IRS Questions and Answers on COVID-19 IRA and 401(k) Loans & Distributions

The CARES Act stimulus package substantially relaxed the rules around certain retirement account loan and distribution requirements, but with much confusion. As a result, the IRS recently put out a FAQ document to address the COVID-19 rule relaxation around IRA and 401(k) loans and distributions. This important information should come as welcome news for the nearly one percent of all retirement plan holders who have already taken a distribution under the new rules, according to Fidelity Investments.

Who’s eligible?

If you, a spouse or dependent tested positive for COVID-19, you automatically qualify. You also may qualify under less direct circumstances, such as experiencing economic hardship due to being quarantined, laid off, receiving a reduction in work hours, or missing work because you don’t have childcare. Business owners who are forced to close or reduce operating hours also qualify.

How Much Can I Take Out? 

COVID-19 impacted individuals can take up to $100k in distributions without paying the 10 percent penalty imposed on early withdrawals by people under 59½ years old. The $100,000 limit is the total for all the plans you have. For example, if you take $70k out of your 401(k), you can take only up to $30k out of your IRA under these rules. You will still owe taxes on the distributions as ordinary income; however, you are able to pay the taxes owed over a three-year period.

Can I Pay Myself Back?

The law also allows you to pay yourself back. Taxpayers can replace their distributions if they do so within a three-year timeframe. This means that if you take out a distribution in 2020, start to pay the taxes owed over the three-year rule and then pay back the distribution in 2022, you’ll be able to amend your 2020 and 2021 returns to get a refund, as well as not pay the tax you would have owed in 2022.

How Do Loans Work?

The maximum amount you can borrow increases from $50,000 to $100,000. You also can borrow the entire amount of your plan balance up to this limit (net of any outstanding loans). Moreover, for any loans you already have within the plan, the due date for payments due through the end of 2020 can be postponed for up to one year.

Is There Anything Else I Should Know?

Yes. First, there is more guidance coming from the IRS. Second, if you are eager to know what this formal guidance will look like, you can turn to the Hurricane Katrina relief rules from 2005 as this is what is expected will apply for the COVID-19 measures as well. Lastly, the IRS will generate a new form 8915E where taxpayers will report the repayment of COVID-19 covered distributions.

Understanding the Federal Government’s Proposal for Opening Up Again

After seeing a peak and then a sustained decline in coronavirus cases, hospitalizations, and deaths resulting from COVID-19, the White House and the Centers for Disease Control and Prevention has rolled out a three-tier approach to get the nation back to its pre-coronavirus economic activities.

While this program is led by the Federal Government, it is ultimately up to governors how they will reopen states and localities. However, there are some universal criteria that states must follow to gradually reopen the economy.   

Before transitioning from the stay-at-home orders to the three phases, certain criteria must be met. In order to move to less restrictive phases, there must be a dropping trend of documented cases over 14 continuous days or a downward trajectory of positive tests as a percent of total tests over 14 continuous days, according to guidelines set out by the White House and the CDC. Once the initial gating criteria are met, the local government can move into phase one.

Phase One

This stage will permit establishments such as places of worship, movie theaters, restaurants, and sporting arenas to reopen if they abide by strict social distancing guidelines. Along with recommending stringent sanitation guidelines for permitted establishments to reopen, this phase also suggests telework for employees and minimizing nonessential travel.

Phase Two

Schools, daycare centers, and camps (and similar events) could resume, along with nonessential travel. Establishments permitted to reopen in phase one can remain open and are now permitted to relax their physical distancing to a moderate level. Bars can start reopening, with diminished standing-room occupancy, and gyms can stay open with strict distancing and sanitation protocols.   

Phase Three

This phase would come into force when the state and/or locality has no evidence of a relapse. Worksites would see normal staff protocols without restrictions. Large establishments will be able to function under limited social distancing protocols; gyms will operate with standard sanitation protocols; and bars would be able to run with increased standing room occupancy.

As states across the country are reopening, there are many preparations that businesses can implement to stay compliant with government mandates, including re-integrating their workforce and encouraging customers to return to establishments.

Sanitation

Along with social distancing, maintaining sanitation is equally important. Encouraging workers to wash their hands at every available opportunity, including upon arriving at work; before and after eating; after touching doors, desks, keyboards, and other materials; using the restrooms, etc.

