on a biweekly basis (roughly $104,000 annually). 

Treasury’s guidance makes clear that an employer may elect to defer the payment of the employee portion of these taxes on “applicable wages” until next year, when they would be owed in installments between January 1, 2021 and April 30, 2021.  “Applicable wages” are defined as those wages paid to an employee on pay dates between September 1, 2020 and December 31, 2020, “but only if the amount of such wages or compensation paid for a bi-weekly pay period is less than the threshold amount of $4,000 or the equivalent threshold amount with respect to other pay periods.”  The guidance specifies that applicable wages are determined on a pay period by pay period basis.  Finally, the guidance makes clear that employers are required to pay these taxes to the federal government, but goes on to state that employers “may make arrangements to otherwise collect the [due taxes] from the employee.”

The guidance leaves several clear takeaways.  First, it is clear that an employer is permitted to defer payment of these taxes, but is not required to.  Second, it is likewise clear that unless further action is taken (likely by Congress), these taxes are merely deferred, not forgiven, and will be due by the end of April 2021.  Finally, it is not clear what, if any, role an individual employee plays with respect to determining whether they want their share of these taxes deferred, or paid in the normal course.  Employers will want to keep each of these points in mind as they evaluate whether or not to participate in this elective deferral.

It is unclear whether Treasury will issue additional guidance regarding this program.  Littler WPI will keep you apprised of relevant developments.

Recent Revisions to MCAA’s Model COVID-19 Return to Work Exposure Control Plan

MCAA’s Model COVID-19 Return to Work Exposure Control Plan was again revised to address changes to CDC guidance and add additional COVID-19 safety resources to the plan. MCAA recommends that you evaluate these changes to ensure that your company’s program is current.

Revisions were made to the actual MCAA Model COVID-19 Return to Work Exposure Control Plan and to the accompanying documents, including:

  1. The addition of the Temperature and Symptom Screener Training PowerPoint with accompanying instructor notes;
  2. Changes to COVID-19 symptoms;
  3. Changes to discontinuing isolation protocol;
  4. Definition of “Prolonged Period”;
  5. Changes to temperature and symptom screening protocol; and
  6. Changes to PPE requirements for screeners.

The following resources can be found in the RESOURCE CENTER and below:

MCAA Model COVID-19 Return to Work Exposure Control Plan & Checklist

MCAA COVID-19 Regulatory & Legal Guidance

MCAA Model COVID-19 Return to Work Exposure Control Plan Questionnaires – Jobsite Screening and Company Screening Questionnaires

MCAA COVID-19 Return to Work Employee Safety Training PowerPoint & Instructor Notes

MCAA Model COVID-19 Return to Work Exposure Control Plan Test & Answer Key

MCAA COVID-19 Temperature and Symptom Screener Training PowerPoint & Instructor Notes

Law Office of Adele Abrams Newsletter – August 20, 2020

MCAA partner Adele Abrams has released the Law Office of Adele Abrams Newsletter dated August 20, 2020. The latest newsleter includes articles on OSHA Use of NWS Chart for Heat Stress Invalidated and Updates Affecting Marijuana in the Workplace.

ASHRAE Epidemic Task Force Releases Updated Building Readiness Guide

As many buildings are preparing to reopen during this pandemic, the ASHRAE Epidemic Task Force has updated its reopening “Building Readiness” guidance for HVAC systems to help mitigate the transmission of SARS-CoV-2. Specific updated recommendations to the building readiness guidance include the following: Pre- and Post- Flushing Strategy, Energy Recovery Ventilation (ERV) Systems Operation, and Building Readiness Modes of Operation for the Building.

8/17 Alston & Bird Coronavirus Flash Update

Alston & Bird have released their August 17 COVID-19 update, including the latest news on emergency funding, administrative and regulatory actions, workplace and home issues, and many other topics, as well as to links to all their past updates.

Withum COVID-19 Bill Update – 8/13/2020

Final PPP Statistics:  As many of you know the PPP loan program is officially closed, it is certainly possible that it can be extended via the next stimulus bill, however that has been delayed and it is unclear what changes to the PPP (if any) will come as a result of the bill and when. The SBA has been consistently publishing PPP loan statistics, and this link provides what is effectively the “final” results as we know them. Some general observations:

  • $133 billion of funds allocated to the program went unused.
  • NY, CA and TX were the largest recipients of loans.
  • Over 87% of the total loans issued were below $150k.
  • Chase, BOA and PNC were the top three lenders (by dollars).
  • Healthcare, professional services and tech were the top three beneficiaries (by dollars).

