Coronavirus Job Retention Scheme – FAQs

To make it easier to find the answers that you are looking for within this article, we have linked each of the questions in the list below. Simply click on the question you want to read and the page will automatically scroll to that section.

* Last updated 1 June 2020, after the Chancellor provided an update on the future of the Coronavirus Job Retention Scheme on 29 May 2020. *


WEBINAR: Coronavirus Job Retention Scheme and the impact on Payroll

As well as the further updates we have added to this page, you can also access our webinar below from Thursday 9th April, which covered the Coronavirus Job Retention Scheme and the impact on payroll. This was delivered by Avril Craig, Payroll Manager and our new COVID-19 Employer Advisory Team, David McIndoe & Louise Mackie.

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What are the latest changes to the Coronavirus Job Retention Scheme?

On Friday 31st July, The Chancellor announced a new job retention bonus as part of its Plan for Jobs 2020. Employers who bring workers back from furlough and retain them in employment until the end of January 2021 will qualify for a £1,000 bonus.

You will be able to claim the £1,000 bonus, per employee, in February 2021 provided each employee meets the following conditions:

  • Was included on a furlough claim
  • Remains continuously employed to the end of January 2021
  • Earns at least £520 a month on average between the beginning of November and the end of January

How exactly the payment is to be claimed, has not yet to be outlined by HMRC.

On Friday 29 May 2020, the Chancellor provided an update on the future of the Coronavirus Job Retention Scheme.

A summary of the key elements of the Chancellor’s announcement is below:

  • In June and July, there will be no employer contribution and the Government will continue paying 80% of furloughed people’s wages, up to £2,500 a month.
  • From 1 July, flexibility will be introduced allowing for part-time work.
  • To introduce the new, flexible furlough, the current scheme will be closed to new entrants on 30 June. Employers wanting to place new employees on the scheme will need to do so by 10 June to allow time to complete the minimum furlough period before then.
  • In August, the Government will pay 80% of furloughed people’s salaries, employers will be asked to pay National Insurance and pension contributions.
  • In September, the Government will pay 70% of furloughed people’s salaries, with employers contributing 10%. Employers will also pay National Insurance and employer pension contributions.
  • For the final payment in October, the Government will pay 60% of furloughed people’s salaries, with employers contributing 20%. Employers will also pay National Insurance and employer contributions.

More details can be found here.

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What is the Coronavirus Job Retention Scheme (CJRS)?

The CJRS is focussed around encouraging employers to “furlough” staff rather than laying them off.  The term “furlough” isn’t well known in the UK but it is widely understood in (for example) the US economy.  It refers to a temporary leave of absence which is imposed due to the special needs of the company or employer.

The CJRS is a temporary scheme initially in place for 4 months starting from 1 March 2020 (where employees have already been furloughed), but it may be extended if necessary and employers can use this scheme at any time during this period. It was initially a 3 month period, but this was extended until 30th June, as announced by the Chancellor on Friday 17th April.

The purpose of the CJRS is to encourage employers to stand down employees in a temporary fashion on furloughs rather than laying staff off.  

The term “furlough” will cover staff who remain under contract and on the payroll but are not working because the employer does not have work for them to do as a result of the virus. This certainly ought to cover staff placed on statutory layoff. However, the key difference is that the new term “furlough” presents a similar option for employers who do not currently have the contractual right to require staff to be laid off. 

During the period when employees are on furlough, employers can apply for a grant that covers 80% of their usual monthly wage costs, capped at £2,500 per month, plus the associated Employer National Insurance Contributions (NIC) and minimum 3% automatic enrolment employers pension contributions on that wage.

The salary figure is based on the person’s salary in February 2020.  HMRC will be able to confirm this via Real Time Information.  

So, this would effectively mean that for a person on a salary of £37,500 (£3,125 a month in February 2020) then HMRC would pay the maximum grant of £2,500 towards that. 

For persons on salaries below £37,500 (£3,125 a month in February 2020) then the grant paid would be proportionately lower, and for persons on annual salaries of above £37,500, the grant per month would be capped at £2,500 and so the additional monthly cost of having that person on furlough would have to be borne by the employer.  

The CJRS will be backdated to 1 March 2020 and will operate for at least April, May and June 2020.  

HMRC announced that the new system will go live on 20 April 2020.