Cleaning

Whether it’s an office environment or a retail/restaurant establishment, cleaning surfaces at least once a day is recommended, but more often for surfaces that are touched or used during the course of business. Examples of items to sanitize regularly throughout the day include handles, tables, elevator buttons, sinks, registers, and point of sale terminals.    

Signage

Reminding employees and visitors to go home if they have symptoms or have been exposed to the coronavirus through signage is recommended. A protocol to contact the front office based on these circumstances should be implemented.

Encouraging Telework

Identifying tasks suitable for telecommuting versus in-office is helpful for task completion, as well as promoting social distancing. Look at the perspective of work from two buckets – solitary or collaborative – and telecommuting and office time can be split accordingly. If an employee is tasked with writing reports, performing research, or calling experts, he or she could easily work from home. While collaborative work can be done remotely, it is better to be done at the office.

Other Considerations

Along with face masks, there are other ways to reduce the potential for coronavirus transmission. Offices and other establishments can have fewer seats in common rooms, using tape to mark 6 feet or more of distance. When it comes to hallways, one way to stop face-to-face exposure is to have one-way corridors. While it might create longer days, staggering shifts to reduce the number of people in the office and rearranging breaks would also reduce unnecessary employee-to-employee interactions.

Ditching cash as an accepted form of payment is another way to reduce the likelihood of coming into contact with the coronavirus on currency, along with encouraging social distancing since cash doesn’t need to be exchanged. Using online/digital payments or credit cards only is one way to accomplish this. Using designated entrances for workers (or customers), coupled with designated entrances and exits can help reduce opposing traffic and people meeting face-to-face.  

While research continues to create a vaccine and render the coronavirus harmless, until that happens, businesses have many tools to reopen their businesses for the foreseeable future.

Sources

https://www.whitehouse.gov/openingamerica/

Are Dividends Becoming a Luxury During the Coronavirus Pandemic?

According to the futures market, Chicago Mercantile Exchange contracts are forecasting a drop of 27 percent in dividends over 24 months for the S&P 500 index. Dividends are projected to fall to $42.05 in 2021, a drop from 2020’s dividend of $47.55 and 2019’s high of $58.24. Looking forward to 2026, according to CME’s futures contract, the dividend is expected to recover to $56.65. While the latter years are not as likely as what’s up next, it’s worth taking note.

Although these dividend levels have already been announced, the future doesn’t look much brighter. According to Goldman Sachs, Q2 economic growth is expected to drop by 34 percent. Even though the COVID-19 economic crisis is expected to be worse, we can get an idea of how bad by comparing it to the financial crisis of 2008. From 2007 to 2009, the S&P 500 dividend dropped by 25 percent; it took 48 months to recover from this drop. Based on this historical look-back, chances are it’ll take longer to get back to par this time around.

It’s noteworthy to highlight companies that suspended their dividends in April 2020, and when they last suspended their dividends, historically speaking. Dine Brands Global (DIN) initially paused its stock-buyback program. This was followed up with a suspension of its quarterly dividend of 76 cents. Royal Dutch Shell lowered its dividend by two-thirds to 16 cents per share, the first time since 1945. These examples illustrate just how dire the economic situation is for companies around the world.    

Cash Dividends Explained

A cash dividend is money distributed to stockholders according to a corporation’s present earnings or amassed profits. Dividends are declared and issued by a board of directors that determines whether they’ll remain the same, increase or decrease. 

Understanding the Need to Reduce or Cut Dividends

A dividend cut often results in a drop in a company’s stock price since it indicates a weakened financial position. Oftentimes, dividends are cut because earnings are dropping or there’s less money available to pay the dividend, which can be due to increasing debt levels.

The point here is that dividend cuts are a poor sign for a company that is facing financial difficulties due to reduced revenue, with the same overhead still needed to be paid (rent, wages, insurance, debt servicing). While dividends can be cut for short- or long-term reasons, such as buying their own stock back or buying out another company, with the ongoing coronavirus situation the majority of businesses aren’t doing it for positive reasons.