New Clarifications/FAQs on How to Calculate Forgiveness: The SBA released new FAQs recently, Withum has written an in-depth analysis on each one within this article. The FAQs do not present major shifts in how we view the mechanics of forgiveness but do help provide further detail and clarity on topics such as how to calculate the maximum forgivable salary for owner/employees based on entity type (LLC, S-Corp, C-Corp and how to account for benefits paid within and outside of the covered period among other topics. As borrowers begin working on their applications, understanding these nuances is important. 

PPP and M&A: Withum often gets questions regarding how the sale or a business or the acquisition of another entity may impact a borrowers PPP loan and ability to obtain forgiveness. Withum has put together an article addressing some of the complexity that may arise from these transactions, as well as how they impact the employee retention tax credit.

Reminder Section:  (what should I be doing):

  • Talk to your payroll company about claiming the employer payroll tax deferral and employee retention credits (ERC) that were made available in the CARES Act.
  • Talk to your payroll company about claiming the qualified sick/family leave refundable tax credits (from FFCRA, passed prior to the CARES Act).
  • Consider speaking with your lender to discuss changes to terms of existing debt facilities.
  • If you have already received a PPP loan, start forecasting how you intend to spend the funds and how you can qualify for the highest amount of loan forgiveness possible. If you are not forecasting 100% loan forgiveness, then most likely you should seek assistance regarding your particular situation. Withum believes the vast majority of borrowers should expect and plan to receive 100% loan forgiveness.

Withum Update – SBA Releases New FAQs on Loan Forgiveness

On August 4, 2020, the Small Business Administration (SBA), in conjunction with the Treasury Department, released 23 frequently asked questions (FAQs) regarding loan forgiveness under the Paycheck Protection Program (PPP).

The FAQs, released approximately one week ahead of the SBA’s opening its loan forgiveness application portal, covers general questions surrounding the process and the type and amount of costs that can be included in the loan forgiveness application. Some of the FAQs confirm previously-stated positions and represent logical extensions of prior guidance, and others contradict prior guidance.

This article focuses on the most salient points of the FAQs and highlights the departures from prior SBA guidance or prevailing interpretations.

General Loan Forgiveness FAQs

  • Sole proprietors, independent contractors and self-employed individuals with no employees can use the EZ loan application.
  • Borrowers are not required to make loan payments prior to their receipt of a decision on their loan forgiveness application, provided they the application is filed within 10 months of receipt of the loan. Interest accrues from the date of receipt of the loan, but only on the part of the loan that is not forgiven.

Payroll Cost FAQs

  • There is no change to the paid or incurred rule as applied to payroll costs.
    • Paid – payroll costs that are incurred prior to a borrower’s covered period (CP) but paid during the CP are includable.
    • Incurred – payroll costs that are incurred during the CP but paid on or before the next regular payroll date after the end of the CP are includable.
  • Cash compensation is determined using gross payroll amounts. For purposes of the $100,000 annualized limitation on cash compensation, all forms of cash compensation should be considered, including wages, tips, commissions, bonuses and hazard pay.
  • Employee group health care costs are includible to the extent paid by the employer during the CP for coverage during the CP, but not for coverage outside the CP. This narrowing of the “paid” rule contradicts prior SBA guidance and creates a difference in the treatment between cash compensation and employee group health care costs.
  • No forgiveness will be provided for retirement benefits accelerated from periods outside the CP. This too represents a narrowing of the “paid” rule and contradicts prior SBA guidance.
  • The FAQs confirmed prior guidance that the maximum owner compensation amount for a 24-week CP is $20,833 in total across all businesses, but it added that borrowers are free to choose how to allocate such amount among their businesses.
  • Changes were made to the calculation of the owner compensation limits by business type. Below are the new rules.
    • C Corporations: cash compensation relating to a C corporation’s shareholder/employees is limited to 2.5 months of their 2019 cash compensation (for a 24-week CP), subject to a cap of $20,833. The corporation also is eligible for forgiveness on its group health care costs, state/local employment taxes, and retirement contributions capped at 2.5 months of the 2019 retirement contribution amounts.
    • S Corporations: cash compensation relating to an S corporation’s shareholders/employees is limited to 2.5 months of their 2019 cash compensation (for a 24-week CP), subject to a cap of $20,833. The corporation also is eligible for forgiveness on its state/local employment taxes, retirement contributions capped at 2.5 months of the 2019 retirement contribution amount, and health care contributions for owners owning less than 2% of the stock of the S corporation (or family members of such owners). Group health care costs are not eligible for forgiveness for owners or for family members of owners holding at least 2% of the S corporation’s stock.
    • Self-Employed Schedule C (or Schedule F) Filers: forgiveness is capped at 2.5 months of 2019 net profit as reported on Schedule C, line 31. No forgiveness may be obtained for group health care costs, retirement contributions, or state/local employment taxes.
    • General Partners: forgiveness is capped at 2.5 months of 2019 net earnings from self-employment (on Schedule K-1, box 14a) multiplied by .9235, and payment of this amount must be made during the CP. No forgiveness may be obtained for group health care costs, retirement contributions, or state/local employment taxes. The partners’ 2019 Schedules K-1 must be submitted along with the partnership’s loan forgiveness application.

