implementation of the Families First Coronavirus Response Act

From the AVMA Government Relations –

Here are links to information on the implementation of the Families First Coronavirus Response Act.  More information will be coming from the IRS and Dept. of Labor quickly.

www.dol.gov/newsroom/releases/osec/osec20200320

DOL press release describing the Families First Coronavirus Response Act.  Indicates that guidance and emergency rules will be coming this week.

www.irs.gov/newsroom/…

IRS press release describing the Families First Coronavirus Response Act.  Provides some information and indicates guidance and emergency rules coming this week.  Excerpts from the web page:

Prompt Payment for the Cost of Providing Leave

When employers pay their employees, they are required to withhold from their employees’ paychecks federal income taxes and the employees’ share of Social Security and Medicare taxes. The employers then are required to deposit these federal taxes, along with their share of Social Security and Medicare taxes, with the IRS and file quarterly payroll tax returns (Form 941 series) with the IRS.

Under guidance that will be released next week, 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 IRS.

The payroll taxes that are available for retention include withheld federal income 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.

If there are not sufficient payroll taxes to cover the cost of qualified sick and child care leave paid, employers will be able file a request for an accelerated payment from the IRS. The IRS expects to process these requests in two weeks or less. The details of this new, expedited procedure will be announced next week.

 

Examples

If an eligible employer paid $5,000 in sick leave and is otherwise required to deposit $8,000 in payroll taxes, including taxes withheld from all its employees, the employer could use up to $5,000 of the $8,000 of taxes it was going to deposit for making qualified leave payments. The employer would only be required under the law to deposit the remaining $3,000 on its next regular deposit date.

If an eligible employer paid $10,000 in sick leave and was required to deposit $8,000 in taxes, the employer could use the entire $8,000 of taxes in order to make qualified leave payments and file a request for an accelerated credit for the remaining $2,000.

Equivalent child care leave and sick leave credit amounts are available to self-employed individuals under similar circumstances. These credits will be claimed on their income tax return and will reduce estimated tax payments.

 

Small Business Exemption

Small businesses with fewer than 50 employees will be eligible for an exemption from the leave requirements relating to school closings or child care unavailability where the requirements would jeopardize the ability of the business to continue. The exemption will be available on the basis of simple and clear criteria that make it available in circumstances involving jeopardy to the viability of an employer’s business as a going concern. Labor will provide emergency guidance and rulemaking to clearly articulate this standard.

 

Non-Enforcement Period

Labor will be issuing a temporary non-enforcement policy that provides a period of time for employers to come into compliance with the Act. Under this policy, Labor will not bring an enforcement action against any employer for violations of the Act so long as the employer has acted reasonably and in good faith to comply with the Act. Labor will instead focus on compliance assistance during the 30-day period.

Sources on shortages of both drugs and medical products

COVID-19 Resources

For resources on COVID-19 related to veterinary medicine:

  • AVMA  AVMA COVID-19 includes information on COVID-19 origin and spread, COVID-19 in humans, Coronavirus and domestic animals, keeping veterinary teams healthy, links to telemedicine resources, supply chain impacts, financial relief legislation, and more.
  • FAQs  COVID-19 FAQs for Veterinarians and Veterinary Clinics and COVID-19 FAQs for Pet Owners are available on the AVMA COVID-19 website as downloadable PDFs, and are also included below.
  • Pet Exposure  If you encounter a pet that has been in close contact with a COVID-19 patient, please see AVMA COVID-19 for guidelines on handling precautions. 

AVMA COVID-19 Update

Your AVMA is actively engaged on COVID-19 and its potential impacts on veterinary medicine. Our goal is to support you with relevant information in this fast-evolving situation. We are in regular contact with the U.S. Centers for Disease Control and Prevention (CDC), the U.S. Food and Drug Administration (FDA), veterinary medical experts, and international agencies to gain the latest resources and intel on the disease and its causative virus (SARS-CoV-2) for you and your clients.We’ve gathered information important to veterinary professionals at avma.org/Coronavirus and will continue to provide you with regular updates there and on the AVMA@Work blog as soon as they become available. We are also sharing updates on all our social media platforms. You can subscribe to the blog and follow our social media pages for breaking updates.

Coronavirus: What we know as it relates to pets

We are actively monitoring developments related to animals and the virus. On Thursday, February 27, a dog in Hong Kong tested “weak positive” for coronavirus (the owner tested positive for coronavirus). The dog has since received a second positive result that has been sent to the World Organization for Animal Health (OIE), which is working with Hong Kong health officials on this case. The precise meaning of “weak positive” remains unclear and further evaluation is ongoing. Hong Kong authorities have said the dog shows no clinical signs of illness but remains quarantined. We will keep you updated as we learn more.

At this time, the U.S. Centers for Disease Control and Prevention (CDC) and the World Health Organization (WHO) say there is no evidence that companion animals, including pets, can spread COVID-19. However, as with any disease, it’s always a good idea to wash your hands after being around animals.

