Guidance on Treatment of ‘Premium Pay’ Under ARPA

May 19, 2021

For Immediate Release: May 19, 2021
Contact: Mark F. Cavanaugh, Esq., Associate Counsel and Compliance Officer, mark.cavanaugh@nhrs.org; (603) 410-3592 

The New Hampshire Retirement System (NHRS, the retirement system) has determined that “Premium Pay” under the American Rescue Plan Act (ARPA) is earnable compensation for retirement calculation purposes and subject to member and employer contributions.

Premium Pay is optional additional compensation funded by federal money provided to state and local governments under ARPA for eligible workers performing essential work during the COVID-19 public health emergency. Premium Pay is not mandated under ARPA, but the law gives employers the option to grant this additional pay, up to $13 per hour, and not to exceed $25,000.00 per eligible worker, to employees deemed eligible under US Treasury rules.  NHRS views this as a temporary increase in the member’s base rate of compensation.  If a participating employer authorizes Premium Pay to an NHRS member, the compensation should be reported to the retirement system as base compensation, and member and employer contributions should be remitted.

More information on ARPA:
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-governments/state-and-local-fiscal-recovery-funds 

Additional COVID-related guidance for NHRS employers:
https://www.nhrs.org/faqs/faq---covid-19-guidance-for-participating-employers 

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