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The Families First Corona Response Act (FFCRA) and Coronavirus Aid, Relief and Economic Security (CARES) Employer Payroll Changes

++New Updates++

June 22nd – The following SAP Note has been released:

2939028BEN: Health Flexible Spending Account Carryover amount and Grace Period Changes for 2020

June 19th – The following SAP Note has been released:

2932996BEN: COBRA Administration Outbreak Period 2020

June 1st – The following SAP Note has been released:

2930118TAX: Social Security Deferral not Considering Social Security Year-to-Date Amounts

May 18thThe following SAP Note has been released:

2924659 BEN: COBRA General Notice and Election Notice Forms for Year 2020

May 12th – The following SAP Note has been released:

2922945 –  COVID-19 US Wage Garnishment Student Loan: Mass Change Between Active and Pending Statuses

We are all living a very critical moment during this COVID-19 outbreak, and unfortunately, this is also affecting many employees and businesses in the USA. In these unprecedented times, employers have to absorb information quickly and make decisions impacting their business and human resources. The business landscape is evolving rapidly as federal, state, and local authorities announce action plans.
This blog was designed to provide general guidance in the SAP system changes related to the COVID-19 and the tax implications on the CARES and FFCRA legal changes.
In this blog post, we will discuss the following topics:

  • New Tax Types for Families First Coronavirus Response Act (FFCRA)
  • New Tax Types for Coronavirus Aid, Relief, and Economic Security (CARES) Act – Employer Tax Credits and Deferrals
  • How to use the new tax types in payroll
  • Changes in SAP system.
  • SAP Notes that must be implemented.

For additional reading, see this blog with centralized Announcements for country/local versions.

New Tax Types for Families First Coronavirus Response Act (FFCRA)

  • 200 ER Individual PSL Credit
  • 201 ER Family PSL Credit
  • 202 ER Extended PFML Credit
  • 571 ER Medicare Leave Cred – Ind. Leave
  • 572 ER Medicare Leave Cred – Fam. Leave
  • 573 ER Medicare Leave Credit -Exp. PFML
  • 574 ER Social Sec Leave Cred -Ind Leave
  • 575 ER Social Sec Leave Cred -Fam Leave
  • 576 ER Social Sec Leave Cred -Exp. PFML

New Tax Types for Coronavirus Aid, Relief, and Economic Security (CARES) – Act – Employer Tax Credits and Deferrals

  • 204 ER Employee Retention Credit
  • 004 Employer Social Security Tax (already available in the standard delivery but required to be used in combination)
  • 577 ER SocSecTax Pmt Deferral-SocSecTax

 

  • 057 Employer Railroad Rtmt Tier1 Soc S (already available in the standard delivery but required to be used in combination)
  • 578 ER SocSecTax Pmt Deferral-RailRtmt1

 

  • 058 Employer Railroad Rtmt Tier2 Soc S (already available in the standard delivery but required to be used in combination)
  • 579 ER SocSecTax Pmt Deferral-RailRtmt2

 

How to use the new tax types in payroll

Eligible employers who pay qualifying sick or child care leave will be able to retain an amount of the payroll taxes equal to the amount of qualifying sick and child care leave that they paid, rather than deposit them with the government.

Some of the payroll taxes that are available for retention include Federal Withholding taxes, the employee share of Social Security and Medicare taxes, and the employer share of Social Security and Medicare taxes with respect to all employees.

Therefore, the new tax types are not to be taxed as regular wages, but are refundable tax credits or tax that can be deferred for the cost of providing the required paid and medical leave to employees.

Changes in SAP system

To use these new tax types, you’ll need them to your taxability model.

Calculation of the COVID19 Families First Coronavirus Response Act: Employee Paid Leave Rights and Employer Credits:

1- For the wage types related to the paid leave of the first 10 days of an employee with own COVID-19 condition, assign the following Tax Types to its tax model:

  • 200 Employer Individual PSL Credit
  • 571 ER Medicare Leave Cred – Ind. Leave
  • 574 ER Social Sec Leave Cred -Ind Leave

These tax types ceilings are USD 5,110.00

2- For the wage types related the paid leave of the first 10 days of an employee with dependent COVID-19 condition or who had care for a child with a school/daycare COVID-19 closure, assign the following tax types to its tax model:

  • 201 Employer Family PSL Credit
  • 572 ER Medicare Leave Cred – Fam. Leave
  • 575 ER Social Sec Leave Cred -Fam Leave

These tax types ceilings are USD 2,000.00

3- For the wage types related to the paid leave over 10 days for employees who had to care for a child with a school/daycare COVID-19 closure, assign the following Tax Types to its tax model:

