VOLUNTARY FRINGE BENEFIT CONTRIBUTIONS FOR WAGES PAID UNDER
THE PAYCHECK PROTECTION PROGRAM

Many contributing employers have inquired about the ability to make fringe benefit contributions on the basis of hours paid but not worked by employees, such as for payroll and fringe benefit contributions available through Paycheck Protection Program (“PPP”) loans. The Boards of Trustees of the Funds have decided to permit contributing employers to voluntarily make fringe benefit contributions on behalf of employees for hours paid but not worked through June 30, 2020, subject to the following rules:

  1. Fringe benefit contributions must be submitted on behalf of all covered employees receiving wages. An employer cannot pay wages and fringe benefit contributions for some covered employees and only wages to other covered employees.
  1. The employer must pay the full fringe benefit package (Pension, Welfare, Training and all ancillary fund contributions) for each hour reported to the Funds and the District Council.
  1. The employer must pay the hourly wage rate required under the terms of the applicable collective bargaining agreement and remit the fringe benefit contributions rate for each hour paid.

The ability to voluntarily make fringe benefit contributions for hours paid but not worked is available to all contributing employers regardless of whether they have obtained a PPP loan and is applicable only to hours paid through June 30, 2020.

This information is provided solely for the general interest of contributing employers and should not be relied upon or construed as legal advice. Each employer should consult its own professional advisors to determine the impact of the recent legislation, including the FFCRA and the PPP, on its business operations, financial implications and its required actions.