We have been getting quite a few phone calls relating to the Cares Act, the Families First Coronavirus Response Act, and the status of gins as an “Essential Critical Infrastructure”. In addition, Governor Abbott issued a state wide order yesterday directing all Texans to minimize non-essential gatherings and in-person contact with people who are not in the same household, which is effective statewide. Please take a little time and read this to the end – this is a summary of all these issues with a lot of links to reference material on each issue:
First of all, we believe cotton gins are “Essential Critical Infrastructure”, as gins are classified under agriculture, more specifically producing oilseeds, which are also an animal feed ingredient. If you need a letter for your employees to carry, Click Here to pull up a generic letter specifically for cotton gins. You should type in in all blanks and put this on your letterhead. Please let us know if you have problems with your workers getting to work. We also have two more general letters from TDA related to agriculture that can be used. These letters can be found here in English and Spanish.
Being designated as “Essential Critical Infrastructure” allows your critical work to continue, but you must keep your employees and customers safe! Be sure you posted the Safety Posters, which can be downloaded here in English and Spanish. In addition, you must be extra cautious with your workers safety during this time. Make sure your workers are maintaining safe work practices, which today would involve them keeping the recommended six foot spacing from each other during work. Many gins are closing their offices and gins to outside folks. Salesmen can call to discuss any needed items, and can leave deliveries outside. Customers can call with orders that can be left outside for them to pick up. Each gin will be a little different, but many have already begun these types of practices. Many gins with farm stores have the customers call in orders and wait in their pickup while the orders are loaded, or leave orders outside for customers to retrieve. While these types of practices are inconvenient, having your gin become a “hot spot” for a Coronavirus outbreak, and losing a significant part of your workforce would be a much more serious issue.
Under the Cares Act, there are sources of funding available if you can demonstrate a loss of revenue over the past year or if you have employee related expenses that are caused by employees taking sick leave. There are loans which may be forgiven under certain circumstances, and tax credits available. More information about this act is available at the Fisher Phillips site that we discussed in earlier articles. This site was sent out a few days ago: Fisher Phillips Care Act Explanation
We are getting the most questions about the Families First Coronavirus Response Act. This act significantly expands sick leave and medical leave rights for employees. This may at least partially be offset by employer benefits in the Cares Act. For more information about this act, there are two very good additional resources. The first is a summary put out by Lloyd Gosselink, which is a law firm in Austin. Click here to review their summary. You can also click here to see the official DOL explanation of this act.
This is a highly unusual time in the world – we are trying to keep up with these issues as closely as possible, but please let us know if you have additional questions or observations. Many of your questions help us with our research on these issues.