  • 202 Employer Expanded PFML Credit
  • 573 ER Medicare Leave Credit -Exp. PFML
  • 576 ER Social Sec Leave Cred -Exp. PFML

These tax types ceilings are USD 10,000.00

Calculation of the Coronavirus Aid, Relief, and Economic Security (CARES) Act provides Employer Tax Credits:

1- For the wage types related to any wage that is subject of the Employee Retention Credit for eligible employers, assign the following Tax Type to its tax model:

  • 204 Employer Employee Retention credit

This tax type ceiling is USD 10,000.00

2- For the wage types corresponding to any wage that is subject of Employer Social Security Tax Payment Deferral, assign the following Tax Type to its tax model:

  • 577 ER SocSecTax Pmt Deferral-SocSecTax

This tax type ceiling is USD 137,700.00

3- For the wage types corresponding to any wage that is subject of Employer Social Security Tax Deferral Railroad Tier 1, assign the following Tax Type to its tax model:

  • 578 ER SocSecTax Pmt Deferral-RailRtmt1

This tax type ceiling is USD 137,700.00

4- For the wage types corresponding to any wage that is subject of Employer Social Security Tax Deferral Railroad Tier 2, assign the following Tax Type to its tax model:

  • 579 ER SocSecTax Pmt Deferral-RailRtmt2

This tax type ceiling is USD 102,300.00

 

SAP Notes that must be implemented

2917910BSI: FFCRA and CARES act (tax types 200 – 206)

2922945 –  COVID-19 US Wage Garnishment Student Loan: Mass Change Between Active and Pending Statuses

2924659 BEN: COBRA General Notice and Election Notice Forms for Year 2020

2930118TAX: Social Security Deferral not Considering Social Security Year-to-Date Amounts

2932996BEN: COBRA Administration Outbreak Period 2020

2939028BEN: Health Flexible Spending Account Carryover amount and Grace Period Changes for 2020

 

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Stay safe and happy reading!

Virginia

User Assistance Developer

18 Comments
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  • Hi Virginia,

    We implemented the note 2917910 in our system. Per the attached manual instructions, I tried to create entries in the table T5UTT. I was able to create Tax types 200-204. For the remaining tax types starting from 571, I get an error that it is not valid.

    Can you please help suggest what am I missing here?

    Thanks

     

    Baburaj S Avanathan

    614.397.9132

    • Hi Baburaj Avanathan ,

      The manual steps must be installed after implementing correction instructions.
      Then, after correction instructions you may be able to create the other tax types.
      Have you followed these steps?
      Thanks
      Virginia

       

      • HI Virginia,

        I am working for a customer with multiple legal entities. a few of them have less than 500 employees, so this above changes are definitely applicable. There are a couple of legal entities with more than 500 employees. Per the legal requirement, these tax credits are only for those companies with less than 500 employees. How do we ensure that we restrict this to only applicable companies?

        Using T5UTI it is not possible, the tax models would be requiring the tax types to be available in T5UTI, if we simply restrict the tax types per company there would be errors in the payroll run. The only way I can think of is using the tax modifier and groupings and then use those modifiers to distinguish the companies. That approach would result in quite a good amount of work.

        What are the dis-advantage of generating theses new tax types for all companies? How is it going to impact in reporting? Are there any legal reporting that these wage types / tax types would be included within? Do we even know about it now?

        Appreciate your answers

         

        thanks

        Baburaj S Avanathan

        614.397.9132

        • Hi Baburaj Avanathan ,

          From your question on how to distinguish the companies:
          The way you described is the one intended within the tax model architecture.

          You could also use different wage types – one set of wage types eligible for FFCRA and CARES while another set that’s not eligible. It can be controlled via PCL 71.

          As for having all the tax types available, these tax types are to be used in 3PR to either offset the taxes being paid or to replace the ones that are being deferred. So, you wouldn’t have any direct impacts. However, you would need to choose how to handle these “extra” wage types and how to filter the ones that are applicable from the ones that aren’t.

          For the reporting question, I’ll keep you informed, as SAP is still evaluating it. For more details, you can check the following Announcement on SAP Launchpad

          https://launchpad.support.sap.com/#/legalchangenotification/NoteInforSet/jira=GSREQAMER-714/TwoColumnsMidExpanded/0

          Hope it helps.

          Thanks,

          Virginia

  • Thanks Virginia, we were able to successfully implement the changes associated with this note 2917910. We had some trouble implementing one of the pre-requisite note (2877736) that had function module HR_PL_D_PC22T as object locked.