While reducing or removing a dividend from a company’s stock can divert cash for ongoing operations or debt servicing, it also can tell the markets things aren’t going well financially. This is illustrated by looking at AT&T. In December 2000, the company reduced its dividends by 83 percent, lowering it to 3.75 cents, versus the expected 22 cents by shareholders.

One of the first signals that a company can’t pay dividends, or won’t be able to in the near future, is to look at the company’s earnings trend and its payout ratio.

Looking at a Historical Example

During the second half of the 1990s, AT&T’s stock faced more and more competitors as deregulation went into effect. According to the company’s income statements from 1998 to 2000, annual earnings per share dropped by 50 percent.  

This data is according to AT&T’s 10-K, which shows that its yearly earnings dropped from $1.96 in 1998; to $1.74 in 1999; and finally to $0.88 in 2000. With this precipitous decline in earnings and the financial pressure it put on AT&T, a reduction in dividends came next. Based on this data and some analysis, we can explain how the Dividend Payout Ratio works.

Understanding the Dividend Payout Ratio

Using this ratio can help investors gauge how likely a company’s dividend will be cut or removed altogether.

Dividend Payout Ratio = Dividend Payment per Share / Earnings per Share

Looking at AT&T’s 10-Q report for Q3 of 2000, AT&T earned 35 cents per share and gave shareholders a dividend of 22 cents a share. Based on the dividend payout ratio formula, the resulting ratio was 0.63. This ratio means that 63 percent of AT&T’s earnings were given to shareholders via dividends. When companies have challenging earnings seasons, the payout ratio gets closer to 1 because whatever the company earns is eaten up by the dividend. Therefore, the closer the ratio gets to 1, the more likely the dividend will be lowered or suspended.

While there’s no predicting what the economy will do in the future, looking at past trends can give investors insight into what companies will do with their dividends when the economy faces new headwinds.

Why Sequence of Returns Risk Matters Now

That year or two when you are closing in on your retirement date, followed by a year or two after you retire, are the worst times for a sustained market decline. Market analysts call this scenario the sequence of returns (SOR) risk – because once your principal has been significantly reduced, there’s not enough time in the market left for you to recover those losses.

Two things will likely happen. First, the amount of retirement income you can withdraw each year is irrevocably reduced. For example, if you were planning to withdraw 4 percent a year from a $350,000 portfolio, you would have received a supplementary income of $14,000 a year. But if your principal drops to $280,000 a year, your 4 percent draw will generate only $11,200 a year. If you need that additional money, you will have to increase your draw to about 5 percent of the principal each year.

This leads us to the second consequence of a market decline: your principal will diminish faster. The longer you live, the greater your chances of running out of money.

How Big Is This Problem?

Because the coronavirus pandemic has sent stock markets reeling over the past few months, SOR risk has become a widespread concern. According to research by Spectrem Group, at the end of 2019 there were 11 million millionaires in the United States. By the end of March this year, at least half a million of those people were no longer millionaires.

While losses among millionaires may be disconcerting, the situation is far more dire for middle-class investors, who might not have several hundred thousand dollars to spare in their retirement portfolio.

Strategies To Offset SOR Risk

If the last recession is any indicator, the economic recovery going forward could take several years. That’s not good news for people who were looking forward to retirement. This group may want to seriously consider the merits of delaying retirement and continuing to work longer, such as:

  • Allowing their portfolio time to recover
  • Continuing to contribute to tax-advantaged retirement accounts
  • Enabling their Social Security benefits to accrue higher

Another strategy to help protect your portfolio against future SOR risk is to position a larger allocation to fixed-income assets and/or an annuity. While this might limit your potential for income growth in the future, these assets are backed by more reliable payors and less subject to the vagaries of the stock market. By diversifying your current assets, you can build multiple streams of reliable income to protect you from the future threat of market losses, a global pandemic or changes in Social Security benefits.

It’s worth considering that once we emerge from this current crisis, legislators will have to find a way to deal with the federal deficit and growing debt. The Social Security program was already projected to cut benefits by 2035 without any new funding solutions. Now, that threat is even further exacerbated by the enormous jump in unemployment numbers. This situation leaves even fewer people paying into the Social Security and Medicare programs.

All of this is why it’s very important to address today’s challenges presented by the sequence of returns risk. Explore ways to develop multiple income streams to protect your current assets and ensure they last throughout your lifetime.