According to the CDC, people who are sick with COVID-19 should restrict contact with pets and other animals, just like you would restrict your contact with other people. When possible, a member of the household other than the individual who is ill should care for any animals in the household. Those infected with COVID-19 should avoid contact with animals, including petting, snuggling, being kissed or licked, and sharing food. Those who must care for a pet, or who will be around animals while sick, should wear an appropriate facemask and wash hands thoroughly before and after interacting with those animals.

Potential Shortages of Drugs and Medical Supplies

The AVMA is also concerned about potential medical supply chain issues, including both pharmaceuticals (specifically active pharmaceutical ingredients [APIs]) and medical products, such as personal protective equipment. We have learned from FDA that there are 32 animal drug firms that make finished drugs or source active pharmaceutical ingredients in China for the United States market. The FDA has contacted all 32 firms and no shortages have been reported at this time. However, six of those firms have indicated that they are seeing disruptions in the supply chain that soon could lead to shortages. The FDA is working with these firms to help identify interventions to mitigate potential shortages. FDA has done similar work on the medical product/device side. An FDA webpage has been created through which the FDA is sharing information around the availability of drugs and medical supplies. Because veterinarians use a substantial number of FDA-approved human drugs under federal extralabel drug use statute and regulations, shortages on the human side will be felt by veterinary medicine as well. The AVMA’s concern and our work on behalf of the veterinary profession thereby touches both markets.

AVMA is in close communication with FDA and is supporting its efforts by gathering information about drug needs (from both the animal and human markets) and any related concerns from veterinarians, practices/practice groups, and veterinary distributors. Veterinarians are encouraged to send information regarding any supply chain issues of concern to the AVMA at coronavirus@avma.org. Detailed information on the product of concern and the manufacturer/distributor of that product will be most helpful.

Prevention tips you can implementThere is currently no vaccine to prevent COVID-19. The best way to prevent illness is to avoid being exposed to the virus and to follow strict handwashing and other hygiene protocols.

  • Designate your practice/workplace as a temporary NO HANDSHAKE ZONE. Ask colleagues and clients to refrain from shaking hands (fist bumps or forearm bumps are good substitutes).
  • Practice good hygiene: Wash hands often with soap and water for at least 20 seconds, especially after using the restroom; before eating; after blowing your nose, coughing, or sneezing; and between client/patient visits.
  • If soap and water are not readily available, use an alcohol-based hand sanitizer with 60%-95% alcohol.
  • Place hand sanitizer, sanitizing wipes, and tissues in all exam rooms, meeting rooms, restrooms, break rooms, and other common areas.
  • Avoid touching your eyes, nose, and mouth with unwashed hands.
  • Cough or sneeze into your elbow or use a tissue to cover your nose and mouth, then throw the tissue into the trash can.
  • COVID-19 symptoms are similar to those of influenza (e.g., fever, cough, and shortness of breath), and the current outbreak is occurring during a time of year when respiratory illnesses from influenza and other viruses, including other coronaviruses that cause the common cold, are highly prevalent. To prevent influenza and possible unnecessary evaluation for COVID-19, all persons more than 6 months old should receive an annual influenza vaccine. Vaccines are still available and effective in helping to prevent influenza.
  • Voluntary home isolation: If you are ill with symptoms of respiratory disease, such as fever, cough, shortness of breath, sore throat, runny or stuffy nose, body aches, headache, chills or fatigue, stay at home. The CDC recommends that you remain at home until at least 24 hours after you are free of fever (100 degrees F or 37.8 degrees C) or signs of a fever without the use of fever-reducing medications.
  • Take steps to prevent the spread of disease among veterinary personnel and to/from clients by following guidelines and procedures laid out in the National Association of State Public Health Veterinarian’s Compendium of Veterinary Standard Precautions for Zoonotic Disease Prevention in Veterinary Personnel. While the primary focus of this resource is controlling the spread of pathogens between animals and veterinary personnel, many of its principles apply to infection control in general and following it is simply good practice.

We want to emphasize that we’re here for you. We are working with all of the relevant agencies and key stakeholders to be your source of veterinary-related information so that you can make the best decisions for your practice, your employees, your clients, and your patients. If you have any questions regarding how the AVMA Trust may be able to help you or your practices, visit www.AVMAPLIT.com or call 800-228-7548.

Please check back in with us on the AVMA website or follow our social media channels, where we will continue to share the latest developments regarding COVID-19.

John Howe, DVM
John Howe, DVM
President, American Veterinary Medical Association
Rena Carlson-Lammers, DVM
Rena Carlson-Lammers, DVM
Chair, Board of Directors, American Veterinary Medical Association
Janet D. Donlin, DVM, CAE
Janet D. Donlin, DVM, CAE
Chief Executive Officer, American Veterinary Medical Association
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