Last Updated: 5/26/2020
The CARES Act’s Paycheck Protection Program provides funds to certain small businesses to cover payroll costs and benefits, among other specific expenses. This money is intended to help business owners continue to pay their employees, but knowing how to correctly calculate average monthly payroll costs for the PPP — and employee counts — is essential to a successful application. Here’s where to start:
Payroll costs for PPP loans include:
Under the Act, the Small Business Administration and the Treasury Department have said that payroll costs are based on gross pay and do not include withholdings such as the employee’s and employer’s share of Federal Insurance Contributions Act (FICA) and income taxes.
For example, an employee who earned $4,000 per month in gross wages and had $500 in federal taxes withheld would count as $4,000 in payroll costs. The employee received $3,500, and $500 from their wages were paid to the Federal government. All those gross wages can be used when calculating your average costs. However, as an employer, you also paid employer-side Federal payroll taxes for that employee. That additional cost to you was not part of their gross wages and is not included in the calculation under the statute.
In general, borrowers can calculate their aggregate payroll costs using data either from the previous 12 months or from the calendar year 2019. Borrowers can use their average employment over the same time periods to determine their number of employees.
Seasonal businesses can use average monthly payroll for the period between February 15, 2019, or March 1, 2019, and June 30, 2019.
A company that was not in business from February 15, 2019 to June 30, 2019 can use the average monthly payroll costs for the period January 1, 2020 through February 29, 2020.
For purposes of loan eligibility, the CARES Act defines “employee” to include “individuals employed on a full-time, part-time, or other basis.”
So, you will need to calculate your total number of employees, including part-time employees, when determining your employee headcount for purposes of the eligibility threshold. For example, if you have 200 full-time employees and 50 part-time employees each working 10 hours per week, the SBA considers that to be a total of 250 employees for your PPP loan application.
Note that this differs from how the SBA will have you calculate employee headcount for PPP loan forgiveness. There, you’ll need to determine the number of full-time equivalent (FTE) employees you have, so part-time workers may be counted differently. We’ve laid out all the details in this article for calculating your headcount as well as complying with and documenting the details needed for your PPP loan forgiveness application.
Once you’ve figured out your average monthly payroll costs, you’ll need to complete the Paycheck Protection Program loan application and submit the application with the required documentation to an approved lender that is available to process your application by June 30, 2020. Click here for the application form or contact an SBA-approved lender for more information. Remember that providing an accurate calculation of payroll costs is the responsibility of the borrower, so by completing the form, you are attesting to the accuracy of your calculations.
If you have questions about how the CARES Act or FFCRA impacts your business, please consult your legal advisor or tax professional, or review detailed guidance about PPP payroll cost reports from the Treasury Department and from the SBA.