How to Stay Productive When Working from Home

Due to the unprecedented effects of COVID-19, the line between our professional and personal lives has blurred. Trying to take care of job responsibilities from home requires new ways of navigating. Here are a few ideas to help you become more productive while working at home – and stay grounded in these uncertain times.

Dress for Work

As tempting as it might be to stay in your pajamas, don’t. Act as if you’re going into the office: shower put on your work clothes and head to your desk. You’ll feel more focused and professional. According to Heather Yurovsky, founder of Shatter & Shine, one should not underestimate the power of putting on clothes suitable for public viewing. “It makes you feel human, confident and helps draw the line between being at home and being at work,” she says.

Create a Dedicated Space

While working from the kitchen table or couch in your living room might be more comfortable, it also might prohibit your productivity. Set up a home office. Get an extra monitor. Make sure you have a dependable internet service. In short, replicate a professional workspace as best you can; one that feels separate from the rest of your home. When your surroundings are more in line with a real office, you’ll be more motivated. Plus, you’ll be able to more easily turn on when your day begins and turn off when it’s over.

Set Up a Plan for the Kids

Even though school’s out, chances are you still have to work. Create a schedule for the kids. Carve out certain hours for activities in designated areas of the house. According to Emily Weinmann of Us Happy Four, one of the best ways to keep the little ones occupied and happy is to prepare activity stations. Another great idea is to prepare snacks the night before and put them in your office, in the fridge or in their rooms. When someone is starving, the snacks will be ready. And finally, relax screen time. When you’re stuck at home and it’s either raining or it’s scalding hot outside, you’ll be grateful for technology.

Keep Regular Hours

If you stick with regular hours, you’ll not only be able to seamlessly transition going back into the office, you’ll also be on the same schedule as your colleagues. Everyone will be working concurrently, so you’ll be more efficient, easier to reach, and productive. When lunchtime comes, leave your home office and eat in the kitchen, the patio or the backyard. Even though you’re in one place, the simple change of venue will be mentally refreshing.

Set Clear Boundaries

This is especially important if you have other humans in your home. Try your best to discourage intrusions. When you’re in a meeting, shut the door. Lock it if you have to. If your home is more open, put signs in strategic places where people frequent, like the entry to the kitchen or stairs to the basement. This way, they’ll pause and reflect on whether an interruption is really necessary.

Limit Your Intake of News

In a society that’s saturated with news at every turn, it’s tough not to get sucked into the latest tragedy. Be intentional: Turn off the TV during work hours. Don’t visit news sites when you’re at the computer or on your phone. If you feel you must have a bit of news to break up your day, tune in for a few minutes during lunch or in the evening. But even then, be judicious and limit your time. If some story sends you over the edge, turn it off and head outside for a walk. Change the channel. Put on your favorite music.

These days, we’re all doing the best we can, taking life one day at a time. Unless you already work from home or have made a decision that you’ll work from home for the rest of your life, remember that things will change.

Sources

https://www.themuse.com/advice/coronavirus-work-from-home-tips

https://www.forbes.com/sites/bryanrobinson/2020/03/14/9-tips-to-be-productive-when-working-at-home-during-covid-19/#2af81a845a38

https://www.todaysparent.com/family/family-life/working-from-home-with-kids-coronavirus/

Payroll Protection Program Loan Forgiveness is Here

The first Payroll Protection Program (PPP) loans were made over eight weeks ago, which means they may be forgivable if the guidelines set forth by the Small Business Administration (SBA) and the United States Treasury Department are met.

In order to have a loan forgiven, borrowers need to complete the 11-page application made available by the Treasury Department.  Applicants can complete the forms either in hard copy or via an online platform if provided by their lender.  Large borrowers, those who took out more than $2 million from the PPP program are required to file even more paperwork.

Along with the application, borrowers also need to submit a Forgiveness Amount Calculation. This calculation discloses the total eligible payroll costs paid during the program.  Applicants will also need documentation such as tax filing statements, utilities, their PPP loan contract, EIDL contract, and any supporting documents you used when applying for the PPP loan. 