For companies unfortunate enough to be under the management of an administrator, the administrator will be able to access the scheme on the company’s behalf. However, this option should only be considered if there is a reasonable likelihood of rehiring the workers. For instance, this could be as a result of an administration and pursuit of a sale of the business.

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Which employees does CJRS apply to?

Furloughed employees must have been on the PAYE payroll on 28 February 2020, and can be on any type of contract including:

  • Full-time employees
  • Part-time employees
  • Employees on agency contracts (who are not working)
  • Employees on flexible zero-hour contracts

The latest government guidance has outlined that, legally, anyone who left their job for any reason after 28 February can be rehired by their previous employer and included in the furlough scheme.

There is no obligation to do so and any decision should be based on the needs of the business.

If you are considering rehiring employees it would be prudent to seek legal advice as employees who re-join without a sufficient break in service may have their continuity of service preserved and have certain rights reinstated including the right to redundancy pay and right to claim unfair dismissal should their employment be terminated when the furlough scheme ends. It is possible the Government will issue further guidance on this point in due course.

Any employees who continue to work, but on reduced hours, or for reduced pay, will not be eligible for this scheme. Those employees on unpaid leave will only qualify if their leave started after 28 February 2020.

Employees with more than one employer can be furloughed from each job as each employment is separate and the furlough cap applies to each employer individually. Employees can be furloughed in one job and receive a furloughed payment but continue working for another employer and receive their normal wages. If contractually allowed, employees are permitted to work for another employer whilst they are placed on furlough.

Staff must be furloughed for a period of at least three weeks. This must be a continuous period and cannot be split or staggered in any way. Employees can be furloughed on a rotational basis so as not to totally deplete the workforce.

Furloughed employees cannot undertake any work for or on behalf of their employer. However, they can take part in volunteer work or training, as long as it does not provide services or generate revenue for their employer.

Any salary paid to furloughed employees will continue to be subject to the usual income tax and NIC deductions.

Update as at 17th April – You can only claim for furloughed employees that were on your PAYE payroll on or before 19 March 2020 and which were notified to HMRC on an RTI submission on or before 19 March 2020. This means an RTI submission notifying payment in respect of that employee to HMRC must have been made on or before 19 March 2020. Employees that were employed as of 28 February 2020 and on payroll (i.e. notified to HMRC on an RTI submission on or before 28 February) and were made redundant or stopped working for the employer after that and prior to 19 March 2020, can also qualify for the scheme if the employer re-employs them and puts them on furlough.

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Can I furlough an Apprentice?

Apprentices can be furloughed in the same way as other employees and they can continue to train whilst furloughed.

However, Apprentices must be paid at least the Apprenticeship Minimum Wage, National Living Wage or National Minimum Wage (AMW/NLW/NMW) as appropriate for all the time they spend training.

This means employers must cover any shortfall between the amount they can claim for their wages through this scheme and their appropriate minimum wage.

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What about employees who are receiving statutory payments?

Any employees on sick leave or self-isolating will qualify for Statutory Sick Pay (SSP). Employees who are shielding in line with public health guidance (or need to stay home with someone who is shielding) can be furloughed if they are unable to work from home and would otherwise have been made redundant.

Employees who are unable to work because they have caring responsibilities resulting from coronavirus can be furloughed. For example, employees that need to look after children can be furloughed.

Those employees on sick leave or self-isolating should get SSP but cannot be furloughed until the SSP period has ended.

Individuals who are on or plan to take Maternity Leave must take at least 2 weeks off work immediately following the birth of their baby. This is a health and safety requirement and not open to negotiation.

Employees who qualify for Statutory Maternity Pay will still be eligible for 90% of their average weekly earnings in the first 6 weeks, followed by 33 weeks of pay paid at 90% of their average weekly earnings or the statutory rate (whichever is lower). The statutory flat rate from April 2020 is £151.20 per week.

Employers who offer enhanced earnings related to contractual pay to women on Maternity Leave can claim the enhanced pay through the scheme.

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How should employees be furloughed?