If you have any questions regarding the loan forgiveness process, please contact a member of Withum’s SBA Financial Assistance Services Group.

Nonpayroll Cost FAQs

  • There is no change to the paid or incurred rule as applied to nonpayroll (i.e., overhead) costs.
  • No change to the definition of a covered mortgage in the CARES Act, but the FAQs state that interest on an unsecured line of credit is not eligible for forgiveness because the loan is not secured by real or personal property.
  • The renewal of a lease that was in place prior to February 15, 2020, will not affect loan forgiveness for the rental payments on such renewed lease.
  • Additional color is provided to the previous guidance that “transportation” expenses include gasoline for a borrower’s vehicle. The FAQs provide that “transportation” expenses include transportation utility fees assessed by state and local government.

Headcount and Wage Reduction FAQs

  • The SBA previously announced a safe harbor with regard to headcount reductions where the employer made an offer of reemployment that was rejected by an employee. The FAQs add that borrowers must demonstrate both an inability to hire similarly-qualified individuals on or before December 31, 2020, and that they informed the relevant state unemployment office of the offer within 30 days of the employee’s rejection of the offer.
  • With regard to salary/wage reductions, the FAQs reiterate that the borrower should only take into consideration decreases in salaries and wages, and not additional compensation such as bonuses, commissions, etc.

The FAQs provide additional guidance for borrowers, but hopefully Congress acts to further limit the loan forgiveness process either by eliminating the requirement to apply for certain loan sizes or by further streamlining the application process. Unless it does, the SBA plans to open its loan forgiveness application portal in the next few days. To the extent borrowers are left to make reasonable assumptions about the operative rules, we continue to encourage full disclosure as part of the loan forgiveness application process.

8/10 Alston & Bird Coronavirus Flash Update

Alston & Bird have released their August 10 COVID-19 update, including the latest news on emergency funding, administrative and regulatory actions, workplace and home issues, and many other topics, as well as to links to all their past updates.

8/3 Alston & Bird Coronavirus Flash Update

Alston & Bird have released their August 3 COVID-19 update, including the latest news on emergency funding, administrative and regulatory actions, workplace and home issues, and many other topics, as well as to links to all their past updates.

Train Your COVID-19 Symptom Screeners with MCAA’s New Screener Training Resource

Are your company’s COVID-19 temperature and symptom screeners properly trained? To protect your company as much as possible from complaints, lawsuits, local labor issues, etc., it is critically important to:

  • Establish a consistent process for conducting such screening and excluding symptomatic individuals to promote workplace
    safety;
  • Adopt measures to mitigate the risk of claims under laws related to discrimination and medical privacy; and
  • Be mindful of employee relations considerations.

Temperature and symptom screeners play an important role in accomplishing these objectives, so it’s a good idea to ensure that they are properly trained to take temperatures and screen for symptoms. MCAA’s new training resource, COVID-19 Temperature and Symptom Screener Training, will help you provide the proper training.

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Withum COVID-19 Bill Update – 7/29/2020

Second Round of PPP Loans:  There has been a lot of news swirling online that new legislation will open the door for borrowers to get a second PPP loan.  Also there is more chatter that automatic forgiveness for certain loans is on the horizon. It appears as though early August may be the target for new legislation if it comes. Details on this are fluid to say the least, but it looks like both Republicans and Democrats are on the same page that the PPP is an effective tool that they want to use as part of upcoming stimulus programs.

SBA Issues Procedural Notice on Forgiveness Process:  The SBA released a notice that provides clarification to lenders on how they should submit applications to the SBA for “final approval” after the lender has reviewed and approved a borrower’s forgiveness application. The highlight in this document is that the SBA indicated it will be using a third party software vendor to develop its portal, which will not be up and running until August 10th, so lenders will need to hold any applications until that time.  

