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PBM Operational Update

04/7/2020
To conform with current guidance about “social distancing” during the next two weeks, we are making some changes and we want to update you.
 
  • Beginning tomorrow, April 8, 2020, most PBM staff will be working remotely. Our lines of communication remain open. You will still be able to contact us via email, your web portal, the U.S. Mail, and through our phone system.
 
  • When you call our office, our system will prompt you to leave a voicemail. We will retrieve and route these to the appropriate staff member throughout the day; at least once each ½ hour.
 
  • Our U.S. Mail is delivered to a secure post office box within our local post office facility. We will continue to retrieve it each business day.
 
  • Because we may be unable to sign for Federal Express and UPS deliveries, we recommend that you use the U.S. Mail express delivery services for all expedited or oversized packages.
 
  • We will continue to provide payroll, tax, accounting, and consulting support services just as we have been during the last several weeks.
 

 

  • We do not expect to make physical client visits in April. Instead, we will be scheduling virtual visits using the “Go To Meeting” and our conference calling platforms. We will be giving you direction about these as our vision takes shape.
 
 
 
PPP LOAN UPDATE
Another day, and more guidance received. Overnight the U.S. Treasury issued a 6-page document with F.A.Q.’s regarding the Paycheck Protection Program:
 
 
Several relevant “takeaways” from our perspective:
 
• Accurate information is the responsibility of the borrower. The lender must do due diligence to verify the information. If errors in calculation, the lender should remedy the error with the borrower.
 
• The borrower has to determine all its affiliate entities (over 50% ownership) and do total FTE headcount and notify the lender of this affiliate relationship.
 
• PPP covers payroll for vacation, medical and sick leave. However, if you get tax credits as a result of paid sick leave or the Expanded FMLA benefits contained in the Families First Coronavirus Response Act (“FFCRA”), these payroll amounts will be excluded from calculations relating to the PPP.
 
• A single signature on a PPP application for the entire business is OK from the designated “authorized representative” of the business.
 
• Borrowers can calculate aggregate payroll costs from either the previous 12 months or calendar year 2019. It seems whichever they chose is acceptable.
 
• Employer Social Security and Medicare taxes (“FICA” taxes) are not included in “Gross Monthly Wages” Calculation. However, if the application has already been submitted it is OK to rely on the guidance available at the time of application to submit a proper application. If the application has not been filed as of yet the application should be revised to exclude EMPLOYER FICA taxes.
 
• It does imply that we continue to include state unemployment tax with the calculations of “Gross Monthly Payroll”.
 
Please reach out to your consultant with any questions. Thank you in advance for your patience and understanding as we all are working to get through these times together.
 

 

We leave you with a quote by the famous former coach of UCLA basketball John Wooden:

 

“Things turn out best for the people who make the best of the way things turn out”
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