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COVID-19 Update

Contents

OVERVIEW

With COVID-19, employers must balance health and safety with the need to protect their business.  Brody and Associates is here to help.  We continue to monitor the COVID-19 pandemic closely, and all the latest legal and legislative moves that impact employers.

This page is designed to provide you with relevant facts employers should know regarding the virus, links to government agencies which are responding to the outbreak, as well as practical insights.

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

FACTS OF THE DAY

Fact 1:  With clear, calm and wise thinking (and a little luck), we will get through this pandemic.  While no one will be unscathed, getting through this challenge is attainable. 

Fact 2:   Paid leave – an option, not a legal obligation.  As long as you are even handed, you are allowed to send all similarly situated employees home for lack of work or because you are otherwise closing your doors – for any period of time.   Currently, a few states like New York mandate paid leave of a limited duration if schools and businesses are shut down.   If your business is closed due to an Emergency Executive Order of the Government based on the Coronavirus, your employees likely will be entitled to this benefit.   But, if this does not apply to your employees, unemployment is an option.

Fact 3:  Maintain a safe workplace – distribute health and safety guidelines.  OSHA mandates you maintain a safe workplace.  Given the uncharted territory of COVID-19, specific compliance guidelines may not exist for your industry.   However, there remains the General Duty Clause by which OSHA mandates every employer create a safe and healthy workplace.   Until specific regulations are issued, the best idea is to look to the CDC and NIH.   The CDC and NIH both have extensive guidelines on how to stay safe and minimize the spread of Coronavirus.   Distribute the guidelines to every employee.  Over educate.  Then check OSHA’s website for new guidance that may impact your business.  Click here for the general guidance issued by OSHA.

MUSING OF THE WEEK

Musing 1:   Looking for the new normal.  This isn’t the new normal; we’re not there yet.  For your business to succeed you need to be flexible and creative.  So plan for the unexpected – an oxymoron but true.    At any cost but health, find new ways to keep your business safe and successful, so when the new normal is here, you’ll be better than before.

 

ARTICLES SUMMARIZING COVID-19 LEGISLATION

 

Covid-19 Federal Paid Sick Leave Legislation Just Passed:  What Employers Are Obligated To Do

Two federal Acts will take effect on April 2, 2020.    Both cover employers with less than 500 employees. Together they provide 12 weeks of paid leave for employees who must care for someone impacted by COVID-19 or who are themselves sick or likely infected by the virus.  Here is the initial guidance on these laws:

Emergency Family and Medical Leave Expansion Act

This Act expands time off provided under the Family Medical Leave Act (FMLA).  However, unlike the FMLA, this Act provides time off with pay.  It also covers employees who have worked for as little as 30 days for the employer.  

Employers with fewer than 500 employees must provide up to 12 weeks of leave for employees who are unable to work (or telework) due to a need to care for their son or daughter who is under 18 years of age and whose school or place of care has been closed, or the child care provider is unavailable, due to the COVID-19 virus.  To qualify, an employee must provide notice as is practical.  

The initial 10 days of leave is unpaid (but see below). Thereafter, employers must pay not less than two-thirds (2/3) of the employees’ regular rate for the remaining ten (10) weeks—but limited to $200 per day.  Small businesses with fewer than 50 employees may be exempt from these requirements “when the imposition of such requirements would jeopardize the viability of the business.”

For employers with 25 or more employees, the employee is entitled to reinstatement to the same or equivalent position. Employers with fewer than 25 employees must make reasonable efforts to restore an employee to his or her previous position but may be exempt from reinstating the employee if such reasonable efforts fail and the economic or operating conditions of the employer have changed due to the COVID-19 pandemic. 

Emergency Paid Sick Leave Act

This Act provides pay for the first two (unpaid) weeks of leave under the Emergency Family Medical Leave Expansion Act.   Employees are immediately eligible; there is no 30 day waiting period.  Employers with fewer than 500 employees must provide two (2) weeks of paid sick time to employees who are unable to work (including telework) for one of the following six reasons.  The reasons break down into COVID-19 quarantine/sick related issues and providing care for someone impacted by COVID-19.

COVID-19 Quarantine/Sick Related Issues
1.  The employee is subject to a federal, state, or local quarantine or isolation order relating to COVID-19;
2.  The employee has been advised by a health care provider to self-quarantine due to COVID-19;
3.  The employee has sought a medical diagnosis resulting from symptoms of COVID-19;

Providing Care for Someone Impacted by COVID-19
4. The employee is caring for an individual subject to a quarantine order;
5.  The employee is caring for the employee’s own child whose school is closed, or whose care provider is unavailable due to COVID-19; or
6. The employee is experiencing any other substantially similar condition specified by the Department of Health and Human Services.

For an employee absent under subsections (1), (2), and (3), compensation shall not be less than the employee’s regular rate but shall not exceed $511 per day.  The 2/3 pay maximum, as described in the Act above, does not apply here.   

For an employee absent under subsections (4), (5), and (6), compensation shall be no more than two-thirds of the employees’ normal pay and shall not exceed $200 per day.

 A full-time employee is entitled to 80 hours of paid sick time. A part-time employee is entitled to the number of hours worked on average over a two (2) week period. 

Employers may not require the employee to find a replacement worker. Employers may not require an employee to use other paid leave before using paid sick time under this Act.
 
The employer must post notice of its obligations under this Act in a conspicuous place on its premises.  The Secretary of Labor shall make available a model notice by March 25, 2020.

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

New York State Executive Order 202.8 Shuts Down Many Businesses

By Robert G. Brody and Mark J. Taglia

Executive Order 202.8
Effective Sunday, March 22, 2020 at 8:00 PM, New York State’s Executive Order 202.8 shut down many New York businesses in order to combat the spread of COVID-19.  The State also issued guidance on who is exempted from the law.  Here is what we know. 

As of 8:00 pm, Sunday March 22, 2020 through April 19, 2020:

  1. All businesses and not-for-profit entities need to utilize, to the maximum extent possible, any telecommuting or work from home procedures that they can safely use.
  2. Each employer shall reduce the in-person workforce at any of its work locations by 100%.
  3. Any “essential” business or entity providing essential services or functions shall not be subject to the in-person restrictions. Any business violating the above shall be subject to enforcement as if this were a violation of an order pursuant to section 12 of the Public Health Law (click here to be linked to section 12 of the New York State PHL).

