Important Paycheck Protection Program Bulletin

Important Paycheck Protection Program Bulletin


By Matthew L. Austin, Managing Director | Keiter Advisors

Offer to Re-Hire and Reporting a Rejection of Re-Hire to the State Unemployment Commission

The Treasury specified in its Interim Final Rule that a borrower’s loan forgiveness amount will not be reduced if an employer makes an offer to re-hire an employee during the covered period for the same salary and same number of hours as earned by such employee in the last pay period prior to the separation and that offer is rejected by the employee. There were several additional requirements specified by this interim final rule, including:

  • The borrower has to maintain records documenting the offer and its rejection
  • The borrower must inform the applicable state unemployment insurance office of such employee’s rejected offer of reemployment within 30 days of the employee’s rejection of the offer.

Has Your Business Received a PPP Loan?

It is this last requirement to notify the state unemployment insurance office which is of note, as it creates additional responsibilities for the employer/borrower in order to obtain the re-hire exemption outlined above. Forms to notify the commission can be found on the Virginia Employment Commission’s site. If an employer has employees in other states, we encourage them to consult with the state unemployment insurance offices as soon as possible.

We believe it is an important requirement to notify the relevant state office(s) if a borrower intends to utilize the benefits of the rejected offer in the calculation of loan forgiveness.

If you have questions, we encourage you to reach out to your Keiter team member, Scott Zickefoose, or Matt Austin.


Disclaimer:  This content has been prepared for general guidance and informational purposes only based on the date published.
The FFCRA, CARES Act, and SBA Paycheck Protection Program (PPP) are continually releasing new guidance that may change the information provided within this content. Keiter recommends that you perform your own independent research and/or speak with a qualified accounting professional before making any financial business decisions. © 2021 Keiter, All Rights Reserved.

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The information contained within this article is provided for informational purposes only and is current as of the date published. Online readers are advised not to act upon this information without seeking the service of a professional accountant, as this article is not a substitute for obtaining accounting, tax, or financial advice from a professional accountant.


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