  • Designate which employees are to be furloughed.
    • This might be your entire workforce, or it could be a selection of employees.
    • The minimum furlough period is 3 weeks and the maximum period is 4 months (as updated on 17th April).
    • You can rotate your furloughed employees if there is some work available.
  • Inform these employees and obtain their consent to the furlough process.
    • In doing so, you are effectively amending each employee’s terms & conditions of their employment so you may which to seek external legal or HR advice on this.
    • However, HMRC have stated that employers must provide written confirmation to each employee that they are being furloughed and this record must be maintained for a period of five years.
  • Pay these employees their new agreed salary.
    • The furlough claim is essentially an employer reimbursement scheme so you must ensure that all employees are paid their new agreed terms before making any claim.
    • There is no change to the current payroll process and everything is submitted (and paid to employees) as normal.
    • The reclaim is dealt with via separate submission at a later date.
  • Calculate the reclaim.
  • Request the reclaim via HMRC’s portal.

Once the furlough scheme ends, these employees would either return to full pay or employers would renegotiate a new contract, or consider redundancy. Should a member of staff need to come off furlough then you would need to cancel the furlough agreement formally.

Employers cannot force employees to be furloughed, this is clear from current government advice. Employers should discuss the prospect of furlough with their staff and make any changes to the employment contract by mutual agreement.

When employers are making decisions in relation to the process, including deciding who to offer furlough to, equality and discrimination laws will apply in the usual way.

Changing the status of employees remains subject to existing employment law, and depending on the employment contract, may be subject to negotiation.

Another reason why it is important to negotiate the change in terms is that if a change is not agreed an employee could bring a claim for either breach of contract or unlawful deduction of wages if employers fail to pay full salary without the employee’s agreement to receive a reduced salary.

Employers will need to ensure that employment contracts are updated, and employees are properly consulted on the changes to their contract to be able to take advantage of the CJRS.

As such, we would recommend that any clients considering furloughing employees should seek specialist legal advice to reduce the risk of any potential breach of employment regulations.

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What about eligible individuals who are not employees?

As well as employees, the grant can be claimed for any of the following groups, if they are paid via PAYE:

  • office holders (including company directors)
  • salaried members of Limited Liability Partnerships (LLPs)
  • agency workers (including those employed by umbrella companies)
  • limb (b) workers

Office holders can be furloughed and receive support through this scheme. The furlough, and any ongoing payment during furlough, will need to be agreed between the office holder and whoever operates PAYE on the income they receive for holding their office.

Where the office holder is a company director or member of a Limited Liability Partnership (LLP), the furlough arrangements should be adopted formally as a decision of the company or LLP.

Where furloughed directors need to carry out particular duties to fulfil the statutory obligations they owe to their company, they may do so provided they do no more than would reasonably be judged necessary for that purpose.

This also applies to salaried individuals who are directors of their own personal service company (PSC).

The rights and duties of a member of an LLP are set out in an LLP agreement and in the absence of an agreement, default provisions in the LLP Act 2000, based upon company and partnership law. Such an agreement may include separate agreement between the LLP and an individual member setting out the terms applicable to that member’s relationship with the LLP.

The rights and duties of a member of an LLP are set out in an LLP agreement and in the absence of an agreement, default provisions in the LLP Act 2000, based upon company and partnership law. Such an agreement may include separate agreement between the LLP and an individual member setting out the terms applicable to that member’s relationship with the LLP.

To furlough a salaried LLP member, the terms of the LLP may need to be varied by a formal decision of the LLP, for example, to reflect the fact that the member will perform no work in the LLP for the period of furlough, and the effect of this on their remuneration from the LLP.

For a salaried LLP member who is treated as being employed through the PAYE system by the LLP, the reference salary for this scheme is the LLP member’s profit allocation, excluding any amounts which are determined by the LLP member’s performance, or the overall performance of the LLP.

Where agency workers are paid through PAYE, they are eligible to be furloughed and receive support through this scheme, including where they are employed by umbrella companies.

Furlough should be agreed between the agency, as the deemed employer, and the worker, though it would be advised to discuss the need to furlough with any end clients involved. As with employees, agency workers should perform no work for, through or on behalf of the agency that has furloughed them while they are furloughed, including for the agency’s clients.

Where an agency supplies clients with workers who are employed by an umbrella company that operates the PAYE, it will be for the umbrella company and the worker to agree whether to furlough the worker or not.

Where Limb (b) Workers are paid through PAYE, they can be furloughed and receive support through this scheme.

If directors are included within the furloughed workers, as they often take a low or no salary from the business and dividends are utilised to top up their income, which are not subject to PAYE, then the dividend amounts are unlikely to form part of the CJRS calculation for the director.

