SSA No-Match Guidance

In the past few weeks the Social Security Administration began sending out letters to employers informing them of a number of names that didn’t match the social security numbers submitted in the employer’s wage statements. The SSA hadn’t sent these letters our for nearly a decade. This year’s letters are significantly different from years’ past in that they didn’t contain any information on specific employees in most cases.

The National Council of Ag Employers along with other organizations was provided guidance on how to handle these letters. Please follow the link below to that guidance. The guidance gives a couple different paths you can take in responding to the letters. Read the guidance carefully multiple times before deciding what route to follow. None are wrong.

Please give us a call if you have any questions.

DSF

GUIDANCE ON HOW TO HANDLE SSA NO-MATCH LETTERS

SSA No-Match Letters Going Out

This is just a quick note to make you aware that the Social Security Administration has begun sending out letters to employers commonly known as No-Match letters. These letters were commonplace a decade ago but the SSA stopped sending them out in about 2011.

These letters do not tell you exactly which employees have names and social security numbers that don’t match. They only typically tell you to go to a SSA website to find out who they are. They encourage you to use a system on the site that checks the names and numbers. We are in the process of gathering more information and formulating a proper response to these letters.

We will post a longer article soon or contact gins directly regarding the response employers should have in reaction to these letters. In the meantime please let us know if you received an SSA No-Match letter. More to follow.

Disaster Bill Setback – Not Dead

I promised an update to the situation in the Senate when something happened. I waited a few days to see if anything would come of the setback Monday. Here’s where it looks like we stand right now. The farm press and general press have covered the failure of the Senate to pass a cloture vote on Monday this week. That vote would have ended debate on an amendment that replaced the House passed disaster bill with one that was very similar to the bill Senators Perdue, Isakson, Jones and Shelby had crafted. Unfortunately that cloture vote didn’t pass but the vote DID NOT KILL THE BILL as has been reported. I will add that watching the vote Monday, Senator Schumer was the one that cast the deciding vote for non passage. Sixty votes pass so forty-one kills it. He cast the forty-first vote against. If you think this is really about Puerto Rico you’re sadly mistaken.

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Senators Working Hard on Disaster Bill – Future Still Unclear

According the Atlanta Journal and Constitution, talks to move a much needed disaster package through the Senate hit a snag Monday over funding for Puerto Rico. This is the same funding problem that kept the bill’s provisions out of the spending bill that reopened the Government last month.

The disaster program which would bring help to many farmers in the Southeast, has been the subject of a tug-o-war between the President and Democrats that want additional spending for Hurricane Maria in Puerto Rico and the US Virgin Islands. The President is convinced that the money that has already been promised is being mis-managed and has refused to add additional spending to the relief in the region. According to Senator Isakson, over $40Billion has been allocated to help Puerto Rico with more than half not spent yet.

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March 2 is Right Around the Corner

Beginning in 2019 employers that are required to electronically file their OSHA 300A form data will have to do so by March 2. OSHA had been phasing in the electronic rule and has recently finalized an updated rule affirming the March 2 date.

Employers with 20 or more employees (at any point in the calendar year) and in certain industries (agriculture is on the list) are required to send in OSHA 300A log summary data each year by March 2 of the following year. So what this means is that cotton gins that had 20 or more employees must send in their OSHA 300A log summary information to OSHA for calendar year 2018 by March 2, 2019.

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OSHA Increases Fines Again

Last month (during the shutdown) OSHA, one of the agencies that didn’t get furloughed, published a final rule raising the maximum penalties once again. Back in 2016, the budget reconciliation act increased the maximum fines OSHA could levy. The fines at that point hadn’t been updated in 10 years and the change in 2016 more than doubled the max fines for Other than Serious, Serious, Willful and Repeated violations.

That same bill also directed OSHA to modify their fines annually to allow for inflation. Late last month, OSHA increased the maximum penalties for all levels of violations in response to that act. Today (as of Jan 24, 2019) the maximum penalty for a Other than Serious or Serious violation is $13,260. The maximum for Willful or Repeated violations is $132,589.

We’ve already seen some of this take effect where a gin that had a reportable injury was about 24hrs late and had a proposed fine of $6,600. It is important that you report injuries in the timeframe that OSHA has set out. If you have questions please let us know.

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