July 23, 2020
If we elect to take the 24-week Covered Period, does that mean we have to keep our head count for the entire Covered Period or risk the reduction because of lowered FTE?
Posted by Armanino LLP Webmaster
Yes. The numerator in the FTE Reduction Factor calculation specifically uses the average FTEs during the Covered Period, whether eight weeks or 24 weeks. However, if you choose to apply for forgiveness prior to the end of your Covered Period, the clock apparently stops on this issue. Though no guidance has yet been issued to clarify the FTE calculation impact of filing early, it does appear impractical to determine what average FTEs may be at a future point in time subsequent to filing the forgiveness application. This may change with new guidance.