    We then referred to the SAP Note 151354 to unlock the object  HR_PL_D_PC22T.

    After that we implemented the corrections delivered in the SAP note 2917910, then I was able to make the entries for the new tax types.

    Thanks very much

    Baburaj S Avanathan

     

  • Virginia,

    We have implemented note 2917910 and made manual configurations indicated. When running current payroll simulation for an employee who has already capped on Social Security(/404) earlier in the year the new wage type /4KG is still generating. We were not expecting /4KG to generate. Can you let me know if this is a bug in the changes made for RPCALCU0 by the note. if not, can you please explain.

    Thanks

    Gene

      • In addition to the max limits not hitting at the same time, this is also causing penny differences in rounding back from BSI since the 206 year to date amounts are different than the 004 and 057 year to date amounts being sent to BSI.

         

        Thanks,
        Jill

      • Hi Virginia,

        The new note 2930118 resolved the capping of the Social Security deferral wage type /4KG but did not address the railroad tier1 deferral wage type /4KH.  Can a note be released to fix all the new deferral wage types that have a cap?

        Thanks,

        Jill

    • Virginia,

      How does SAP recommend the handling of the 3rd party when the goal is to off-set the original balance sheet account and redirect to a new balance sheet account?

      Thanks and Regards

       

      Gene

      • Hi Gene Davis

        It’s important to mention that SAP does not provide an official handling of the 3rd party. I’d suggest you to check with other consultants how it was implemented in the forum. There is an option that might work. Testing is required, though.

        It all depends upon what you (and Finance departments) want to do to handle the deferral. You may want to try using a customer wage type to offset the /404 postings (GL and/or Vendor) since there is not date delimitation in the HR Payee assignment.  Ex. Copy the amount from /404 into a customer wage type in a payroll rule, post that wage type as offsets to the /404 in the GL and/or 3PR.

        That way you don’t have to change the /404 posting & 3PR settings for a temporary situation and you can put date delimitation around the rule itself so it only processes while the deferral is valid.  You can then use a new HR Payee for the customer wage type and set up a different Remittance Rule for the new HR Payee – ex. End of Year + 365 day grace period would get you to 12/31/2021 (may need FI to adjust later for the 50% that is due 12/31/2022, once you know what the total amount is).

        Regards,

        Virginia

        • Hi Virginia,

           

          I am a tad confused now from your comment. Why would we create a custom wage type , As a company we are looking at utilizing example 2 in the note with the assumption that the /4KG was the offset the /404 but when I read your comment it almost sounds like it is not? IF I read it correctly what is the purpose of the /4KG then? The note also describes changing processing classes 72 and 73 on the 4KG which is supposed to allow 3rd party remittance to post for HR Payees with the opposite sign. However, with the wage type posting set up there would be no need to change the processing classes as we can control the sign in wage type posting maintenance.

           

          Forgive my ignorance but I thought I understood what would happen until I finished the manual updates and started testing. I don’t technically want you to tell me how to configure this but further clarification on the implementing the /4KG etc. wage types would be helpful.

          Regards,

          Lena

  • Hello Virginia,

    I have the following questions:

    1. Can you please point me to the legal requirement that the Tax Types 574, 575 and 576 must be calculated even though the Employees YTD Social Security earnings have met the limit of 137,700.00 USD? I have an example below.

    FFCRA%20-%20SAP%20Tax%20Log

    FFCRA – SAP Tax Log

     

    2. The department of labor indicates in their bulletin that FOR Employer CREDITS there should be a daily limit of 511 USD (up to a maximum of 5110.00 USD for 2 weeks) for the EPSLA related payments and 200 USD (Up to a maximum of 10000.00 USD for 10 weeks) for EFMLA related payments.

    Did the solution delivered by SAP with the note 2917910BSI: FFCRA and CARES act (tax types 200 – 206) have a daily limit associated with it? Based on the example screen shot above, it does not appear so. Are we missing something?

     

    Please help clarify,

    Many thanks,

    Baburaj S Avanathan

    /
    FFCRA%20-%20SAP%20Tax%20Log
  • Hello Virginia,

    We applied Notes  2917910 and Note 2930118 and have successfully completed all the required manual entries. After this we are noticing that all tables with tax type fields are all displaying two digit tax codes instead of the three digits. For example, when I browse T5UTT, T5UTD in SE16, I see the two digit tax codes. Is this a side effect for this note ? Is there a correction for this ? Please advise. Thanks.

     

    /
    • Just learnt that this is because of a setting on the user parameter.  Settings ==> User Parameter ==>  Data Browser. You need to have the Consider Conversion Exit checked.