(from the Society of Human Resources Management) Some employers, particularly smaller ones, have been surprised by the new requirement to report wages paid for leave taken under the Families First Coronavirus Response Act (FFCRA) on employees' W-2 forms. But W-2s, which must be provided to employees by Jan. 31, can be corrected if they've already been issued. The reporting instructions were contained in IRS Notice 2020-54, issued last July, but not detailed in the Form W-2 instructions, "likely due to the short-term nature of the program," said , said Robert Delgado, principal-in-charge of compensation and benefits with KPMG.
The IRS has issued specific guidance on how employers are expected to report wages paid for emergency paid sick leave and emergency paid Family and Medical Leave Act time off under the FFCRA. Pay for either type of FFCRA wages should be reported separately from regular wages, on Box 14 of the W-2, or on a separate statement provided concurrently with the regular W-2, according to this guidance. There is some disagreement whether employers that are not claiming the FFCRA tax credit for providing sick-leave wages have to report the wages on employees' W-2s.
Schools that have elected to voluntarily extend FFCRA leave into 2021 will need to include wages paid under the leave on 2021 W2s as well.
More from the Society for Human Resources Management
Related content: FFCRA Leave Extensions (webinar recording), Leave Considerations Tool (NBOA resource)
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