For employers’ reference, the New York State Department of Economic Development has issued guidance on what exactly is considered essential services.   It has broken these services down into twelve (12) broad categories, as follows:

1.  Health care operations including research and laboratory services, hospitals, walk-in care health facilities, veterinary and animal health services, elder care, medical wholesale and distribution, home health care workers or aides, doctor and dentist offices, nursing homes, or residential health care facilities or congregate care facilities and medical supplies and equipment providers.
2.  Essential infrastructure including utilities like power generation, fuel supply and transmission; public water and wastewater; telecommunications and data centers; airports/airlines; transportation infrastructure such as bus, rail or for-hire vehicles and garages.
3.  Essential manufacturing including food processing, including all foods and beverages, chemicals, medical equipment/instruments, pharmaceuticals, safety and sanitary products, telecommunications, microelectronics/semi-conductor, agriculture/farms, paper products.
4.  Essential retail including grocery stores, all food and beverage stores, pharmacies, convenience stores, farmer’s markets, gas stations, restaurants/bars (only for takeout/delivery), hardware and building material stores.
5.  Essential services including trash and recycling collection, processing and disposal, mail and shipping services, laundromats/dry cleaning, building cleaning and maintenance, child care services, auto repair, warehouse/distribution and fulfillment, funeral homes, crematoriums and cemeteries, storage for essential businesses, animal shelters or animal care/ management.
6.  News media.
7.  Financial Institutions including banks, insurance, payroll and accounting.
8.  Providers of basic necessities to economically disadvantaged populations including homeless shelters and congregate care facilities, food banks, human services providers whose function includes the direct care of patients in state-licensed or funded voluntary programs; the care, protection, custody and oversight of individuals both in the community and in state-licensed residential facilities; those operating community shelters and other critical human services agencies providing direct care or support.
9.  Construction including skilled trades such as electricians, plumbers, other related construction firms and professionals for essential infrastructure or for emergency repair and safety purposes.
10.  Defense and national security-related operations supporting the U.S. government or a contractor to the U.S. government.
11.  Essential services necessary to maintain the safety, sanitation and essential operations of residences or other essential businesses including law enforcement, fire prevention and response, building code enforcement, security, emergency management and response, building cleaners or janitors, general maintenance whether employed by the entity directly or a vendor, automotive repair, disinfection and doormen.
12.  Vendors that provide essential services or products, including logistics and technology support, child care and services needed to ensure the continuing operation of government agencies and provide for the health, safety and welfare of the public including logistics, technology support, child care programs and services, government owned or leased buildings and essential government services.
 
Despite the length of this list, many employers are asking if they are covered.   In many cases we need to make an educated guess, but there is an alternative.  New York State has created a service which allows employers to ask the State for guidance on the essential nature of their business.  Beyond guidance, the State has already determined single person businesses are deemed essential and do not need to abide by this closure order.   Over time, we will have more guidance on the definition of “essential.” 
 
If you need help deciphering the definition of essential, need assistance in asking the State for guidance, or any other employment related issues pertaining to COVID-19, we stand ready to help. 

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

New Amendment to Mandatory Connecticut Unemployment Form

The Connecticut Department of Labor just amended the mandatory form every employer must deliver to its employees when they separate from the Company – regardless of the reason.   The key difference is when listing the reason for separation, a new category was added – Leave of Absence.   Given the number of employers who are using furloughs – a forced leave of absence with a promise of a return to work – this change is key and likely a reaction to the current COVID-19 pandemic.  The new form and the entire unemployment packet can be found here.

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

Emergency Relief Available for Your Business

The Federal government passed a stimulus package designed to put tens of thousands of dollars in your pocket. This package is designed to keep our economy going during this tragic time. You need to understand your options. The bare bones of three programs are below.

PAYCHECK PROTECTION PROGRAM
Under the recently passed CARES Act, you can borrow, through an SBA approved bank, a 100% forgivable loan equal to 250% of your average monthly payroll to cover payroll, rent, benefits, and certain interest payments. We believe practically all of our clients should do this. The money could be in your hands within the next few weeks.

SBA EMERGENCY LOANS
You can get a 30 year, 3.7% loan directly from the SBA for the amount of profit you expect to lose due to the COVID-19 pandemic. To induce you to apply, every applicant gets a $10,000 payment that is a non-repayable grant, even if you ultimately do not get the loan.

BRODY AND ASSOCIATES BUSINESS PREPAREDNESS PROGRAM (“BPP”)
We know you have many questions spawned by the pandemic and need answers economically. To help support you and your business, Brody and Associates created the Business Preparedness Program (“BPP”). Our BPP allows clients to purchase one to two hours of legal services per month at $315 per hour – almost 50% off my rate. Because we know you have so many questions, we will double the number of hours you purchase for the first month at no extra cost. BPP hours must be used within the month they are purchased. If you exceed your BPP hours, our standard rates apply.

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

Recommended Strategies to Help Curtail the Spread of COVID-19

By Robert G. Brody and Mark J. Taglia

The following strategies are for employers to help curtail the spread of COVID-19 and are based on recommendations made by the Centers for Disease Control and Prevention (the “CDC”) with an extra dose of practicality.

Actively Encourage Employees Who Might be Sick to Stay Home.

  • Make sure employees are aware of your sick leave policies and that your policies are consistent with current public health guidelines.
  • Expand sick leave to cover employees who are not sick but might be.
  • Employees who were sick should stay home until they are symptom free (including fever) for at least 24 hours, without the use of fever reducing medication.
  • Maintain flexible work policies to allow employees to stay home to care for sick family members.

Protecting Employees Who are at Work.

  • Send sick employees home once they begin to display acute respiratory symptoms (i.e. cough or shortness of breath). This should not be an option.
  • Encourage hand hygiene and respiratory etiquette (i.e. covering one’s mouth when they cough).
  • Provide tissues, alcohol based hand rubs, soap and water and remind employees where these facilities are located if you have provided new locations with hand cleaning supplies and the like. .
  • Display posters near the entrance to your offices and in break rooms encouraging hand hygiene, respiratory etiquette and staying home when employees are sick.