The SBA further clarified that it may delay the opening of its portal further if any new legislation impacts the forgiveness process.  Withum has long believed Congress or the SBA would choose a loan threshold (e.g., loans of $250,000 or less) and grant “automatic” forgiveness to those borrowers, requiring only a signed certification that the funds were used properly. This would drastically reduce the amount of applications that the SBA and lenders would need to review. 

Withum does not have any official guidance or information on the legislative proposals reported in the press in past day or two (as noted above), but they think it may be prudent to wait to submit your application to your lender until a legislative consensus emerges. As a reminder, lenders have 60 days to process your loan forgiveness application and submit their decision to the SBA, and the SBA has 90 days to authorize the forgiveness amount.

PPP and M&A:  Withum often gets questions regarding how the sale of a business or the acquisition of another entity may impact a borrowers PPP loan and ability to obtain forgiveness. Withum put together an article addressing some of the complexity that may arise from these transactions, as well as how they impact the employee retention tax credit.

Reminder Section:  (what should I be doing):

  • Talk to your payroll company about claiming the employer payroll tax deferral and employee retention credits (ERC) that were made available in the CARES Act.
  • Talk to your payroll company about claiming the qualified sick/family leave refundable tax credits (from FFCRA, passed prior to the CARES Act).
  • Consider speaking with your lender to discuss changes to terms of existing debt facilities.
  • If you have already received a PPP loan, start forecasting how you intend to spend the funds and how you can qualify for the highest amount of loan forgiveness possible.  If you are not forecasting 100% loan forgiveness, then most likely you should seek assistance regarding your particular situation.  Withum believes the vast majority of borrowers should expect and plan to receive 100% loan forgiveness.

Revised CDC Guidelines for Discontinuing COVID-19 Isolation and Precautions

CDC Guidelines for Discontinuing COVID-19 Isolation & Precautions – For Non-Healthcare Settings – July 2020

Recent research indicates that individuals with mild to moderate cases of COVID-19 remain infectious no longer than 10 days after symptoms began; and individuals with severe illness or those who are severely immunocompromised remain infectious no longer than 20 days after symptoms began.

Based on these findings, the CDC has made changes to their guidelines regarding discontinuing COVID-19 isolation and precautions for non-healthcare settings. The highlights of these changes include the following:

  • Decision makers should use a symptom-based strategy for decision making. Using a test-based strategy is no longer recommended, except to discontinue isolation or other precautions earlier than would occur under the symptom-based strategy that follows.
  • Persons with COVID-19 who have symptoms and were directed to care for themselves at home may discontinue isolation under the following conditions:
    • At least 10 days have passed since symptom onset; and
    • At least 24 hours have passed since resolution of fever without the use of fever-reducing medications; and
    • Other symptoms have improved.
  • Infected individuals who never develop COVID-19 symptoms may discontinue isolation and other precautions 10 days after the date of their first positive real-time qualitative test for the virus.
  • The test-based strategy may still be appropriate for severely immunocompromised individuals. Consult with infectious disease experts for more information.

These recommendations will prevent most, but cannot prevent all, instances of secondary spread. 

VIEW GUIDELINES

Joint Response to Critique of Groom Law Group’s Paper on Composite Plans

In a joint letter to the Congress, the national labor/management coalition responded to the Western Council of Teamsters rebuttal of the Groom Law Group paper of Composite Plans. Coalition partners include the Associated General Contractors of America, FCA International, International Council of Employers of Bricklayers and Allied Craftworkers, International Union of Operating Engineers, Laborers’ International Union of North America (LiUNA!), Mechanical Contractors Association of America, National Electrical Contractors Association, Sheet Metal and Air Conditioning Contractors’ National Association, The Association of Union Constructors, The International Association of Bridge, Structural, Ornamental and Reinforcing Iron Workers, The Signatory Wall and Ceiling Contractors Alliance, United Association of Plumbers and Fitters, and United Brotherhood of Carpenters and Joiners of America. This July 31, 2020 version of the letter contains update analysis of the 5500 filings of the median critical and declining status plans.

7/27 Alston & Bird Coronavirus Flash Update

Alston & Bird have released their July 27 COVID-19 update, including the latest news on emergency funding, administrative and regulatory actions, workplace and home issues, and many other topics, as well as to links to all their past updates.

