December 21, 2020
TO: Contributing Employers to the NYCDCC Benefit Funds
FROM: Board of Trustees
DATE: December 2020
RE: Contributions for Paid Leave under the FFCRA
The Families First Coronavirus Response Act (the “FFCRA”) requires certain employers to provide their employees with paid sick leave or expanded family and medical leave for specified reasons related to COVID-19. For a summary of FFCRA obligations, please visit https://www.dol.gov/agencies/whd/pandemic/ffcra-employer-paid-leave.
In addition to imposing paid leave requirements, the FFCRA requires employers to continue group health plan coverage on the same terms as if the employee did not take paid leave. The allocable costs related to the maintenance of health benefits during the period of the required leave is to be reimbursed to employers by the Department of the Treasury via tax credits. Additional information is available at https://www.irs.gov/newsroom/determining-the-amount-of-allocable-qualified-health-plan-expenses.
Based on FFCRA employer obligations with respect to health coverage, employers must make contributions to the Welfare Fund for FFCRA paid leave benefits in accordance with the instructions below. Unless your Collective Bargaining Agreement with the Union provides otherwise, only contributions to the Welfare Fund are required to be made for the employee on FFCRA paid leave, and no other contributions will be required.
Instructions for Making Welfare Fund Contributions for FFCRA Paid Leave
To view in PDF form, please click HERE.