Perform Routine Cleaning.

  • Routinely clean all frequently touched surfaces in your offices.
  • Provide disposable wipes for employees to use to clean frequently used items they come into contact with throughout the day.
  • Arrange for regular deep cleaning if possible.

International Travel.

  • Check with the CDC’s Traveler Health Notices before any international travel. Avoid travel if at all possible.
  • Encourage employees to check themselves for any acute respiratory symptoms before traveling.
  • Have any employee who becomes sick while traveling seek healthcare assistance and notify their supervisor.
  • If any employee becomes sick oversees, the U.S. Consular Office can help locate healthcare services.

Additional Considerations.

  • Employees with sick housemates should notify their supervisor and refer to current CDC guidelines on how to conduct a self-risk assessment.
  • Lastly, if you do have an employee who tests positive for COVID-19, you must inform fellow employees of any possible exposure. However, you must maintain the confidentiality of the infected employee as required under the Americans with Disabilities Act (the “ADA”).

Planning for the Pandemic

Based on current forecasts, the full impact of the pandemic has yet to hit the U.S.  It is important as a prudent employer to plan ahead.  The following are some items to keep in mind when planning:

  • Consider how to prevent and limit spread within your office while maintaining business operations (remote operations are best).
  • Plan for potential high absenteeism due to illness of employees and their family members.
  • Prepare for school closures and how that will impact your business.
  • Inform employees that some individuals are at greater risk than others for contracting the disease (including older employees and those with chronic medical conditions).
  • Identify essential job functions within your organization and cross train personnel to perform those functions.
  • For businesses with multiple locations, assess the similarities and differences of each office to determine how to best utilize the resources you have should some of your operations be closed.
  • Ensure your response plan is flexible and involve your employees in its design process to limit any gaps. Remember, inclusion will give extra comfort to your team as they will see firsthand you are planning to protect everyone and the business.
  • Share your plan in advance with your employees.
  • Consider sharing your plan with other businesses and organizations in your area who may not have planned ahead.

Final Recommendations

Now is a good time to review your HR policies and Employee Handbooks to make sure your policies are consistent with current public health recommendations, state and federal laws.

The CDC, Department of Labor, and Equal Opportunity Commission are excellent resources for employers to use to stay up to date with the latest on the Coronavirus and its impact on businesses.

Next week, in part two of our series, we will be looking at specific laws employers should know when dealing with employees during the coronavirus pandemic.

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

 State Of Connecticut Executive Order 7H “Stay Safe, Stay Home” Campaign Shuts Down Many Businesses

By Robert G. Brody and Mark J. Taglia

It’s been over a week in Connecticut since many business have had to close their doors.  Let’s see where we are.  Effective Monday, March 23, 2020 at 8:00 PM, the State of Connecticut’s Executive Order 7H shut down many Connecticut businesses in an effort to combat the spread of COVID-19.  The State also issued guidance on who is exempted from the law.  Here is what we know. 

As of 8:00 pm, Monday March 23, 2020:

  1. All businesses and not-for-profit entities need to utilize, to the maximum extent possible, any telecommuting or work from home procedures that they can safely use.
  2. Each employer shall reduce the in-person workforce at any of its work locations by 100%.
  3. Any “essential” business or entity providing essential services or functions shall not be subject to the in-person restrictions. However, individuals working at these locations whose duties are not critical to an essential business function should work from home.

The Executive Order is in effect until April 22, 2020.

To assist employers in defining essential services, the Department of Economic and Community Development (the “DECD”) has issued comprehensive guidance. The text issued by DECD follows:

DECD GUIDANCE ON ESSENTIAL BUSINESSES

DECD’s guidance on essential businesses is as follows:

With respect to non-essential businesses and nonprofits, this guidance applies to each business location individually and is intended to assist businesses in determining whether they are an essential business and the steps they may take to request that designation.  

The guidelines set forth here apply to places of business. Non-essential businesses may continue activities that are conducted off-site (e.g. a customer’s home) and/or by telecommuting or working from home. 

Pursuant to the Governor’s Executive Order 7J, issued on March 22, 2020, 1) non-essential retailers may be staffed on-site, provided that they may only offer remote ordering (e.g. phone, internet, mail, dropbox) and curb-side pick-up or delivery and 2) non-essential businesses and nonprofits to allow staff or third parties on site to the minimum extent necessary to provide security, maintenance and receipt of mail and packages. This includes, but is not limited to, auto, boat, bicycle, recreational vehicle, and all other vehicle sales, if conducted remotely. 

To the extent possible, employees of Essential Businesses whose duties are not critical to an Essential Business function described below should telecommute or utilize any work from home procedures available to them.  

Critical Infrastructure Sectors

Essential workers in the 16 critical infrastructure sectors defined by the federal Department of Homeland Security.  You can read more on the Department of Homeland Security’s site here.

  • Healthcare/Public Health
  • Emergency Services – Law Enforcement, Public Safety, First Responders
  • Food and Agriculture
  • Nuclear Reactors, Materials & Waste
  • Energy
  • Water and Wastewater
  • Transportation and Logistics
  • Other Community-Based Government Operations and Essential Functions
  • Critical Manufacturing
  • Financial Services
  • Chemical
  • Defense Industrial Base
  • Communications
  • Information Technology
  • Dams
  • Commercial Facilities

Healthcare and related operations

  • biotechnology therapies
  • consumer health products and services
  • doctor and dentist offices
  • elder care, including adult day care
  • health care plans and health care data
  • home health care workers or aides
  • hospitals
  • manufacturing, distributing, warehousing, and supplying of pharmaceuticals, including research and development
  • medical marijuana dispensaries and producers
  • medical supplies and equipment providers, including devices, diagnostics, services, and any other healthcare related supplies or services
  • medical wholesale and distribution
  • nursing homes, or residential health care facilities or congregate care facilities
  • pharmacies
  • physical therapy and chiropractic offices
  • research and laboratory services, including testing and treatment of COVID-19
  • veterinary and animal health services
  • walk-in-care facilities