ASHRAE Epidemic Task Force Releases Updated Reopening Guide for Schools, Universities

As schools prepare to reopen for the fall academic year, the ASHRAE Epidemic Task Force has developed HVAC systems operation guidance to help mitigate the airborne transmission of SARS-CoV-2. The guidance includes checklists such as starting up HVAC systems prior to occupancy and checks and verifications to maintain during the academic year. The guidance addresses determining building readiness, filtration upgrades, facility design recommendations and controlling infection outbreak in school facilities.

Link to more information and guidelines:  https://www.ashrae.org/about/news/2020/ashrae-introduces-updated-reopening-guide-for-schools-and-universities

Withum COVID-19 Bill Update – 7/20/2020

Automatic Forgiveness?: Treasury Secretary Mnuchin recently suggested publicly that the SBA should consider forgiving all PPP loans and forgoing the process of the forgiveness application. This would, of course, be a stunning change in direction with respect to the mechanics of loan forgiveness. There has been chatter for a while that the SBA may seek to forgo applications on “small” loans as a vast majority of the loans issued were below $150k. This would substantially reduce the workload of the lenders and SBA when it comes to processing applications, and is appearing more and more likely as the days roll on, though the actual dollar threshold is a moving target. 

EIDL Loans: As we all know, the EIDL loan program was funded and gained a lot of traction/interest at the same time as the PPP roll out. Many companies clamored to gain access to the loan product as a result of its favorable terms (30 year repayment, 4% max rate, no personal guarantee for small loans). Withum is starting to see clients identify onerous covenants and reporting requirements (e.g., quarterly financial reports and year-end reviewed financials). There does not appear to be uniformity among all EIDL loan agreements, if you received an EIDL loan, it is important to review your agreement to ensure you have clearly identified all reporting requirements that are connected with the loan.

Reminder Section:  (what should I be doing):

  • Talk to your payroll company about claiming the employer payroll tax deferral and employee retention credits (ERC) that were made available in the CARES Act.
  • Talk to your payroll company about claiming the qualified sick/family leave refundable tax credits (from FFCRA, passed prior to the CARES Act).
  • Consider speaking with your lender to discuss changes to terms of existing debt facilities.
  • If you have already received a PPP loan, start forecasting how you intend to spend the funds and how you can qualify for the highest amount of loan forgiveness possible.  If you are not forecasting 100% loan forgiveness, then most likely you should seek assistance regarding your particular situation.  Withum believes the vast majority of borrowers should expect and plan to receive 100% loan forgiveness.

U.S. Department Of Labor Publishes Additional Guidance on Wage And Hour Rules, Family and Medical Leave As Workplaces Reopen

WASHINGTON, DC – On Monday, July 20, the U.S. Department of Labor published additional guidance for workers and employers on how the protections and requirements of the Fair Labor Standards Act (FLSA), the Family and Medical Leave Act (FMLA), and the Families First Coronavirus Response Act (FFCRA) affect the workplace as workplaces reopen amid the coronavirus pandemic. The guidance from the Department’s Wage and Hour Division (WHD) includes commonly asked questions and answers that address critical issues in all three laws. 

“The U.S. Department of Labor understands how critically American workers and employers need this information as they return to work. Continuing to provide it remains a top priority for the Wage and Hour Division,” said Wage and Hour Division Administrator Cheryl Stanton. “With so many workers and employers committed to the greatest comeback the American workforce has ever seen, we are providing ongoing guidance to help them better understand their rights and responsibilities to protect workers and help ensure a level playing field for employers as our economy recovers.” 

Today’s guidance is the latest addition to compliance assistance materials the WHD has published. These materials include a Fact Sheet for Employees, a Fact Sheet for Employers and a Questions and Answers resource about paid sick and expanded family and medical leave under the FFCRA. WHD has also produced two guidance posters, one for federal workers and one for all other employees, that fulfill notice requirements for employers obligated to inform employees of their FFCRA rights; Questions and Answers about posting requirements; and simple Quick Benefits Tips to determine how much paid leave the FFCRA allows workers to take.

FFCRA will help the U.S. combat and defeat the coronavirus by reimbursing, through tax credits, American businesses with fewer than 500 employees for the cost of providing employees with paid leave taken for specified reasons related to the coronavirus. The legislation enables employers to provide such paid leave, while at the same time ensuring that workers are not forced to choose between their paychecks and the public health measures needed to combat the virus.

WHD provides additional information on common issues employers and employees face when responding to the coronavirus and its effects on wages and hours worked under the Fair Labor Standards Act and job-protected leave under the Family and Medical Leave Act at https://www.dol.gov/agencies/whd/pandemic

For more information about the laws enforced by the WHD, call 866-4US-WAGE, or visit www.dol.gov/agencies/whd