A further concern is that a director must be non-active to be furloughed but, given they will continue to need to manage the business in some way, especially if they operate a personal service company, they are unlikely to be completely inactive and therefore may fail the CJRS requirements.

Commercially businesses will need to make a choice between the cost saved by furloughing directors and the commercial disruption of not having that director performing an active role in the business. 

More information for employees can be found here:- https://www.gov.uk/guidance/check-if-you-could-be-covered-by-the-coronavirus-job-retention-scheme#while-youre-on-furlough

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How is the claim calculated?

Full or part time employees on a salary

Claim for the 80% of the employee’s salary, as in their last pay period prior to 19 March 2020.

If, based on previous guidance, you have calculated your claim based on the employee’s salary as at 28 February 2020 (and this differs from their salary in their last pay period prior to 19 March 2020) you can choose to still use this calculation for your first claim.

Employees whose pay varies

If the employee has been employed for 12 months or more, you can claim the highest of either the:

  • same month’s earning from the previous year
  • average monthly earnings for the 2019-2020 tax year

If the employee has been employed for less than 12 months, claim for 80% of their average monthly earnings since they started work until the date they are furloughed.

If they have been employed for less than a month, work out a pro rata for their earnings so far, and claim for 80%.

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How are furloughed employees paid?

The employer will continue to pay the employee through payroll as usual on the normal payday using the Real Time Information (RTI) system. The employee will pay tax and NIC on payments made as normal. We also understand that employees will still be required to pay student loans and employee pension contributions during the period of furlough.

Payment of PAYE and NIC should be made to HMRC and the RTI filing requirements continue to apply. In addition, pension uploads, along with payments, should continue to be made to the pension provider.

All employers remain liable for associated Employer NIC and minimum automatic enrolment employer pension contributions on behalf of their furloughed employees.

In addition to the grant to cover wages of a furloughed employee – equal to the lower of 80% of an employee’s regular salary or £2,500 per month – employers can also claim back the associated Employer NIC and minimum automatic enrolment employer pension contributions (currently 3%) due on those wages. If your pension scheme offers more generous employer contributions, you will have to bear the cost of the difference. Remember you are only claiming employer contributions, so the employee deductions continue as they are. Even in the cases of final salary pension schemes, your claim is limited to the minimum, which is 3% on all earnings over £520 per month.

Employers can choose to provide top-up salary in addition to the grant but be aware that any employer NICs and pension contributions on any additional top-up salary will not be funded through this scheme.

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How do I make a claim?

All claims must be submitted via the new Online Service which should be up and running by 20 April 2020.

Employers will be able to submit one claim at least every 3 weeks; being the minimum length of time an employee can be furloughed for. Claims can be backdated until 1st March 2020 if applicable.

Claims should be made in accordance with actual payroll amounts at the time payroll is run or in advance of an imminent payroll. Employers must pay the employee all the grant received for their gross pay and no fees can be charged from the money that is granted. Once HMRC have received the claim and confirmed that the employer is eligible for the grant, they will pay it via BACS payment to a UK bank account.

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What are our fees for CJRS calculations and submissions?

Understandably, the work involved in the preparation and submission of these claims will vary for each client as each will have a different number of employees on furlough and different calculations required, depending on such things as whether employees have variable or fixed pay arrangements and other circumstances unique to each client. Some clients are asking us to run different scenarios, to assist with furlough decision making.  

Therefore, we will tailor our work to suit your exact needs and as such, we will have bespoke pricing for each client requiring our assistance with CJRS calculations and submissions. Please note, our pricing for processing your payroll is being held at our 2019/20 rates until further notice.

If you would like a fee quote for this service, then please contact David McIndoe in our Coronavirus Employer Advisory Team – david.mcindoe@hlca.co.uk.

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How do I register for the PAYE portal?

We have agent access for our payroll clients who have provided us with 64-8 authorisation, so we can do the claim for you, but this work will involve additional work.

If you have a PAYE registration in place, but no PAYE account, you can register using the following link: https://www.gov.uk/paye-online/enrol

However, it is worth noting that you will have to wait for an activation code coming through the post which normally takes up to 10 days which might take longer at the moment because so many businesses will be registering.

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What is the impact on the National Minimum Wage, National Living Wage and Apprentices Minimum Wage?