Certification of the loan forgiveness amount requested is necessary to prove it was truly used to pay eligible costs such as payroll, business mortgage interest, rent or lease payments, and utilities. Further, borrowers must report any declines in the number of full-time equivalent employees (FTEs) and/or wage reductions over twenty-five percent. Failing to retain pre-program FTE headcount or wage reductions over this threshold will reduce the eligible amount of loan forgiveness.

The amount of paperwork necessary to substantiate the application can be daunting, especially for many “main street” businesses. In order to help you complete the application, the SBA has issued formal guidance which can be found here.  As a more user-friendly guide giving detailed instructions on how to fill out your PPP forgiveness application form guide can be found here provided by Bench. We can assist you with the application process itself and the required documentation. Give us a call to see how we can help instead of struggling through the process on your own.

In the Wake of the Coronavirus Pandemic, Congress Passes the Most Expensive Single Spending Bill in American History

Paycheck Protection Program and Health Care Enhancement Act (HR 266) – This is a multilayered legislative bill divided into four distinct sections. Phase 1 authorized funding for coronavirus preparedness and response; specifically, for measures such as vaccine development and public health funding. Most of the money was allocated to the Department of Health and Human Services. Approximately 81 percent of funds were allocated domestically, with the other 19 percent allocated internationally.

Phase 2 allocated $104 billion for three specific objectives: 1) Require private health insurance plans and Medicare to cover COVID-19 testing; 2) Expand unemployment insurance by $1 billion and loosen up eligibility requirements; 3) Provide for paid sick leave at an employee’s full salary, up to $511 per day, and paid family leave at two-thirds of a worker’s usual salary.

Phase 3 provided stimulus checks to individuals and “grants” to small businesses meeting specific criteria, such as keeping employees on the payroll for two months. This phase of the bill represents by far the most expensive single spending bill ever enacted in American history, at about $2.2 trillion.

And finally, the last phase of the bill provided funding to replenish the Paycheck Protection Program (PPP) for small businesses and shore up public health measures, such as virus testing and hospital funding. The bill was signed into law by the president on April 24.

VA Tele-Hearing Modernization Act (HR 4771) – This bill amended previous guidelines to allow appellants to appear in cases before the Board of Veterans’ Appeals by picture and voice transmission from locations outside the Department of Veterans Affairs. The bill was introduced by Rep. Joe Cunningham (D-SC) on Oct. 21, 2019, and signed into law by the president on April 10.

Safeguarding America’s First Responders Act of 2020 (S 3607) – Sponsored by Sen. Chuck Grassley (R-IA), this bill was introduced on May 5 and passed in the Senate on May 14. The legislation is designed to extend death benefits to public safety officers whose deaths are caused by COVID-19, and for other purposes. The bill is currently under consideration in the House.

Law Enforcement Suicide Data Collection Act (S 2746) – Sen. Catherine Cortez Masto (D-NV) introduced this legislation on Oct. 30, 2019. The act would require the director of the FBI to provide information on suicide rates in law enforcement, and for other purposes. It was passed in the Senate on May 14 and is currently being considered by the House.

HEROES Act (HR 6800) – This bill was introduced on May 12 by Rep. Nita Lowey (D-NY). In response to the COVID-19 outbreak, this bill is designed to provide emergency supplemental appropriations for a variety of applications, including assistance to state, local, tribal and territorial governments; further, expand paid sick days, family and medical leave; unemployment compensation; nutrition and food assistance programs; housing assistance; payments to farmers; and the Paycheck Protection Program. It also outlines several potential tax credits and deductions and requires employers to develop and implement infectious disease exposure control plans. The House passed this bill on May 15; it is currently in the Senate for consideration.

COVID-19 Recovery Responses are Crucial for Companies to Thrive in the Future

With the coronavirus spreading across the globe, catching individuals and governments off guard, business owners have not fared any better. While the virus is having a grave impact on the health of millions across the globe, businesses have seen an equally serious impact on their bottom line. The virus is projected to hit businesses’ cash-flow and the ability to stay open post-pandemic.  

While different parts of the country have been hit harder than others, the nation’s businesses, their owners, and employees are all dependent on the national and global economy. Looking to those who have survived past crises, business owners are now tasked with guiding their organizations through the coronavirus pandemic.