Infrastructure

  • airports/airlines
  • commercial trucking
  • dam maintenance and support
  • education-related functions at the primary, secondary or higher education level to provide support for students, including distribution of meal or faculty conducting e-learning
  • hotels and other places of accommodation
  • water and wastewater operations, systems and businesses
  • telecommunications and data centers
  • transportation infrastructure including bus, rail, for-hire vehicles and vehicle rentals, and garages
  • utilities including power generation, fuel supply, and transmission

Manufacturing

All manufacturing and corresponding supply chains, including aerospace, agriculture and related support businesses

Retail

  • appliances, electronics, computers and telecom equipment
  • big-box stores or wholesale clubs, provided they also sell groceries, consumer health products, or operate a pharmacy
  • convenience stores
  • gas stations
  • grocery stores including all food and beverage retailers
  • guns and ammunition
  • hardware, paint, and building material stores, including home appliance sales/repair
  • liquor/package stores and manufacturer permittees
  • pharmacies
  • pet and pet supply stores

Food and Agriculture

  • farms and farmer’s markets
  • food manufacturing, processing, storage, and distribution facilities
  • nurseries, garden centers and agriculture supply stores
  • restaurants/bars (provided compliance with all applicable executive orders is maintained)

Services

  • accounting and payroll services
  • animal shelters or animal care or management, including boarding, grooming, pet walking and pet sitting 
  • auto supply, repair, towing, and service, including roadside assistance
  • bicycle repair and service
  • building cleaning and maintenance
  • child care services
  • critical operations support for financial institutions
  • financial advisors
  • financial institutions, including banks, credit unions, and check cashing services
  • funeral homes, crematoriums, and cemeteries
  • insurance companies
  • laundromats/dry cleaning
  • legal and accounting services
  • mail and shipping services
  • marinas and marine repair and service
  • news and media
  • real estate transactions and related services, including residential leasing and renting
  • religious services (subject to Executive Order 7D limiting gatherings to 50 people)
  • storage for Essential Businesses
  • trash and recycling collection, hauling, and processing
  • warehouse/distribution, shipping, and fulfillment

Providers of Basic Necessities to Disadvantaged Populations

  • food banks
  • homeless shelters and congregate care facilities
  • human services providers whose function includes the direct care of patients in state-licensed or funded voluntary programs; the care, protection, custody and oversight of individuals both in the community and in state-licensed residential facilities; those operating community shelters and other critical human services agencies providing direct care or support social service agencies

Construction

  • all skilled trades such as electricians, HVAC, and plumbers 
  • general construction, both commercial and residential
  • other related construction firms and professionals for essential infrastructure or for emergency repair and safety purposes
  • planning, engineering, design, bridge inspection, and other construction support activities

Safety and Sanitation Services

  • building cleaners or janitors
  • building code enforcement
  • disinfection
  • doormen
  • emergency management and response
  • fire prevention and response
  • general maintenance whether employed by the entity directly or a vendor
  • home-related services, including real estate transactions, closings, appraisals, and moving services
  • landscaping services
  • law enforcement
  • outdoor maintenance, including pool service
  • pest control services
  • security and maintenance, including steps reasonably necessary to secure and maintain non-essential businesses
  • state marshals

Essential Service Vendors

Vendors that provide essential services or products, including logistics and technology support, child care, and services needed to ensure the continuing operation of government agencies and provide for the health, safety and welfare of the public including:

  • billboard leasing and maintenance
  • child care services
  • essential government services
  • government owned or leased buildings
  • information technology and information security
  • logistics
  • technology support

Defense

  • defense and national security-related business and operations supporting the U.S. Government or a contractor to the US government

Requesting Designation

If the function of your business is not listed above, but you believe that it is essential or it is an entity providing essential services or functions, you may request designation as an Essential Business.

Requests by businesses to be designated an essential function as described above, should ONLY be made if they are NOT covered by the guidance.

Restrictions on requesting designation as an Essential Business:

Any business that only has a single occupant/employee (e.g. attendant) is deemed exempt and need not submit a request to be designated as an Essential Business.

*                                                          *                                                          *

Despite the length of this list, many employers are asking if they are covered.   In many cases we need to make an educated guess, but there is an alternative.  As mentioned at the end of the legislation, like New York, Connecticut has created a service which allows employers to ask the State for guidance on the essential nature of their business (see link above).  Additionally, the Governor has already issued a clarifying order for retailers (Executive Order 7J), which allows non-essential retailers to take orders remotely and sell products for curbside pickup and delivery, and allows other nonessential businesses to allow the minimum staff necessary on site to handle security, maintenance, mail, and other essential services

To help businesses in Connecticut navigate the COVID-19 crisis, DECD has established the COVID-19 Business Emergency Response Unit reachable at (860) 500-2333.

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

The Coronavirus Aid, Relief, and Economic Security (CARES) Act: $2.4 Trillion Aid Package to Help Combat COVID-19’s Financial Impact

By Robert G. Brody and Mark J. Taglia

The Coronavirus Aid, Relief, and Economic Security (CARES) Act, which President Trump signed into law on March 28, 2020, is a wide-ranging economic rescue package for individuals and businesses.

The CARES Act provides, among other things, direct monetary payments to individuals, help for the unemployed (including freelancers and gig workers), and support for small businesses.  The following is a brief summary of some of the key benefits employers should know.

Direct Monetary Payments to Individuals and Families
The IRS will send direct payments to families of up to $1,200 for individuals, $2,400 for couples, and $500 per child.

Single taxpayers with an adjusted gross income up to $75,000 will receive $1,200 in direct payments and joint filers with an adjusted gross income up to $150,000 will receive $2,400.  As such individuals’ income increases, these benefits will decreases until eliminated for those individuals making more than $99,000 and $198,000 respectively.  The IRS will use individuals 2019 tax filings to determine eligibility.

Help for Unemployed Individuals, Freelancers, and Gig Workers

The CARES Act provides increased unemployment benefits in two primary ways:  
  • First, unemployed individuals eligible for state unemployment insurance will receive  an additional $600 per week in federal aid for their first four months of unemployment.
  • Second, non-traditional employees, often referred to as “gig” workers and Freelancers, as well as individuals not able to work because of COVID-19, will be eligible to receive unemployment insurance.  These workers will be entitled to receive half of their state’s average weekly unemployment benefit, plus the additional $600 federal benefit referenced above; provided their unemployment was related to COVID-19.