Employees are only entitled to the NMW/ NLW/AMW for the hours they are working or treated as working under minimum wage rules. This means that furloughed workers who are not working can be paid the lower of 80% of their salary or £2,500 even if, based on their usual working hours, this would be below their appropriate minimum wage.

However, time spent training is treated as working time and must be paid at the appropriate minimum wage. As such, employers will need to ensure that the furlough payment provides sufficient funds to cover these training hours. Where the furlough payment is less than the appropriate minimum wage entitlement for the training hours, the employer will need to pay the additional wages to ensure at least the appropriate minimum wage is paid for 100% of the training time.

Where a furloughed worker is paid close to minimum wage levels and asked to complete training courses for a substantial majority of their usual working time employers are recommended to seek independent advice or contact ACAS.

The new increases to NMW and NLW are not suspended, they apply to those who are working. However, they do not apply to furlough pay which is based on the pay in February 2020 for fixed pay employees and, for variable pay employees,  the higher of the pay for the same month last year, and the average of the 2019/20 pay. You can pay this amount, or more if you choose, but amounts paid in excess of this cannot be reclaimed. NMW does not apply because the employee isn’t working.

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What is the current position on holidays and holiday pay?

At present, the Government’s Job Retention Scheme guidance remains silent on whether holidays can be taken during furlough.

HMRC have, however, clarified that annual leave, including bank holidays, can be taken during furlough.  ACAS have amended their guidance accordingly.  The guidance states that employees or workers who are temporarily sent home on furlough leave because there is no work can request and take their holidays in the usual way if their employers agree.

ACAS have also confirmed that furloughed workers must get their usual pay in full, for any holiday they take.

Standard employment law provisions state that employers can require employees to take holiday as long as they give twice as many days’ notice as the period of leave the employee is required to take. For example, if the employer requires the employee to take one week’s annual leave at a certain time, it must give the employee at least two weeks advance notice (or whatever is outlined in the employment contract). 

So, an employer can furlough the employee and require a proportion of that to be annual leave as long as the correct notice is given.

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What about the accrual of holiday entitlement whilst on furlough?

Employees remain employed by the business during any period of furlough leave.  All terms and conditions of employment, with the exception of pay, will be unaffected by furlough, for example, continuous service continues to accrue as does holiday entitlement.

The government has introduced a temporary new law allowing employees and workers to carry over up to 4 weeks’ paid holiday into their next 2 holiday leave years. This law applies for any holiday the employee or worker does not take because of coronavirus, for example, if:

  • they’re self-isolating or too sick to take holiday before the end of their leave year
  • they’ve had to continue working and could not take paid holiday

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When you are sending a letter to staff to get their agreement to furlough, do you have to state the furlough period? Or can you simply state, the start date of furlough and running “until further notice”?

Unless employers have a relevant clause in their contracts of employment, it is important to get agreement from your employees to this temporary variation in writing. There is no guidance stipulating what must be included in the furlough letter, however, it would good practice to include the date furlough commenced, the minimum period of furlough, any review period, and duration ie until further notice.  ACAS have a free furlough letter template which can be downloaded from their website https://www.acas.org.uk/furlough-letter-template.

The latest guidance has also confirmed that you need to keep written records for 5 years.

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What about fixed-term employees?

According to the Government’s website employees on fixed-term contracts can be furloughed.

Their contracts can be renewed or extended during the furlough period without breaking the terms of the scheme. However, where a fixed-term employee’s contract ends because it is not extended, or renewed employers will no longer be able to claim grant for them.

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Do casual workers and employees on zero-hour contracts qualify for the CJRS?

Yes.

Employers will be required to use an average of hours worked to calculate the amount available to claim under the CJRS.

The 80% grant will apply to the higher of:

  • The earnings in the same period in the previous year; or
  • The average earnings in the whole previous 12 months (or fewer if they have worked for less than 12 months, including a part month calculation if they were taken on in February 2020).

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What if I need a furloughed employee to perform some work?

There may be some flexibility for a furloughed worker returning to work and then going back on furlough. A worker must be furloughed for a minimum of 3 weeks for their employer to be able to claim CJRS relief.

An employer can place a worker on furlough more than once, and one period can follow straight after an existing furlough period, while the scheme is open.

Whilst on furlough, an employee must not perform any employment duties. Therefore, a reduction in an employee’s hours will not qualify for relief under the CJRS.

