​Is Your Organization Tracking Wages Correctly for the CARES Act?

Organizations that received CARES Act funding — like healthcare facilities, schools, and nonprofits — have to make sure their documentation for employee wages all agrees.

The federal government’s goal of this documentation is to make sure there are processes in place so that organizations are spending CARES Act money appropriately.

For example, let’s say your organization is a nursing home. You have an hourly employee that spent 30% of their time caring for patients with the coronavirus and 70% on administrative tasks last month.

Not only does that person’s timesheet need to reflect the proper coding for all of their tasks, but every month, that employee and their supervisor need to complete and sign a Personal Activity Report. You can download a Personal Activity Report we created here.

That Personal Activity Report and the employee’s timesheet will need to match the breakdown of time the employee spent handling COVID-related tasks and all other duties.

For salaried employees, your organization will need to complete the Personal Activity Report at least twice a year. However, we recommend that you complete the documentation monthly regardless because it will ensure you’re complying with the CARES Act’s rules.

All documentation regarding wages must match, whether that’s timesheets, Personal Activity Reports, or employee contracts.

Under the rules, you are allowed to budget your employees’ time. For instance, you could say you expect one employee to spend 20% of their time on COVID-related tasks and the remaining 80% on other duties. Or you can track all of their tasks in real time.

Regardless, each employee and their supervisor will need to sign off on the Personal Activity Report monthly, and all the wage-tracking documentation must agree. You are allowed to adjust employee time reporting after the fact as well.

Right now, these documentation requirements are expected to last through the end of 2020. But the requirements may be extended, or additional guidance may come out later.

We will continue to monitor these requirements and let you know if anything changes.

In the meantime, if you have questions about employee wage reporting or documentation, please reach out to us. We also offer tools and assistance for Payroll Based Journaling — or PBJ.

This communication is intended to provide general information on legislative COVID-19 relief measures as of the date of this communication and may reference information from reputable sources. Although our firm has made every reasonable effort to ensure that the information provided is accurate, we make no warranties, expressed or implied, on the information provided. As legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that may modify some of the provisions in this communication. Some of those modifications may be significant. As such, be aware that this is not a comprehensive analysis of the subject matter covered and is not intended to provide specific recommendations to you or your business with respect to the matters addressed.