Small Businesses and Small Business Administration (the “SBA”) Loans
The CARES Act provides for $349 billion for SBA loan guarantees, which loans can be forgiven in an amount equal to the amount spent by a borrower, if the money is used for payroll support including employee salaries, paid sick and medical leave, health insurance premiums, mortgage, rent, utility payments, etc.   This section of the Act is referred to as the Paycheck Protection Program (PPP).  Under the Act, self-employed individuals, including, sole-proprietors and independent contractors are also eligible for loans.    Brody and Associates will be publishing a new article specifically designed for clients looking to take advantage of the Paycheck Protection Program.

Additionally, the CARES Act provides for billions more in SBA emergency loans and grants through the emergency Economic Injury Disaster Loans (EIDL) and emergency Economic Injury Grants.

These grants, up to $10,000, are advances against the EIDL  and do not need to be paid back, even if the borrower ultimately does not qualify for the underlying loan.  This grant is designed to give immediate relief for small businesses to cover operating costs. 

Meanwhile, the rates on EIDL are very favorable with an interest rate of just 3.75% (2.75% for non-profits) and a loan repayment term of up to 30 years.  Brody and Associates will be publishing a new article specifically designed for clients looking to take advantage of Emergency Economic Injury Disaster Loan program.

Employee Retention Tax Credit
A big win for employers in the CARES Act is a refundable payroll tax credit equal to 50% of the wages paid by eligible employers to employees made during the COVID-19 crisis.  To utilize this benefit, employers are not permitted to receive any SBA payroll support loans.  The tax credit is limited to the first $10,000 of compensation paid to an eligible employee, including health benefits.

An employer’s eligibility is conditioned upon its operations being actually impacted by COVID-19.

For eligible employers with up to 100 full-time employees, all wages qualify for the credit, whether the employer is open for business or subject to a shut-down order. 

However, for employers with more than 100 full-time employees, not all wages will qualify.  For those employers, qualified wages are limited to the wages paid to employees when they are not providing services due to the COVID-19-related circumstances described above.

Delay of Payment of Employer Payroll Taxes
CARES gives employers the option to postpone the payment of the employers share of payroll taxes, provided any deferred payment is paid over the following two years
 
We have only highlighted the relevant sections of the CARES Act we think are most relevant to our readers.  Please click here for a link to the actual law to learn more about its details and other benefits not covered here.

The CARES Act has just been released and there is much still to learn about its applications and its practical impact.  We suggest you seek qualified counsel to help guide you.  Brody and Associates is here to assist.

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

Paycheck Protection Program under the CARES Act:  Don’t Miss the Opportunity 

By Robert G. Brody, John Woyke and Mark J. Taglia

April 16, 2020

Under the recently passed Coronavirus Aid, Relief, and Economic Security (CARES) Act, the federal government is providing a wide array of programs designed to help small businesses, nonprofits and other employers, weather through the economic storm caused by COVID-19.  Many of the programs have staggering amounts of funding but the funding is still running out.  Additional funding is being discussed, but nothing is yet approved.  Regardless of funding, the application process is brief and therefore we continue to recommend that everyone consider applying.  

As we discussed in a recent article, a leading benefit of the CARES Act is the Paycheck Protection Program (the “PPP”). The PPP is a new program funded by the CARES Act and administered through the Small Business Administration (the “SBA”).  It provides small businesses cash flow assistance through federally guaranteed loans in order to retain employees.  PPP loans are 100% guaranteed by the federal government: business owners do not need to personally guarantee the loans or put up any collateral.  More importantly, all or a portion of the loan is forgivable if certain criteria are met.  We expect the vast majority of these loans will be forgiven.  Finally, a PPP loan must be taken out before June 30, 2020 from a bank that is an authorized SBA lender. 

Key Benefits of PPP Loans.

One of the most significant benefits of a PPP loan is the potential for complete loan forgiveness.  If an employer uses the loan to primarily maintain its payroll, and pay other expenses like rent and utilities, the loan will be forgiven i.e., the employer will NOT need to repay the loan. By allowing this forgiveness, the federal government is hoping employers will keep workers employed, and put needed money (consumer spending) back into the economy.

In addition to forgiveness of up to eight (8) weeks of payroll and payroll related expenses, PPP loans have a host of other attractive terms.  There are no SBA fees, a 1.0% interest rate on any amount not forgiven and at least six months of deferral before any repayment starts.

To qualify for loan forgiveness, an employer will have to provide documentation to confirm the calculation of the amount requested,  how the loan was spent, what and how much of a salary reduction was imposed on any employees, and how has the employer’s employee headcount been impacted, if at all.   

How much can be borrowed?

The maximum amount of a PPP loan is 2.5 times the average monthly payroll costs of the employer.  Under the statute and the most recent guidance issued by the federal government on April 13, 2020 (the “Guidance”), this monthly average is based on the 12-month period prior to the date of the loan.  However, in another part of the Guidance, and based on the PPP application, this monthly calculation is based on the 2019 calendar year.  There is no answer to this controversy but we are using the 2019 calendar year.  Beyond this controversy, there are special rules for seasonal employers and employers who were not in existence for either12-month period.  A few important items employers should keep in mind when calculating the requested loan amount are:

•    Only the first $100,000 of annual compensation per employee can be counted;
•    Payroll costs include pay, benefits, state payroll taxes (but the employer’s portion of FICA taxes are not included), and severance pay; and
•    Independent contractors receiving 1099 forms can be counted as employees when calculating your headcount, but their compensation will not be an approved payroll expenditure.  This seems inconsistent but it is another issue related to how the statute was drafted.   

How to Qualify for Loan Forgiveness?

The portion of a PPP loan which can be forgiven are monies used to pay the payroll costs for the first eight (8) weeks after the loan is taken, plus the following expenses during the same 8-week period, to the extent these costs do not exceed 25 percent of total of the amount to be forgiven:

•    Interest on any mortgage obligation of the business;
•    Rent payments;
•    Utility payments;
•    Employee benefits (including healthcare and retirement);
•    State Payroll taxes (but not the employer’s portion of FICA); and
•    Certain other items not listed here.

