Any “hazard” pay would be considered eligible PPP payroll costs (up to $15,386 maximum for any individual during the 8 week covered period). This should be clearly documented. I Would advise you discuss with your outside employment counsel.
We're considering giving employees hazard pay for field work during the COVID crisis. Is this payroll increase forgivable? Would it be better to pay it as a temporary wage bump, or as a bonus?
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I would encourage all business owners to do what is right for the business and not get too preoccupied with ensuring 100% loan forgiveness. No, the "hazard" pay or "bonus" pay is most likely not forgivable unless you can defend and show that under past employment practices, our company has always given out these types of pay increases. Pay increases can be forgiven provided that you can clearly show this is part of your "normal operating practices" in running your payroll. The most obvious example is the fact that the employee is up for their annual performance review on June 1, 2020 and they are entitled to a pay raise of at least 3.5% which is your average pay raise. This can be "defended" and thus, qualify for forgiveness. At the same time, this is NOT the time to be giving out raises, bonus pay or any other increases that are clearly outside the normal scope of how you manage your workforce. We are in the middle of a pandemic crisis and this is not the time to go around giving out raises. You need to be as conservative as possible and perhaps let the employees know that once we get through this, they will be rewarded with a bonus later in the year.
New guidelines now include hazard pay.