4.07: COVID-19 and Reporting

4.07: COVID-19 and Reporting

The following guidance is provided regarding COVID-19 and reporting:

Hazard Pay
Hazard pay is considered reportable compensation if all of the following criteria are met:

• The payment is compensation within the time period of March 10, 2020 through June 30, 2021.
• The payment is offered district-wide to entire categories of employees (i.e. teachers, bus drivers, etc.).
• The payment is specifically documented regarding what was done to earn the payment and includes at least one of the following:
  • Additional duties above and beyond regular or contracted duties (for more information on additional duties, see 4.04: Special situations) there.
  • Exposure to increased risk of contracting COVID-19 due to in-person activities.

The payment must be reported on a DTL2 and a DTL4 record (when a DTL4 is required). When reporting this payment on a DTL2 record, please use the Supplemental Employment 9510, 9520, or 9530 class codes.

Document the additional duties fully. Reporting units must provide this information timely to ORS for review if requested. If a contracted employee is performing duties outside his/her regular job and receiving hazard pay the hazard pay would be reportable as long as it meets the criteria listed above.

If the payment does not meet all of the criteria above, it is considered nonreportable and must be reported on a DTL4 (only) when a DTL4 is required.

Employees Repurposed to Alternate Duties
For employees who are unable to perform their regular duties due to COVID-19 and are repurposed to alternate duties, please do not report more than their contracted hours and wages.  If an employee is working from home performing the same duties as if they were in the office those wages and hours are reportable. Please follow these examples:

Full-time employee:

Part-time employee: 

 Payment for work not performed
Payment for work not performed was reportable on a DTL2 record and DTL4 record (when a DTL4 is required) from March 10, 2020 until Sept. 30, 2020, when Executive Order No. 2020-142 (COVID-19) expired. After that date, these payments are nonreportable, so report wages paid for work not performed on a DTL4 record only (when a DTL4 is required) after Sept 30, 2020.  ORS will take the certification on report submission that wages and hours are not being reported if work is not being performed.

Examples include but are not limited to:

• Employees unable to work full schedule due to COVID-19, such as bus drivers with reduced/suspended routes, paraprofessionals when in-person classes are suspended, etc.
• Employees who are "on-call" -- only report wages for work performed. Do not report wages for time spent on-call without working.

Leave Pay
Leave pay is fully reportable (on both DTL2 and DTL4 records) through March 31, 2021, per the federal Families First Coronavirus Response Act: Employee Paid Leave Rights and the optional extension per the federal Consolidated Appropriations Act (CAA), 2021. In addition to vacation, sick, and administrative leave (which are already reportable), for the 2020-2021 school fiscal year, any documented, district-approved leave is reportable. Leave must be approved by your school board before the end of the 2020-2021 school fiscal year. It can be approved retroactively to the beginning of the 2020-2021 school fiscal year.

Retirees
If a retiree is receiving any of the payments mentioned in this article, the normal rules for reporting retiree earnings apply. See RIM 9.01: Earnings of Retirees Who Return to Work for more information.

COVID-19 Timeline of events

March 16, 2020: ORS sent employers an email: Retirement reporting and the statewide closure of all K-12 school buildings, which stated:

Governor Whitmer announced statewide closure of all K-12 school buildings from Monday, March 16 through Sunday, April 5. It has been decided that members will still receive retirement credit during this time. Continue to report and make payments to ORS as usual according to your pay schedule.

March 18, 2020: MPSERS Employer News — March 2020 reiterated the information in the previous email.

April 16, 2020: MPSERS Employer News — April 2020:

• ORS gave a summary of the issue and provided links to federal information about the Families First Coronavirus Response Act (FFCRA): the U.S. Department of Labor’s FFCRA website or read its fact sheet for employers: Families First Coronavirus Response Act: Employer Paid Leave Requirements.
• ORS stated the following:
  • Hazard pay will be reviewed on a case-by-case basis and will require documentation.
  • Unemployment benefits are nonreportable.
  • If an employee is off work and still being paid regularly, in accordance with Executive Order No. 2020-35, wages and hours should still be reported when paid.

Sept. 16, 2020: MPSERS Employer News — September 2020:

• Executive Orders set to expire September 30, 2020. This affects employees that are unable to work their full schedule and employees receiving hazard pay. See the newsletter for details.
• Leave payments for approved COVID-19 leaves are set to expire Dec. 31, 2020. See Families First Coronavirus Response Act: Employee Paid Leave Rights for details.

Oct. 21, 2020: MPSERS Employer News — October 2020 reiterated expiration dates detailed in September issue of the newsletter.

Nov. 19, 2020: MPSERS Employer News — November 2020 further defined hazard pay.  See the November issue of the newsletter for details.

Jan. 20, 2021: MPSERS Employer News — January 2021 gave notice of FFCRA Leave extensions due to CAA, 2021. See the January issue of the newsletter for details.

(Last updated: 01/20/2021)