Unfortunately for some small businesses, the amount of a PPP loan which can be forgiven can be reduced under the following two circumstances: 

•    If the pay of any individual employee has been reduced by more than 25% from what it was before the 8-week period; and
•    If the employer has reduced the number of full-time equivalent employees prior to the 8-week period.

In certain instances, the reductions discussed above can be waived in whole or in part if the employer reinstates lost wages for affected employees and returns its number of full-time equivalent employees to the prior levels by June 30, 2020.

Does my business qualify for a PPP Loan?

Most businesses with 500 or fewer employees will qualify for this loan.  The following requirements apply to qualify for the PPP SBA loan under the CARES Act:

•    Businesses and entities must have been in operation on February 15, 2020;
•    The business or entity must have been harmed by COVID-19 between February 15, 2020 and June 30, 2020;
•    Types of businesses:

  • Small business concerns, as well as any business concern, a 501(c)(3) nonprofit organization, a 501(c)(19) veterans organization, or Tribal business concern described in section 31(b)(2)(C) that has fewer than 500 employees;
  • Individuals who operate a sole proprietorship, as an independent contractor, and self-employed individuals.

We have only highlighted the relevant sections of the Paycheck Protection Program we think are most relevant to our readers.  Please click here for a link to the law to read more about its details and other benefits.

In addition to the PPP loan available under the CARES Act, a small business can also receive a loan under the Economic Injury Disaster Loan (EIDL) provisions of the CARES Act, as long as the use of the funds is not for the forgiven payroll costs of the PPP.  We will look more closely at the EIDL program of the CARES Act in the coming days.

The CARES Act and the Paycheck Protection Program have just been released and there is much still to learn about its applications and its practical impact.

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

Second Stimulus Package en Route to White House:  Awaits President’s Signature

By Robert G. Brody and Mark J. Taglia
April 23, 2020
 
The second stimulus package designed to help stave off the pending financial crisis resulting from the COVID-19 pandemic has just been approved by both Houses of Congress and is ready for Presidential approval, which is expected to take place later today.
 
The new funding package includes $484 billion for additional COVID-19 testing, hospitals and small businesses.  A big missing component to this latest legislation is aid for state and local governments.  Congressional Democrats had pushed for inclusion of an additional $150 billion for state and local governments, but were forced to acquiesce in order to get the bill passed.
 
The new bill adds $321 billion to the Paycheck Protection Program (the “PPP”), of which $60 billion is earmarked for “underbanked” small businesses that had a difficult time getting loans in the first round of PPP funding (because they didn’t have regular relationships with traditional banks).  The deal also includes an additional $60 billion for loans and grants to be made under the Economic Injury Disaster Loan program (“EIDL”).  Both the EIDL and PPP loan programs ran out of initial funding last week.  Finally, the bill contains $75 billion for hospitals and $25 billion to expand coronavirus testing.
 
Despite the addition of another $484 billion in economic stimulus, few insiders believe this will be sufficient to get the American economy over the current economic downturn. Additional funding is expected for states and local governments; a sentiment President Trump has supported in the past and agreed to address in future legislation.  How much state and local funding will be made available will be hotly debated and could lead to protracted negotiations between both congressional parties and the President.
 
Two cornerstones of the new bill are the additional funding for the PPP and EIDL.  We anticipate new guidelines to be released in the coming days on how the rollout of these funds may differ from the initial grant under the PPP and EIDL.  A big criticism from the first round of funding was the difficulty smaller businesses had trying to access the loans.  As a result, it is anticipated new rules will be implemented to help truly small businesses get their fair share of the latest installment of PPP funds.  Already, Brody and Associates uncovered one interesting nuance in the bill involving the new restrictions applied to EIDL funds.  Under the bill, EIDL funds must be used solely to “prevent, prepare for and respond to coronavirus.”   Previously, EIDL funds had no restrictions.  As a result of this new restriction, the usefulness of EIDL loans will dramatically be decreased.
 
Brody and Associates will continue to closely monitor the implementation of this new legislation and keep our readers informed.

 

New Guidance on How PPP Moneys Can be Spent- Know Your Rights and Limitations!

By Robert G. Brody and John Woyke
April 30, 2020

When the Paycheck Protection Program (the “PPP”) was enacted as part of the federal $2.4 trillion bailout program, Coronavirus Aid, Relief, and Economic Security Act, the terms of the program looked fairly clear; there were few restrictions on how PPP loan proceeds could be used (for a basic discussion of the PPP click here).  Now, as we delve into this issue and new guidelines continue to be published, it becomes clear serious restrictions do exist.   If you don’t timely spend the money on approved expenses, you won’t have all or a portion of your loan forgiven (but you’ll still have two years to pay it back).   If you spend too much of your loan on unapproved items, your loan could be called at the end of 2020.  And if you are guilty of fraud, personal liability and even jail time are possible.  So let’s be clear on how to spend this money.  
 
75% of the Loan Must Be Spent on Payroll Costs
 
The new SBA Interim Final Rule (the “IFR”) (click here for link to text) clearly states 75% of the proceeds of the loan must be used for payroll costs and only 25% for “Other” purposes such as rent and utility payments (for a discussion of what is “payroll” and what is “other purposes” click here).  If compliance is not reached by December 31, 2020, the loan could be called and repayment demanded immediately.  Given the formula used to derive the loan amount -2.5 times average monthly payroll– this compliance should be easy for on-going businesses.  
 
While “payroll purposes” is defined, issues may still arise.   If you make an honest mistake, which seems understandable given the constantly changing landscape we face regarding these new laws, you’ll likely only lose some forgiveness of the loan. But if you intentionally use the 75% for non-payroll items, that is fraud.  Most importantly, this is a criminal act and jail time is possible.  Also, the SBA can pierce the corporate veil and require repayment from a shareholder, member or partner, even though loans up to $200,000 do not require personal guarantees.
 