We await further clarity on this, but as employers may need to react to peaks and troughs, it may be that they can plan to utilise employees for a particular busy period in a month and furlough them for quieter periods.

Furloughed workers may volunteer or train as long as they are not making money for or providing services to their employer. Employers can require workers to undertake training at home provided this condition is met, as long as they are paid at least the National Minimum Wage / National Living Wage for the time they spend training.

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Can your employee work for another employer whilst on furlough?

One of the fundamental principles of the Job Retention Scheme is that employees should remain available for work (subject to the minimum 3-week furloughing period).   The Government has, however, confirmed that an employee can take up new employment whilst being furloughed, without jeopardising their original employer’s access to the Scheme. However, most employment contracts do not permit a staff member to take up new work or may require that they obtain the employer’s consent before they do so.  Employers will, therefore, need to consider how they wish to respond to such requests.

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Can employees check emails and receive calls whilst they are “furloughed”?

The Chancellor confirmed that there will be no provision to partially furlough staff. This means employees will need to be entirely non-active to qualify.

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What about the benefits provided to employees?

We do not expect benefits provided to an employee to qualify for CJRS relief unless they are provided to meet minimum legal requirements e.g. automatic enrolment pension contributions.

If the employee’s salary entitlement reduces whilst they are furloughed, then benefits based on the level of salary will also decrease e.g. employer and employee pension contributions.

Employers will need to determine whether they continue to provide other benefits or enhanced benefits (i.e. above the minimum legal levels) as part of any furlough discussions with employees.

You must not encourage an employee in any way to “opt-out” of an automatic enrolment pension scheme. Doing so could cause the employer to be in breach of the existing regulations relating to Workplace Pensions. 

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Salary sacrifice schemes

Where a furloughed employee is a participant in a salary sacrifice scheme then, unless the employees’ contractual terms are varied, the salary sacrifice is likely to continue from the furloughed pay and the benefits available to the employee are likely to continue as current guidance does not specifically refer to this.

However, it may be possible to cancel the salary sacrifice and associated provision of a benefit as part of a contractual variation. As with all contractual variations, this should be discussed and agreed with the employee and, if necessary, employment law advice taken by the business. 

Any furlough reclaim will be based on post sacrifice salary as at 28 February 2020, which is 80%. You can pay more than this if you choose, but the reclaim is restricted.

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Can CJRS be backdated?

CJRS relief can be backdated to 1 March 2020, but claims will be limited to being backdated to the day the employee completely stopped undertaking duties of employment (i.e. those who have already been made redundant as a result of coronavirus).

If businesses re-employ staff that have been made redundant since 1 March 2020, these employees are eligible for furlough and the employer can apply for the CJRS grant.

CJRS will not apply to employees who have been put on reduced hours. This means that if an employee worked reduced hours because of Coronavirus from 12 March 2020 and became completely inactive on 26 March 2020, CJRS relief could only be claimed from the government from 26 March 2020.

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What if I have an employee who has reduced their hours due to childcare difficulties?

If the employee has reduced their hours because they are unable to perform work due to coronavirus, such that they may have been made redundant, then they may be considered for furlough and the CJRS should be available on payments made to them. As previously stated, an employee must not perform any employment duties whilst on furlough, so if the employee has chosen to reduce their hours to part-time due to childcare difficulties, this will not qualify for relief under the CJRS.

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What if I need to make a furloughed employee redundant?

A furloughed employee can be made redundant while on furlough or immediately after. CJRS grant payments will cease when the redundancy occurs.

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What if an employee refuses furlough?

If you ask an employee to go on furlough and they refuse, you may consider redundancy or termination of employment, depending on the circumstances. However, this must be in line with normal redundancy rules and protections.

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Looking for more advice?

If you have any questions or concerns, please get in touch with your usual MHA Henderson Loggie contact or a member of our new Employer Advisory Team, contact details provided below. If you are an employee looking for advice on your position, please get in touch with ACAS or check out the latest guidance for employees on the GOV.UK website.

Employer Advisory Team

David McIndoe – david.mcindoe@hlca.co.uk

Louise Mackie – louise.mackie@hlca.co.uk


The information on this page seeks to highlight some of the issues which could be affecting you and/or your business. Readers should not rely on this information without seeking professional advice on its application in their circumstances.

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