Effective Attributes and Responses to Help with Recovery

Right now, more than ever, it is equally important that business owners empathize with their clients’ expectations and their employees’ needs while also taking steps to maintain their financial health.

Other attributes of effective business owners include making sound judgments in light of limited or incomplete data, along with providing a positive but realistic forecast of the situation to keep the employees motivated and productive. Lastly, leaders who see crises like the coronavirus as opportunities to identify trends for innovation and ways to problem solve can look to brighter days in the future.  

Protecting the Business’ Bottom-Line

Like other sustained business interruption events, there’s a three-pronged approach that businesses can implement to increase their chances of survival. The first is to manage the shock from the initial impact and establish a protocol for the new normal in order to preserve continuity. The next step is to learn from what has occurred and adapt to the way work is now being performed to serve clients as effectively as before. The final step is to identify future opportunities to operate differently, more efficiently, and gear up for the post-crisis new normal.  

To better mitigate major effects from a crisis and begin the adaptation process, the following are practical steps to emerge leaner and more efficient as the reopening process begins. Two primary actions that businesses must take is to first protect the well-being of workers, while also protecting the business financially.

  1. Making decisions should be streamlined because a lack of certainty can give decision-makers analysis paralysis. This can slow down important steps needing to be made faster than during non-crisis times. Moving from a chain of command to collaborative teams to make decisions can increase speed by having fewer steps and faster decision-making processes.
  2. Documenting all cash the business holds, along with committed and uncommitted lines of credit, also is suggested. Be sure to include lines that are pre-established with banks or credit unions, plus any existing borrowing limits from lenders; this will provide a baseline for businesses to make crisis projections. Other liquidity measures might be negotiating to extend better payment terms and refinancing existing lines of credit for better short-term payments, potential new equity injections, etc.
  3. Quickly modeling different economic outlooks for existing markets that are served, depending on how mild, moderate, or severe the crisis impacts that business, can provide greater insight on a business’ financials. As conditions change, it will become evident how much cash is needed and what areas of a business might need to be scaled back or cut. Leaders should also look at the likelihood of not being able to serve outstanding debt, primarily as they look at liquidity and the profitability of the business’ operations.
  4. Determine the business’ mission-critical business segments. This looks at which services or products are most profitable and/or resource-intensive. This will help determine which ones are important to current and future cash flow and which segments could be impacted based on the length and severity of the crisis.
  5. Evaluate what businesses can do to reduce non-essential or discretionary expenses to positively impact its finances. This can be accomplished by reducing or forgoing landscaping a business’ exterior or holding off on repainting a building. It can also come in the form of reducing one shift or reducing spending on employee training.  

Since the coronavirus is a fluid crisis and there are many possible outcomes, business owners will implement different practices based on how this crisis evolves. Depending on the severity of the actual impact, different products or services can be stopped temporarily, employees’ hours can be reduced or a hiring freeze can be implemented.

Be Right About Free Money: Potential Legal Risks of the Paycheck Protection Loan Program

Paycheck Protection Loan ProgramOne of the most important provisions of the CARES Act for small businesses is called the Paycheck Protection Program (PPP). The PPP is a $349 billion program designed to assist small businesses (fewer than 500 employees) facing financial difficulties as a result of the COVID-19 pandemic through specifically structured loans.

The loan program offers funding to cover payroll for up to eight weeks, with the intent of stemming from unemployment. These loans can be forgiven and essentially become a grant if your business meets certain criteria with no need to repay the money.

As the old saying goes, there’s no such thing as a free lunch – or in this case, free government money. There are potential legal risks that could jeopardize the forgivability of the loan.

Conditional Grants

Another way to look at the PPP loans is as conditional grants. The U.S. Small Business Administration (SBA) notes that loans will be forgiven in full if the funds are used for appropriate costs. Covered costs include payroll, mortgage interest, rent and utilities. Further, the payroll costs must account for at least 75 percent of the loan proceeds used. The employer needs to maintain or quickly rehire employees and maintain wage and salary levels in order to receive 100 percent forgiveness.

The Devil’s in the Certification Details

The loan application process requires certain certifications. Businesses that are still operating need to certify that the current economic uncertainty makes the loan necessary to keep operations going.