Calculating Forgiveness of the Loan                    
 
The law states that amounts used for appropriate purposes during the first eight weeks after the loan is made will be forgiven.  No further requirements are written into the law.  The IFR however, require at least 75% of the amount forgiven must have been used for payroll costs during that eight week period.  This means the amount used for non-payroll costs during the first eight week period can be no more than one third of the amount used for payroll costs (25% is one third of 75%).  Therefore, if the borrower doesn’t use the full 75% for payroll, the borrower can’t use the full remaining 25% for “Other” costs.  
 
Furthermore, as has been well reported, the law includes other restrictions on the amount forgiven. These restrictions reduce the amount forgiven based on reductions in headcount of the borrower and individual employee pay reductions of more than 25%.  These reductions are applied to the amount of payroll costs that could be forgiven.  This in turn reduces the amount of “Other” costs allowed.  For example, if a borrower claims it paid $100,000 in payroll costs but due to headcount and individual pay rate reductions, the borrower lost $10,000 of forgiveness, the payroll expense would now be $90,000.   In turn, the 25% for “Other” costs will be based on $90,000, not $100,000, so the maximum forgiveness of “Other” expenses will be one third of $90,000 ($30,000) not one third of $100,000 ($33,333).  
 
When your lender audits how you spent your funds, which we expect to happen within a few months after your eight week period ends, make sure your presentation/analysis complies with these rules.  If you have any questions, check with qualified legal counsel.  
 
Brody and Associates will continue to closely monitor this issue and keep our readers informed.

The subject matter discussed in this article can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 New Requirement – To Qualify For PPP Loan, It Must Be Necessary!

May 7, 2020

In a Notice released May 3, the SBA added a new requirement for borrowers applying for Payroll Protection Program (“PPP”) Loans; the borrower must certify in good faith that their PPP loan is “necessary in order to support the ongoing operations of the Applicant.” In making this certification the borrower must take into account their current business activity and their ability to access other sources of liquidity sufficient to support their ongoing operations “in a manner that is not detrimental to the business.”
 
The exact form this certification will take is not explained.  The ultimate effect of this certification is difficult to ascertain, but it will certainly vary from business to business. For most businesses that have had major reductions in revenue, we believe this requirement will be simple to satisfy.   For those businesses where COVID-19 has had a minor or no impact on revenue, this is a major challenge.  As with all COVID-19 guidance, more regulations are regularly issued and may change what prior guidance suggested.  If this is an issue for your loan application, please contact Brody and Associates for further information and analysis.

The subject matter discussed in this article can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

SBA Explains Impact On PPP Loan Forgiveness Of Employee’s Refusal To Return To Work

By Robert G. Brody and Mark J. Taglia

May, 10, 2020

Earlier this week, the SBA answered the question: will a borrower’s PPP loan forgiveness be reduced if a laid off employee declines an offer of reinstatement?  The answer is No!
 
The SBA and Treasury intend to issue an interim final rule excluding laid-off employees whom the borrower offered to rehire (for the same salary/wages and same number of hours) from the CARES Act’s loan forgiveness reduction calculation.  To qualify for this exception, “the borrower must have made a good faith, written offer of rehire, and the employee’s rejection of that offer must be documented by the borrower.”  Employers must also advise “employees who reject offers of re-employment [that they] may forfeit eligibility for continued unemployment compensation.”
 
If this is an issue for your business, please contact Brody and Associates for further information and analysis.

The Time to Re-Open is Days Away: You Must Be Ready or Stay Closed!  We Can Help

By Robert G. Brody and Mark J. Taglia

May 14, 2020

Last week, Connecticut’s Governor Ned Lamont announced guidelines for the Phase 1 reopening of certain businesses beginning May 20th.  These business sectors include:

Connecticut is one of the most recent states to put forth their Phase 1 reopening guidelines.  Like most states, the guidelines demand compliance or prohibit reopening.  Brody and Associates has been closely studying these requirements and is here to assist our clients.
 
What might be most striking to employers is the fact that “employees are encouraged to continue to work from home where possible” as it will be extremely difficult for businesses to create a completely safe work environment at this time and work from home remains the safer alternative.  Additionally, the Governor explained businesses DO NOT need to reopen on May 20th just because they are in a covered sector.  This is a choice for each business owner.
 
For those businesses that choose to bring employees back on May 20th, anytime thereafter, and for those businesses already opened, they must following guidelines.  If you have questions about how your business can meet these mandates, Brody and Associates, can help.   The following are some of the guidelines offices must follow if they are opened. 

  1. Provide Personal Protection Equipment (“PPE”) to its employees.  If a company cannot provide PPE’s for its staff it will not be permitted to reopen;
  2. Provide formal training to employees about working in a COVID-19 world (Brody and Associates can help you with this);
  3. Post signs in the office detailing safety protocols and procedures which are to be followed;
  4. Require six feet of distance between work areas with demarcations of these areas;
  5. Limit the use of common areas and meeting rooms as well as the use of shared office equipment.  Can you justify the use of common meeting rooms rather than electronic conferences;
  6. Clean the office prior to reopening, as well as ongoing cleaning requirements of bathrooms and workspace; and
  7. Obtain and post a REOPEN CT badge to verify the business has satisfied the State’s reopening standards.  This self-assessment must be done through Connecticut’s Department of Economic Development.  This on-line service is expected to be available by May 18, 2020.

The State is expected to supplement these initial mandates as time to reopening draws near and possibly thereafter.  Further, we anticipate other states to closely follow the framework outlined in Connecticut’s guidance. 

To help our clients get back to work in a safe and legally compliant manner, Brody and Associates has put together a Back to Business Assessment and Legal Advisory Plan for COVID-19.   Some of the more challenging issues you will possibly face and which the State Guidelines don’t address are outlined below. 

  1. Unfortunately, business conditions may not warrant all employees being brought back to work at this time.  If challenged, Employers will need a legitimate business justification for who was returned and who was not.
  2. For those employees who are not recalled, which unemployment program is best?  Shared Work programs are often the best but they are only available if you apply first.
  3. What do you do if an employee refuses to return to work?  Do you fire him or her?
  4. What accommodations must you give employees due to COVID-19 related issues?

We encourage you to call now to schedule your Back to Business Assessment and Legal Advisory Plan for COVID-19 in anticipation of reopening your business, whether it be in Connecticut, New York, New Jersey or elsewhere.  We are here to help.

