UI letters discuss additional payments and other broad relief available under CARES Act
Monday, April 20, 2020

UI letters discuss additional payments and other broad relief available under CARES Act

By Payroll and Entitlements Editorial Staff

The Department of Labor has separately released a pair of unemployment insurance guidance letters that flesh out more of the relief available under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) that was signed into law on March 27, 2020. The full text of these UIPLs will appear in next week’s Report.

Unemployment Insurance Program Letter (UIPL) 15-20 provides guidance on how states will administer an additional $600 weekly payment to certain eligible individuals who are receiving other benefits under the Federal Pandemic Unemployment Compensation (FPUC) program, while UIPL 16-20 provides guidance to states for implementation of the Pandemic Unemployment Assistance (PUA) program.

Additional weekly payment. UIPL 15-20 outlines relief in Section 2104 of the CARES Act, under which states may provide an additional $600 per week benefit to individuals who are collecting regular Unemployment Compensation (including Unemployment Compensation for Federal Employees and Unemployment Compensation for Ex-Servicemembers) as well as the following unemployment compensation programs: Pandemic Emergency Unemployment Compensation; Pandemic Unemployment Assistance; Extended Benefits; Short-Time Compensation; Trade Readjustment Allowances; Disaster Unemployment Assistance; and Payments under the Self-Employment Assistance program.

Timelines. FPUC benefit payments are fully federally funded. For those who are eligible, the benefit payments under the FPUC may begin as soon as the week after the execution of a signed agreement between the DOL and a state. The timeline for these payments will vary by state, according to the DOL. As states begin providing the payment, eligible individuals will receive retroactive payments back to their date of eligibility or the signing of the state agreement, whichever came later. All states have executed agreements with the department as of March 28, 2020, the DOL said.

The CARES Act specifies that FPUC benefit payments will end after payments for the last week of unemployment before July 31, 2020.

Program integrity. UIPL 15-20 also includes guidance to states about protecting unemployment insurance program integrity, as the provisions in the CARES Act operate in conjunction with the fundamental eligibility requirements of the Federal-State UI program. The DOL is actively working with states receiving funding under the CARES Act to provide unemployment insurance benefits only to those who are entitled to such benefits.

Self-employed, independent contractors, gig workers. UIPL16-20 provides guidance to states for implementation of the PUA program available under Section 2102 of the CARES Act. Under PUA, those who do not qualify for regular unemployment compensation and are unable to continue working as a result of COVID-19, such as self-employed workers, independent contractors, and gig workers, are eligible for PUA benefits.

The DOL explained that PUA provides up to 39 weeks of benefits to qualifying individuals who are otherwise able to work and available for work within the meaning of applicable state law, except that they are unemployed, partially unemployed, or unable or unavailable to work due to COVID-19-related reasons, as defined in the CARES Act. Benefit payments under PUA are retroactive for weeks of unemployment, partial employment, or inability to work due to COVID-19 reasons starting on or after January 27, 2020. Benefits cannot be paid for weeks of unemployment ending after December 31, 2020.

Broad relief available. Eligibility for PUA includes those who are not eligible for regular unemployment compensation or extended benefits under state or federal law or pandemic emergency unemployment compensation, including those who have exhausted all rights to such benefits. Covered individuals also include self-employed individuals, those seeking part-time employment, and individuals lacking sufficient work history. Depending on state law, covered individuals may also include clergy and those working for religious organizations who are not covered by regular unemployment compensation.

Program integrity. UIPL 16-20 also includes guidance to states on protecting unemployment insurance program integrity. The DOL is actively working with states to provide benefits only to those who qualify for such benefits.

Further information on UIPLs and previous guidance is available at https://wdr.doleta.gov/directives/ (UIPL 15-20, UIPL 16-20, April 4 and 5, 2020).

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