If this seems vague, it’s because it is. There probably isn’t a small business out there that is not facing significant uncertainty in the current climate. The problem is that the certification standard the PPP lays out is extremely subjective. As a result, with the encouragement for businesses to apply, many may do so under the impression that they will have their loan fully forgiven to only run into trouble later if they don’t meet the certification standards.

Legal Risks

By not providing any definition about the nature or extent of the required impact to operations that would make the loan request “necessary to support ongoing operations,” the SBA is making both applicants and lenders apprehensive.

Some law firms are even warning clients via their newsletters about potential legal exposure under the False Claims Act (FCA). Legal counsels are cautioning that a misrepresentation included in an application could result in FCA liability. Businesses must navigate between being as aggressive as possible to bolster their application while staying within the rules of the program.

More Certification Guidance is Needed

The government agencies involved need to provide more clear and objective guidance on the conditions needed to meet the certification requirements of the loan application process. Without clear and definable guidance as to what constitutes facing economic uncertainty, small businesses could face problems in the future.

Objective criteria such as a percentage of revenue decline or order capacity would provide a rather bright-line test and give both guidance to businesses and confidence in the process. 

Understanding the High-Low Method

Cost Accounting High-Low MethodWhen it comes to cost accounting, the high-low method is an approach that’s used to break mixed costs into either a variable or fixed cost. Although it’s straightforward, it’s important to do multiple analyses because outlier costs from the available data can sometimes misconstrue operating costs. This calculation occurs by looking at the periods with the most and least activity, as well as the total costs for both the high and low periods.

In order to get results for the high-low method, the variable cost and the fixed cost must be determined first. Once these are established, they are entered into the cost model formula.

Variable Cost is determined as follows:

VC = Highest Activity Cost – Lowest Activity Cost / Highest Activity Units – Lowest Activity Units

The next step is to calculate the Fixed Cost as follows:

FC = Highest Activity Cost – (VC x Highest Activity Units)

Now that the fixed and variable costs are known, the high-low cost can be determined:

High-Low Cost Model = Fixed Cost + (Variable Cost x Unit Activity)

Understanding it Through a Real-World Example

Looking at a furniture manufacturer, it’s good to focus on one product to see how the high-low method works:

The first step is to list production that includes each month, the product produced (let’s say it’s tables), and how much it cost to produce all tables each month. The list could be as follows:

Months Units Produced Total Cost ($)
January 153 6,650
February 106 5,653
March 120 6,185
April 126 6,120
May 100 4,888
June 133 6,650
July 113 5,852
August 93 4,988
September 153 6,783
October 166 7,382
November 146 6,783
December 160 7,581

The greatest output or activity for the furniture store happened in October when it produced the highest number of tables: 166 at a cost of $7,382. In August, the furniture store produced the fewest number of tables at 93, manufactured at a cost of $4,988.

Even though the cost may not be the greatest for the peak and valley of production, the corresponding costs for those respective figures is what will be used.

Now that we’ve identified the relevant data, the first task is to determine the variable cost.

VC = Total Cost of High Activity – Total Cost of Low Activity / Highest Activity Unit – Lowest Activity Unit

VC = $7,382 – $4,988 / 166 – 93  

VC = $2,394 / 73 = $32.80 per table

Then fixed costs must be calculated:

Total Cost = (VC x Units Produced) + Total Fixed Cost

$7,382 = ($32.80 x 166) + TFC

$7,382 = $5,444.80 + TFC

TFC = $7,382 – $5,444.80 = $1,937.20

It’s important to remember that variable costs are per unit.

Now that we have the total fixed cost, we can then create the total cost equation:

Total Cost = Total Fixed Cost + (VC x Units Produced)

Total Cost = $1,937.20 + ($32.80 x 166) = $7,382

This demonstrates the comprehensive costs for the tables made by the furniture store.

Further Considerations

The high-low method is a quick way to analyze costs. Since it only necessitates the peak and lulls of production data and costs, it can be done more often, along with helping companies plan with limited data to estimate future unit costs.

It’s important to run multiple types of cost analysis because high and low measurements might not give a full picture of costs. Although these two data points may not be the best overall picture of costs a business experiences at those volume levels, it can be an effective measurement until more data becomes available.