The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

SBA Explains “NECESSITY” Provision for PPP Borrowers – But Not Really!

By Robert G. Brody and Mark J. Taglia

May 14, 2020

Two weeks ago, the SBA announced Paycheck Protection Program (“PPP”) borrowers must show “necessity” before they will be allowed to get/keep their PPP loans.  This spawned the question, how will the SBA review borrowers’ required good-faith certification concerning the necessity of their loan request?  Yesterday in a “Release” issued by the SBA we got some guidance and some assurances, but few answers.
 
Answer from the SBA:  Any borrower that, together with its affiliates received PPP loans with an original principal amount of less than $2 million will be deemed to have made the required certification concerning the necessity of the loan request in good faith.
 
Brody and Associates believes this gives blanket protection to borrowers who applied in good faith and without fraud, and who borrowed less than $2,000,000. So, even if your business has lost no revenue due to the COVID-19 pandemic and incurred no increased costs, as long as you believed the loan was necessary, the SBA will not question the necessity of the loan.  Great news for these borrowers but it still leaves necessity undefined. 
 
The Release further provides borrowers with loans greater than $2 million must have an adequate basis for making the required good-faith certification, based on their individual circumstances, but begs the question of what this actually means! The Release is also not clear on what happens if the loan is exactly $2,000,000.  Finally, the Release explains if you can’t show necessity, your loan will be recalled and no forgiveness provided.  Here is exactly what the SBA said;
 
Answer from SBA:  If SBA determines in the course of its review that a borrower lacked an adequate basis for the required certification concerning the necessity of the loan request, SBA will seek repayment of the outstanding PPP loan balance and will inform the lender that the borrower is not eligible for loan forgiveness. 
 
However, if the borrower repays the loan after receiving notification from SBA, SBA will not pursue administrative enforcement or referrals to other agencies based on its determination with respect to the certification concerning necessity of the loan request.  SBA’s determination concerning the certification regarding the necessity of the loan request will not affect SBA’s loan guarantee.
 
If this is an issue for your business, please contact Brody and Associates for further information and analysis.
 
The subject matter discussed in this post can be very technical.  It is an evolving area of law and very fact specific.  Our goal here is to simply alert you to some of the key issues involved.  We urge you to seek competent legal counsel before applying these ideas to your specific situation.  Brody and Associates stands ready to discuss your particular needs.

 

The ABC’s of BPP for your PPP and BBA

By Robert G. Brody and Mark J. Taglia
May 21, 2020

One more result of the COVID pandemic is an outbreak of abbreviations.  Please forgive us as we try to put some levity in the unimagined world we all now face.  

Earlier this year Brody and Associates introduced its Business Preparedness Program (the “BPP”) to its clients.  The BPP helps our clients address the impact COVID-19 has had on their business by offering our services at a significantly reduced rate.  BPP participants can purchase 1 – 2 hours of legal services per month at the rate of $315/hour – a reduction of 47.5% off  our founding member’s standard rate.   We hope this will enable more of our clients to get the assistance they need.

Since its launch, our clients have successfully taken advantage of our BPP and had Brody and Associates help them navigate through the complicated and contradictory Paycheck Protection Program (the “PPP”).  We have helped calculate loan amounts, forgiveness strategies, and adjust headcount through reductions in force utilizing shared work programs and partial unemployment benefits.  We have also created a system to track and manage PPP expenses to maximize loan forgiveness and prepare for potential U.S. Treasury, SBA and/or Bank Audits.

Our clients have found the BPP an excellent complement to their PPP loans and we are glad we can help. To that point, we are pleased to announce we are continuing to offer the BPP through the end of this year as our clients continue to suffer from the financial impacts of COVID-19.

Finally, as we have guided our clients through the PPP process and the painful impact COVID-19 has on their businesses, we have come across many common themes and challenges.  This has led us to formalize what we have learned in our Back to Business Assessment and Legal Advisory Plan (the “Back to Business Assessment” or “BBA”).

The BBA is a program designed to evaluate a client’s current situation in order to make meaningful recommendations on how they can reopen their business in a legally compliant and cost effective manner while avoiding any personnel pitfalls.  As you re-engage your teams, the Back to Business Assessment can also help you make sure you are bringing back the right folks at the right time.

These programs are additional ways we hope to give our clients a place to turn in these challenging times.  Together we can navigate these constantly changing laws and chart a successful course to the other side of this pandemic while providing some peace of mind.    

Please contact us if you are interested in participating in one or both of these programs or if we can help you in any other way.  Stay safe and thank you.

 

INTERVIEWS/SEMINARS

Fairfield and Hartford County Medical Associations

       On March 27, 2020, Brody and Associates participated in a Zoom conference on Unemployment Laws and Benefits to the Fairfield County Medical Association and Hartford County Medical Association.  Click here to listen to the webinar.  

LCM247 

       On April 3, 2020 Brody and Associates was interviewed regarding Covid-19 and its impact on small business.  Click here to listen to the interview.

 

LINKS TO PRIMARY SOURCES ON COVID-19

Department Of Labor

Families First Coronavirus Response Act (FFCRA) 

Questions about the FFCRA 

Connecticut Department of Labor

New Amendment to Mandatory Connecticut Unemployment Form

State of Connecticut’s Coronavirus Resources

       New Amendment to Connecticut Unemployment 

Safe Workplace Rules for Essential Employers

Governor Lamont Releases Rules for Businesses Under First Phase of Connecticut’s Reopening Plans Amid COVID-19

Primary Sources

Centers for Disease Control and Prevention (CDC) 

      How to Protect Yourself and Others

National Institutes of Health (NIH) 

      Coronavirus (Covid-19) News and Information

Occupational Safety and Health Administration (OSHA)

      Coronavirus Resources

      Guidance on Preparing Workplaces for Covid-19

World Health Organization (WHO)

       Q&A on Coronaviruses (Covid-19)

Federal Sources

Federal Legislation

       Families First Coronavirus Response Act (FFCRA)

       FAQ’s about the FFCRA 

       The Coronavirus Aid, Relief, and Economic Security (CARES) Act

       Paycheck Protection Program (PPP)

       U.S.  EEOC – “What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws