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On April 5, 2020, the U.S. Department of Labor (DOL) released guidance to states on the application of the Pandemic Unemployment Assistance (PUA) program. More information can be found here on the DOL website.

Under PUA, individuals who may not qualify for regulator unemployment compensation, and are not able to work as a result of COVID-19, are eligible for up to 36 weeks of PUA benefits.

The U.S. Department of Labor announced today the publication of Unemployment Insurance Program Letter (UIPL) 16-20, providing guidance to states for implementation of the Pandemic Unemployment Assistance (PUA) program. Under PUA, self-employed workers, independent contractors, gig workers, and individuals who do not qualify for regular unemployment compensation and are unable to continue working as a result of COVID-19, are eligible for PUA benefits. This provision is contained in Section 2102 of the Coronavirus Aid, Relief, and Economic Security Act (CARES) Act, which was enacted on March 27, 2020.

PUA will provide up to 39 weeks of benefits to qualifying individuals who are otherwise able and available to work within the meaning of applicable state law, except for the fact that they are unemployed, partially unemployed, or unavailable or unable to work as a result of COVID-19 related reasons, as it is laid out in the CARES Act. Benefit payments under PUA are retroactive, for weeks of partial employment, unemployment, or the inability to work due to COVID-19 reasons starting on or after January 27, 2020. The CARES Act does specify that PUA benefits cannot be paid for weeks of unemployment ending after December 31, 2020.

Eligibility for PUA includes those individuals not qualified for regular unemployment compensation or extended benefits under federal or state law or Pandemic Emergency Unemployment Compensation (PEUC), including individuals who have exhausted all existing rights to such benefits. Covered individuals also include those who identify as self-employed, those seeking part-time employment, and individuals who lack the necessary work history. Depending on state law, covered individuals might also include clergy and individuals working for religious organizations that are not covered by regular unemployment compensation.

The UIPL also includes guidance to states about protecting unemployment insurance program integrity. The DOL is actively working with states to ensure that benefits are provided only to those who qualify for such benefits.

For more information on UIPLs or previous guidance, please visit: https://wdr.doleta.gov/directives/.

Additional Resources

Visit Barnes Dennig’s COVID-19 Resource Center for a comprehensive list of resources. Please contact our COVID-19 Advisory Team or any of our leadership team at Barnes Dennig to discuss.

Barnes Dennig COVID-19 Advisory Team Leaders: