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PrintBrief highlights featuring the latest action taken by PAYO’s Government Relations Division to further its mission and goals.
Mobile Workforce Issues
Employees who travel outside of their states of residence for business purposes are potentially subject to filing an income tax return in every other state into which they traveled, even if they were there for only one day. These employees and their employers are forced to comply with a patchwork of confusing, outdated, and sometimes predatory nonresident state income tax laws.
August 27, 2020: Letter to the House and Senate in support of Section 403 of S. 4318, American Workers, Families, and Employers Assistance Act, and S. 3995, the Remote and Mobile Worker Relief Act of 2020.
June 29, 2020: Letter to congressional leadership supporting S.3995, Remote and Mobile Worker Relief Act of 2020.
June 29, 2020: Letter to U.S. Sens. Thune and Brown supporting S.3995, Remote and Mobile Worker Relief Act of 2020.
2017
November 6, 2017: Letter to U.S. Senator John Cornyn in support of S. 540.
March 13, 2017: Letter to U.S. House Judiciary Committee in support of the Mobile Workforce State Income Tax Simplification Act.
2016
September 19, 2016: Letter to U.S. House of Representatives in support of the Mobile Workforce State Income Tax Simplification Act.
2015
December 4, 2015: Letter to U.S. House Judiciary Committee, regarding the Mobile Workforce State Income Tax Simplification Act of 2015 (H.R. 2315).
June 10, 2015: Letter in support of the Mobile Workforce State Income Tax Simplification Act.
June 2, 2015: Statement for the Record before the U.S. House Judiciary Subcommittee on Regulatory Reform, Commercial and Antitrust Law.
2014
April 15, 2014: Testimony of member Lori Brown, CPP, before U.S. House Judiciary Committee in support of the mobile workforce bill.
2011
May 25, 2011: Statement for the Record before the U.S. House Judiciary Subcommittee on Courts, Commercial and Administrative Law in support of the mobile workforce bill.
2007
November 1, 2007: Testimony of member Dee Nelson, CPP, before U.S. House Judiciary Committee in support of the mobile workforce bill.
Child Support and Other Garnishments Issues
January 25, 2024: Letter to Wisconsin Assembly on proposed legislation S.B. 337 to eliminate the 13-week limit on garnishment orders.
August 9, 2023: Comments to the Office of Child Support Services on proposed revisions to the Income Withholding Order for Support.
July 12, 2023: Comments on the U.S. Department of Education's negotiated rulemaking and public hearing, expressing concerns about the student loan repayment process.
December 5, 2022: APA comments on H.R. 9224, Protecting Wages of Essential Workers Act of 2022.
November 21, 2022: Letter to the U.S. Department of Education on involuntary federal student loan repayment and wage garnishments.
October 6, 2022: APA request of the IRS regarding federal tax levies and Forms 668-W.
August 17, 2022: Letter to Washington in support of potential legislation on managing lump-sum payments for child support.
August 11, 2022: Letter to Michigan in support of potential legislation on managing lump-sum payments for child support.
May 24, 2022: Letter to California Department of Child Support Services with recommendations on establishing a lump-sum payment program.
April 25, 2022: Letter to OCSE Commissioner Tanguler Gray describing child support issues for payroll professionals.
2021
December 15, 2021: Letter to the Department of Education regarding reinstating student loan garnishments.
March 17, 2021: Letter to the National Council of Child Support Directors asking for support in implementing the electronic National Medical Support Notice.
March 12, 2021: Letter to the Nevada legislature with recommendations on provisions for lump-sum payments and child support found in A.B. 37.
2020
December 4, 2020: Letter to the U.S. Department of Education regarding withholding of student loans under the CARES Act.
October 8, 2020: Letter to IRS Commissioner Rettig requesting electronic capabilities for tax levies.
July 16, 2020: Letter to the U.S. Department of Education on the process for involuntary student loan payments and employee withholding following the forgiveness period under the CARES Act.
July 13, 2020: Comments on Revised Income Withholding Order before the federal Office of Management and Budget.
July 6, 2020: Letter to U.S. Department of Health and Human Services requesting priority improvements to child support electronic systems.
July 6, 2020: Letter to the U.S. House and Senate requesting assistance to raise the priority of improvements to child support electronic systems.
February 17, 2020: Letter to OCSE responding for call for comments on proposed changes to Income Withholding Order/Notice for Support.
February 12, 2020: Letter to the U.S. Department of Labor With APA's request to modify Fact Sheet #30 on garnishment limits under the Consumer Credit Protection Act.
January 13, 2020: Letter to Georgia State Senator expressing support for a proposal to amend the state's garnishment law.
2019
October 2, 2019: Model Legislation on Managing Lump-Sum Payments for Child Support. This model was prepared as a collaboration by the National Council of Child Support Directors, American Payroll Association, and federal Office of Child Support Enforcement.
September 10, 2019: Letter to OCSE requesting clarification of child support withholding limits when the limit recognized by a state IV-D agency is less than that provided in the state’s statute.
June 25, 2019: Letter to U.S. Senate on federal student loan repayment proposals.
June 14, 2019: Letter to the Texas Office of the Attorney General questioning direction to employers to withhold child support from tip income.
June 7, 2019: APA comments on IRS 2019-2020 Priority Guidance Plan.
February 25, 2019: Letter to the Hawaii Senate Committees on Labor, Culture and Arts; Judiciary; and Ways and Means opposing SB 243, as written, which would subject tip income to withholding for child support.
February 11, 2019: Letter to the Arizona legislature opposing HB 2230, as written, which would allow garnishments to be served by certified mail.
2018
December 11, 2018: Letter to the U.S. Department of Labor requesting a correction to Fact Sheet #30 for wage garnishment limits under the Higher Education Act.
October 9, 2018: Letter to OCSE requesting an electronic multi-way communication process for lump-sum payments.
June 15, 2018: APA Recommendations on IRS 2018-2019 Priority Guidance Plan, Notice 2018-43.
April 12, 2018: Opinion Letter issued by the U.S. Department of Labor at the request of APA to interpret the Consumer Credit Protection Act's withholding limits regarding lump-sum payments and child support.
February 7, 2018: Request of the Illinois Supreme Court for a rule amendment regarding employer electronic filing requirements pursuant to Wage Deduction Orders.
2017
November 8, 2017: Letter to the Wisconsin legislature in support of S.B. 397/A.B. 476, an act relating to eliminating the 13-week limit on creditor garnishments of earnings for certain debtors.
October 6, 2017: Letter to the Washington Senate in support of S.B. 5597 to mandate electronic payments of child support.
September 6, 2017: Letter to the Illinois Department of Healthcare and Family Services requesting clarity on changes to the child support withholding limits.
August 28, 2017: Letter to the Nebraska legislature regarding proposed garnishment bills, one in support of the Uniform Wage Garnishment Act.
July 15, 2017: Statement before the American Bankruptcy Institute’s Commission on Consumer Bankruptcy regarding the process to deduct bankruptcy orders and send payments to trustees for employees under Chapter 13.
February 17, 2017: Letter to the California Senate in opposition to S.B. 16 regarding use of local minimum wage rates for limits on student loan garnishments.
February 13, 2017: Letter to the Colorado Senate in opposition to S.B. 17-080 regarding use of the federal poverty level for limits on wage garnishments.
January 1, 2017: Statement in support of the Uniform Wage Garnishment Act.
2016
December 2, 2016: Comments on the federal Office of Child Support Enforcement’s Revised Income Withholding Order Form and Instructions.
November 11, 2016: Letter to the Pennsylvania Bureau of Child Support Enforcement regarding changed employer fees for child support under Pennsylvania Act 64.
June 1, 2016: Letter to Colorado Governor Hickenlooper regarding compliance conflicts between state and federal guidelines for calculating child support withholding.
2015
February 3, 2015: Statement before the Michigan House Commerce and Trade Committee in support of H.B. 4119 and H.B. 4120 on state wage garnishment reform.
January 16, 2015: Comments on the federal Office of Child Support Enforcement’s Notice of Proposed Rulemaking concerning Flexibility, Efficiency, and Modernization in Child Support Enforcement Programs.
2014
October 22, 2014: Statement before the Michigan Senate Committee on Reforms, Restructuring and Reinventing in support of Michigan H.B. 5390 and H.B. 5391 regarding state wage garnishment reform.
July 28, 2014: Response from Hon. Robert J. Colombo, Jr. regarding Michigan wage garnishment electronic disclosure requirements.
June 27, 2014: Letter to Chief Justice Robert J. Colombo, Jr., Third Judicial Court of Michigan, regarding state wage garnishment electronic disclosure requirements.
June 4, 2014: Statement before the Michigan House Commerce Committee in support of H.B. 5390 and H.B. 5391 on state wage garnishment reform.
Employment Eligibility Verification Issues
December 13, 2021: APA comments on remote document examination for Form I-9, Employment Eligibility Verification, USCIS request for public input.
2019
April 28, 2019: APA recommendations to U.S. Citizenship and Immigration Services on Form I-9 and E-Verify.
April 24, 2019: Letter to the U.S. Senate with recommendations on a bill to implement mandatory employment verification requirements.
2017
July 24, 2017: Letter to the U.S. Senate with recommendations on proposed bills to implement mandatory E-Verify, a program for employment verification at the U.S. Citizenship and Immigration Services.
2016
April 29, 2016: Additional Comments to U.S. Citizenship and Immigration Services on proposed revisions to the Form I-9 and Instructions.
January 11, 2016: Comments to U.S. Citizenship and Immigration Services on proposed revisions to the Form I-9 and Instructions.
2015
August 7, 2015: Comments to U.S. Citizenship and Immigration Services concerning Proposed Enhancements to E-Verify.
IRS Issues
September 18, 2023: PayrollOrg comments on IRS employment tax returns (OMB Number 1545–0029).
July 10, 2023: Letter to the U.S. Senate asking for IRS funding to be maintained. A similar letter was sent to the U.S. House of Representatives.
July 3, 2023: Comments to the IRS on the draft Form W-2c.
January 30, 2023: Letter to IRS on coordinating definitions of employee and independent contractor with the U.S. Department of Labor.
October 3, 2022: APA letter in support of the IRS’s “Proposed Collection for Timely Mailing Treated as Timely Filing.”
June 26, 2022: Letter to the IRS with questions regarding the filing and processing of Forms 941 and 941-X.
June 24, 2022: Comments to the IRS on Forms 1099-MISC and 1099-NEC.
April 25, 2022: Letter to the U.S. Senate in support of funding for the IRS.
IRS Advisory Committees
The IRS’s formal stakeholder advisory committees include the IRS Advisory Council (IRSAC), the Electronic Tax Administration Advisory Committee (ETAAC) and the IRS Security Summit. PayrollOrg often provides recommendations to the IRS for members to participate in these committees. Additional information is available on the IRS’s website at www.irs.gov.
PAYO Members currently serving on IRS advisory committees include:
James Paille, CPP, ETAAC, IRSSS
Sherice McCarthy-Hill, ETAAC
Martin Armstrong, DBA, CPP, IRSAC
Martin Rule, CPA, IRSAC
Nancy Ruoff, CPA, IRSAC
Jon Schausten, CPP, IRSAC
Stephanie Salavejus, CPP, IRSSS
Karen Settembrino, CPP, IRSSS
Kevin Valuet, IRSSS
2021
August 23, 2021: Letter to IRS with APA's recommendation for a simple version of the Form W-4, Employee's Withholding Certificate.
August 17, 2021: APA comments on the IRS's Notice of Proposed Rulemaking on the Electronic-Filing Requirements for Specified Returns and Other Documents.
July 16, 2021: Letter to the IRS with a request on common pay agents and excess Social Security tax refunds.
March 17, 2021: Letter to Treasury Secretary Yellen and IRS Commissioner Rettig on small business claims for the Employee Retention Tax Credit.
January 26, 2021: Letter to Congress in support of the IRS's infrastructure and training plans under the Taxpayer First Act.
2020
October 28, 2020: Letter to the IRS requesting that Form 1099-NEC, Nonemployee Compensation, be added to the Combined Federal/State Filing system beginning with 2021 forms.
August 27, 2020: Recommendations to the IRS on the Draft 2021 Form W-4P, Withholding Certificate for Retirement or Annuity Payments.
August 14, 2020: Letter to the Treasury Department and IRS with recommendations on President Trump's Social Security Deferral Memo.
July 17, 2020: Letter to IRS Chief Counsel in support of the National Taxpayer Advocate's recommendations on Frequently Asked Questions.
May 22, 2020: APA Comments to the IRS on the April 2020 Draft Form 941 and Instructions.
April 17, 2020: Letter to Congress with APA's request for COVID-19 relief for employees temporarily teleworking in their home state.
2019
November 25, 2019: APA Offers Recommendations on the IRS's Infrastructure Under the Taxpayer First Act.
November 13, 2019: Letter to the U.S. Congress on Repeal of the Unrelated Business Income Tax (UBIT) on Nonprofit Qualified Parking and Transportation Fringe Benefits in Section 512(a)(7).
September 4, 2019: Comments on the IRS’s Notice and Request for Comments on Form 1099-NEC, Nonemployee Compensation; 84 Fed. Reg. 37012 (July 30, 2019).
August 28, 2019: APA comments on the IRS's Second Early Release Draft 2020 Form W-4.
June 28, 2019: APA comments on the Early Release Draft 2020 Form W-4 and new Publication 15-T.
June 7, 2019: APA comments on IRS 2019-2020 Priority Guidance Plan.
2018
December 17, 2018: Comments to to IRS on the Notice of Proposed Rulemaking: De Minimis Error Safe Harbor Exceptions to Penalties for Failure to File Correct Information Returns or Furnish Correct Payee Statements.
October 26, 2018: Letter to Congress on UBIT Relief.
September 21, 2018: Thank you letter to the IRS on delaying the issuance of major changes to the Form W-4, Employee’s Withholding Allowance Certificate, until 2020.
September 5, 2018: Letter to IRS on the value of the monthly Payroll Industry Conference Calls.
July 26, 2018: APA Comments on the IRS's Notice of Proposed Rulemaking – Filing Requirements for Information Returns Required on Magnetic Media (Electronically)
July 3, 2018: APA Comments on the IRS's Preliminary 2019 Draft Form W-4 and Instructions.
June 15, 2018: APA Recommendations on IRS 2018-2019 Priority Guidance Plan, Notice 2018-43.
April 6, 2018: APA Letter to the IRS and Department of the Treasury requesting transition relief for Health Saving Accounts maximum limit changes.
April 6, 2018: APA Comments to the U.S. House of Representatives' Ways and Means Committee on the discussion draft of the Taxpayer First Act.
February 9, 2018: Letter the U.S. House Ways and Means Oversight Subcommittee on Improvements to the IRS's administration of the U.S. tax system.
February 7, 2018: Statement on implementing the Tax Cuts and Jobs Act before the IRS.
2017
December 15, 2017: Letter to the IRS regarding payroll concerns for implementing H.R. 1, the Tax Cuts and Jobs Act.
December 8, 2017: Letter to the U.S. Congress on payroll concerns in H.R. 1, the Tax Cuts and Jobs Act.
November 7, 2017: Comments to the IRS on a proposed rulemaking to Truncate Taxpayer Identification Numbers on Employee Copies of Form W-2.
September 19, 2017: Letter to the IRS recommending electronic capabilities for filing the amended Form 94x series and related forms and schedules.
September 12, 2017: Letter to the IRS requesting transition relief from Form W-2 late filing penalties because of the accelerated filing deadlines.
May 2, 2017: Letter to leadership in the U.S. Congress opposing use of Form W-2 for employer reporting requirements in the American Health Care Act of 2017.
March 7, 2017: Letter to leadership in the U.S. Congress in support of increased funding for the IRS.
March 7, 2017: Comments on the IRS Notice for Form W-2 de minimis error safe harbor requirements.
2016
December 5, 2016: Recommendations on IRS Form 1042-S and Instructions, Foreign Person’s U.S. Source Income Subject to Withholding.
June 27, 2016: Recommendations for the 2016 Forms 1094-C and 1095-C and Instructions under the Affordable Care Act.
May 16, 2016: Comments on IRS Notice 2016-26 regarding Recommendations for the 2016-2017 Priority Guidance Plan.
April 1, 2016: Comments on the Equal Employment Opportunity Commission’s Revision of the Employer Information Report (EEO-1) to include pay data.
2015
November 24, 2015: Comments on the IRS’s proposed rulemaking Removing of the Automatic Filling Extension for Certain Information Returns.
September 8, 2015: Comments concerning the IRS's draft Instructions for Forms 1094-C and 1095-C under the Affordable Care Act.
August 21, 2015: Letter to the U.S. House Committee on Appropriations urging adequate funding for the IRS.
May 29, 2015: Comments to the IRS concerning proposed procedures for employee consents that are used to support a claim for refund of overpaid FICA or RRTA taxes.
May 1, 2015: Comments to the IRS concerning ways to increase the electronic filing rate of employment tax returns, i.e., Forms 94x.
2014
November 6, 2014: Comments on proposed IRS Forms 1094-C and 1095-C under the Affordable Care Act.
2013
February 26, 2013: Comments on IRS proposed rulemaking to make the truncated Taxpayer Identification Number pilot program permanent.
2012
December 18, 2012: Amicus Brief filed in United States v. Quality Stores, Inc. regarding the treatment of severance payments.
December 17, 2012: Letter to the Department of the Treasury and IRS regarding withholding of federal income taxes absent published withholding tables caused by congressional budget delays.
November 21, 2012: Letter sent jointly with the National Payroll Reporting Consortium to U.S. House Ways and Means Committee and U.S. Senate Finance Committee regarding payroll tax relief proposals stemming from Bush Administration tax cuts.
November 4, 2012: Letter to the Department of the Treasury and IRS recommending the reinstatement of employee leave-reduction rules to assist victims of Hurricane Sandy.
February 14, 2012: Letter to U.S. House Ways and Means Committee and U.S. Senate Finance Committee concerning the expiration of Social Security tax withholding provisions in the Temporary Payroll Tax Cut Continuation Act of 2011.
January 12, 2012: Statement presented by member Lori Brown, CPP, before the IRS on the Real-Time Tax System.
Payroll Card Issues
May 26, 2020: Letter to New Jersey legislature in support of legislation (A.B. 4047) to allow for the use of payroll cards
June 24, 2019: Letter to Massachusetts legislature in support of legislation to allow for use of payroll cards
March 18, 2019: Letter to the Texas House Committee on International Relations and Economic Development in support of HB 2240, an act relating to the payment of wages through a payroll card account
2018
November 12, 2018: Comments to the Illinois State Treasurer regarding the presumptive abandonment period of funds held in payroll card accounts
May 1, 2018: Statement to the New Hampshire Conference Committee considering SB 84, in support of provisions addressing the use of payroll cards
February 2018: APA White Paper, Regulation of Payroll Card Accounts: A Guide for Policymakers (With Model Payroll Card Legislation)
2017
December 11, 2017: Statement to the Massachusetts Joint Committee on Labor and Workforce Development in opposition to unduly burdensome payroll card requirements in S. 1008.
August 31, 2017: Letter to the Delaware Department of Finance regarding proposed regulations defining when payroll cards become unclaimed property.
August 14, 2017: Comments in response to the Consumer Financial Protection Bureau’s proposed amendments to rules concerning prepaid accounts that include payroll cards.
June 5, 2017: Statement in support of New York bills A.6771-A and S.5208-A on the use of payroll cards.
May 2, 2017: Statement to the Massachusetts Joint Committee on Labor and Workforce Development supporting H.3135 and opposing S.1008 on the use of payroll cards.
February 10, 2017: Comments filed jointly with NACHA, the Electronic Payments Association, and the Association for Financial Professionals on the New York State Department of Labor’s wage payment notice and consent templates connected with the Final Rule on Methods of Payment of Wages.
February 10, 2017: Notice and Consent Form Template designed by APA’s Government Relations Task Force Subcommittee on Payroll Cards for direct deposit and payroll cards.
January 19, 2017: Statement in opposition to Virginia H.B. 1445, a bill that would reintroduce inefficient and costly paper paychecks back into Virginia’s payroll system.
2016
July 15, 2016: Comments in response to the New York State Department of Labor’s revised proposed rulemaking adding burdensome and costly payroll card and direct deposit requirements.
May 20, 2016: Letter to Connecticut Governor Malloy in support of signing S.B. 211 to provide the option to pay wages with payroll cards.
May 15, 2016: Statement before the Pennsylvania Senate Banking and Insurance Committee in support of S.B. 1265 to codify payroll cards as a method of wage payment.
January 27, 2016: Statement in opposition to West Virginia S.B. 290, which would effectively ban the opportunity to pay employees with payroll cards.
2015
November 25, 2015: Comments in response to the New York State Department of Labor’s revised proposed rulemaking on burdensome requirements relating to wage payments.
November 12, 2015: Amicus Brief filed in a Pennsylvania lawsuit arguing APA’s position that payroll cards are the functional equivalent of paychecks.
July 30, 2015: Comments in response to New York State Department of Labor’s proposed rulemaking on identifying permissible methods of making wage payments.
March 23, 2015: Comments in response to a Consumer Financial Protection Bureau proposed rulemaking on payroll card disclosure requirements.
March 16, 2015: Letter opposing Washington Substitute H.B. 1211 to impose burdensome requirements on making wage payments through payroll cards.
March 12, 2015: Letter supporting Rhode Island H.B. 5590 to make payroll cards a permissible method of wage payment.
March 2, 2015: Letter opposing Colorado S.B. 101 concerning the authority of employers to pay wages to employees electronically.
February 23, 2015: Letter opposing Washington H.B. 1211 for lack of clarity on the requirements employers will face when making wage payments through payroll cards.
January 15, 2015 - Letter to the Connecticut Department of Labor requesting a meeting to discuss the use of payroll cards when making wage payments.
2014
June 5, 2014: Letter to the Consumer Financial Protection Bureau regarding labor, consumer, and civil rights organizations’ comments about payroll cards.
May 8, 2014: Letter to the Illinois Department of Labor regarding proposed rules implementing the state’s Wage Payment Collection Act on direct deposit and payroll cards.
April 29, 2014: Statement in opposition to Connecticut H.B. 5315, as amended, regarding the payment of wages by payroll cards.
March 25, 2014: Statement in opposition to New Hampshire H.B. 1404 imposing burdensome requirements when paying wages with payroll cards.
March 25, 2014: Testimony before the Hawaii House Committee on Commerce and Consumer Protection on H.B. 1814, S.D.1 regarding the payment of wages with direct deposit and payroll cards.
March 17, 2014: Statement about proposed amendments to Georgia H.B. 947 on the payment of wages with payroll cards and direct deposit.
March 11, 2014: Statement in support of Connecticut H.B. 5315, as amended, to allow for the payment of wages through payroll cards.
March 10, 2014: Statement in support of Georgia H.B. 947 allowing for the payment of wages through payroll cards and direct deposit.
February 19, 2014: Testimony on Hawaii H.B. 1814, HD1 expressing concern about proposed restrictions for paying employees using payroll cards.
February 12, 2014: Statement opposing Wisconsin A.B. 687 requiring employers to provide free banking services when paying employees through payroll cards.
February 3, 2014: Statement supporting Nebraska L.B. 765 to codify paying employees with payroll cards as an acceptable method of payment.
January 27, 2014: Statement opposing New Hampshire H.B. 1404 to impose burdensome requirements when paying employees with payroll cards.
January 23, 2014: Testimony opposing Hawaii H.B. 1814 that would prohibit the payment of wages through payroll cards.
2013
October 14, 2013: Letter opposing Ohio H.B. 253. that would prohibit the payment of wages through payroll cards.
June 19, 2013: Letter in support of New York State A. 6419-B and S. 4392-B. that would expressly allow the payment of wages through payroll cards.
2012
February 28, 2012: Testimony offered by member Cathy Beyda, Esq., in support of Connecticut S.B.155 to allow for the payment of wages with payroll cards.
February 13, 2012: Comments in support of New Hampshire S.B. 341, with modifications, requiring written authorization to pay an employee through direct deposit or payroll card.
2011
September 14, 2011: Letter to California Governor Brown requesting him to veto S.B. 931 to prevent strict regulations on employers paying employees through direct deposit.
2010
August 25, 2010: Letter to Financial Crimes Enforcement Network requesting clarification on compliance with Bank Secrecy Act.
March 26, 2010: Letter to New York Department of Labor opposing state’s policy position on payroll cards.
February 4, 2010: Letter to Vermont House Committee on General, Housing, and Military Affairs supporting state legislation with amendments.
2009
October 1, 2009: Response from Pennsylvania Governor's Office of General Counsel.
September 28, 2009: Letter to the Pennsylvania Department of Labor and Industry.
June 9, 2009: Letter to the Utah Labor Commission in response to proposed rulemaking.
March 24, 2009: Letter to the Vermont Senate Committee on Economic Development, Housing and General Affairs.
February 27, 2009: Written testimony to the Vermont Senate Committee on Economic Development, Housing, and General Affairs.
2008
December 16, 2008: Letter to the Georgia Attorney General's Office seeking clarification on state’s position regarding payroll cards.
December 2, 2008: Letter to the Industrial Commission of Arizona.
September 19, 2008: Letter to the Connecticut Department of Labor.
July 3, 2008: Letter to the Alaska Department of Labor and Workforce Development.
July 3, 2008: Response from the Pennsylvania Bureau of Labor Law Compliance.
June 30, 2008: Letter to the Pennsylvania Department of Labor and Industry.
February 25, 2008: Letter to the West Virginia Senate Finance Committee.
2007
October 10, 2007: Letter to the West Virginia Division of Labor.
July 20, 2007: Letter to the Massachusetts Joint Committee on Labor and Workforce Development.
March 21, 2007: Letter to the Iowa House Labor Committee.
March 19, 2007: Letter to the New York State Senate Labor Committee.
March 12, 2007: Letter to the New Hampshire House Labor, Industrial and Rehabilitative Services Committee.
March 7, 2007: Letter to the Arkansas Senate Public Health, Welfare and Labor Committee.
February 26, 2007: Letter to the Oregon House Business and Labor Committee.
February 12, 2007: Letter to the Kansas House Commerce and Labor Committee.
2006
August 23, 2006: Letter to the West Virginia Division of Labor.
August 14, 2006: Letter to the New York State Senate Rules Committee.
August 14, 2006: Letter to the New Hampshire Department of Labor.
June 21, 2006: Letter to the Vermont Department of Labor.
June 21, 2006: Letter to the Tennessee Department of Labor and Workforce Development.
March 1, 2006: Letter to the Michigan Department of Labor and Economic Growth.
February 23, 2006: Letter to the Minnesota Department of Labor and Industry.
February 21, 2006: Letter to the Kansas Senate Committee on Commerce.
February 21, 2006: Letter to the Iowa House Commerce, Regulation and Labor Committee.
February 6, 2006: Letter to the New Jersey Department of Labor and Workforce Development.
2004
November 19, 2004: Letter to the Federal Reserve Board on proposed rule to amend Regulation E to apply to banks accounts established for payroll debit cards.
Retirement Accounts Issues
APA report, State Retirement Savings Programs: Employer Communications, with advice and considerations for state and local retirement plans:
Employer Communications Report (January 2020)
December 4, 2020: Letter to Congress in support of the SECURE Act 2.0.
March 12, 2020: Letter to Colorado General Assembly on S.B. 20-200, state retirement savings plan.
March 12, 2020: Letter to Hawaii Senate on S.B. 2489, state retirement savings plan.
January 31, 2020: Letter to Missouri House of Representatives on H.B. 1311, Workplace Retirement Savings Plans.
January 31, 2020: Letter to Missouri House of Representatives on H.B. 1432, Secure Choice Savings Program Act.
2018
April 23, 2018: APA Letter to the City of Seattle with recommendations on implementing the city's mandatory, automatic enrollment, payroll deduction retirement plan.
2017
February 15, 2017: Statement before an Oregon State Treasury Hearing on proposed rules to implement the state’s retirement plan.
2016
December 22, 2016: Comments on Oregon’s proposed rules to implement the state’s retirement plan.
September 26, 2016: Comments on the U.S. Department of Labor’s proposed rule on Savings Arrangements Established by State Political Subdivisions for Non Governmental Employees.
Other Federal Topics
December 21, 2023: Letter to the Consumer Financial Protection Bureau on earned wage access.
November 20, 2023: Comments on the USCIS's E-Verify NextGen program to be released in phases in 2024.
October 23, 2023: Letter to Congress about preliminary draft legislation on earned wage access programs.
July 20, 2023: Letter to US House Financial Services Committee by PayrollOrg regarding Bank Failures and Payroll risk.
June 30, 2023: Comments to Nacha on proposed rules regarding changes to the ACH payments network.
May 2, 2023: Letter to FDIC by PayrollOrg regarding Bank Failures and the risk to Payroll.
February 15, 2023: Letter to Congress by APA and GPMI regarding how social security reform could impact benefits for expatriates under social security totalization treaties.
December 12, 2022: Comments on U.S. DOL proposed rulemaking defining employee and independent contractor.
October 3, 2022: APA comments on the U.S. Immigration and Customs Enforcement’s proposed optional alternatives to the physical document examination associated with employment eligibility verification (Form I–9).
February 25, 2022: Letter to the Consumer Financial Protection Bureau regarding earned wage access and the agency's November 2020 advisory opinion.
2021
November 10, 2021: APA comments on H.R. 4728, Thirty-Two Hour Workweek Act.
November 3, 2021: APA comments on earned wage access issues before the House Financial Services Committee Task Force on Financial Technology.
October 29, 2021: APA offers recommendations on S. 2865 and H.R. 5507, the Unemployment Insurance Improvement Act.
July 16, 2021: Electronic Payments Committee Letter Responding to Nacha's Request for Information on the Risks of Early Funds Availability.
July 1, 2021: Electronic Payments Committee Comments Supporting Nacha's Proposal Concerning Third-Party Sender Roles and Responsibilities.
April 9, 2021: Professional Certification Coalition letter to U.S. Senate with comments on work development policy.
April 9, 2021: Professional Certification Coalition's proposed bill on work development policy.
February 23, 2021: Letter to Congress with concerns about the effective date of proposed increases to the federal minimum wage.
January 22, 2021: Electronic Payments Committee Comments Supporting Nacha's Proposal to Increase the Same-Day ACH Dollar Limit.
2020
October 9, 2020: Letter to Congress asking for relief from unemployment insurance taxes in 2021 and beyond because of COVID-19.
July 17, 2020: Electronic Payments Committee Comments Supporting Nacha's Proposal for Account Information Improvements Through the ACH Network.
June 19, 2020: Electronic Payments Committee Comments Supporting Nacha's Proposed Rule Changes for Reversals and Enforcement.
June 1, 2020: Comments to the Small Business Administration on the Paycheck Protection Program Loan Forgiveness Interim Final Rule.
March 13, 2020: Letter to Congress on short-term payroll tax cuts.
2019
November 7, 2019: Electronic Payments Committee Comments on the Federal Reserve Actions to Support Interbank Settlement of Faster Payments.
August 1, 2019: APA Supports Proposed Legislation to Deter Federal Government Shutdowns.
July 12, 2019: Electronic Payments Committee Comments on Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service.
State and Local Topics
January 29, 2024: Letter to Maryland House of Delegates on proposed legislation about pay statements. A similar letter was sent to the Maryland Senate.
January 25, 2024: Letter to New York in support of Governor Hochul's proposal to fix frequency of pay provisions in state labor law.
January 22, 2024: Letter to Maryland Assembly with comments on proposed earned wage access legislation.
January 12, 2024: Letter to Wisconsin Governor Evers regarding proposed earned wage access legislation.
January 9, 2024: Letter to Washington state on two proposed earned wage access bills.
December 18, 2023: Letter to the Council of the District of Columbia on artificial intelligence.
November 20, 2023: Comments on the California Department of Financial Protection and Innovation's notice of modified rulemaking on earned wage access.
October 11, 2023: PayrollOrg comments on preliminary draft legislation on earned wage access in Wisconsin.
June 5, 2023: Letter to Nevada governor in support of earned wage access legislation.
June 1, 2023: Letter to Missouri governor in support of earned wage access legislation.
May 15, 2023: Comments to California on proposed earned wage access regulations.
2022
November 10, 2022: Letter to Washington, D.C. on tax withholding and out-of-date tax tables.
June 24, 2022: Letter to Pennsylvania House in support of electronic wage payments bill.
June 17, 2022: Letter to California Legislature on Pay Data Reporting Bill SB1162.
March 28, 2022: Letter to New York Legislature on Pay Data Reporting Bill A1955/S2777.
March 25, 2022: Letter to California Legislature on Biometric Privacy Bill.
March 25, 2022: Letter to Maine Legislature on Biometric Privacy Bill.
March 25, 2022: Letter to Missouri Legislature on Biometric Privacy Bill.
March 25, 2022: Letter to New York Legislature on Biometric Privacy Bill.
February 22, 2022: APA offers recommendations on Maryland S.B. 0335 and H.B. 0259, Biometric Identifiers Privacy Act.
January 29, 2022: Letter to Colorado legislature in support of budget proposal to shore up the state Unemployment Insurance Trust Fund.
January 7, 2022: APA joint letter with the National Payroll Reporting Consortium to the Baltimore, Maryland, City Council regarding publishing of employer guidance on facial surveillance limits.
2021
December 14, 2021: Letter to New Jersey Senate on amendments to S. 3611 regarding earned income access.
October 19, 2021: Press release from Illinois Department of Labor regarding new data reporting requirements.
September 20, 2021: Letter to the Illinois Department of Labor (IDOL) as follow-up to a meeting with APA on September 15 regarding APA’s request to collaborate with IDOL on pay equity reporting.
September 7, 2021: Joint letter with the National Payroll Reporting Consortium to the Baltimore City Council requesting clarity on application of a facial recognition ordinance on employer time keeping and security systems.
August 31, 2021: Letter to the Texas Workforce Commission with an offer of assistance and concerns regarding enhanced reporting of labor market information, H.B. 3767, Texas Workforce Education and Workforce Alignment Act.
August 31, 2021: Letter to the Illinois Department of Labor with an offer of assistance and concerns regarding reporting requirements in provisions of Illinois S.B. 1480 (Pub. Act 101-0656), as revised by S.B. 1847 (Pub. Act 102-0036), amending the Equal Pay Act of 2003.
August 3, 2021: Letter to Virginia legislature in support of budget bill, H.B. 7001, provisions regarding the unemployment trust fund and related employment taxes.
June 29, 2021: Letter to the City of Baltimore requesting clarification of exclusions to a recently passed biometric restrictions law.
May 18, 2021: Letter to the Connecticut legislature in opposition to provisions in S.B. 881 to significantly increase information reporting for the state unemployment insurance report.
May 14, 2021: Letter to Massachusetts Secretary of Labor and Workforce Development with questions about implementing the unemployment insurance excise tax.
March 18, 2021: Letter to Nevada legislature in support of S. 198, regarding on-demand pay.
March 18, 2021: Letter to South Carolina legislature in support of S. 532 on earned wage access.
February 24, 2021: Letter to Utah House of Representatives with concerns about H.B. 370, Earned Wage Access Services Act.
January 21, 2021: Letter to New Jersey Senate in support of A3450, a bill on earned income access.
2020
November 2, 2020: Letter to states that have not made a decision on their use of IRS Form 1099-NEC, Nonemployee Compensation, for 2021 information filed in 2022.
October 27, 2020: Letter to New Jersey Assembly in support of an earned wage access bill, A3450, if amended.
June 22, 2020: Letter to the City of Eugene, Oregon, with recommendations on Council Ordinance 20616, An Ordinance to Fund Community Safety Services with a Payroll Tax and Adding New Sections to the Eugene Code, 1971.
April 17, 2020: Letter to state tax administrators and commissioners with APA’s request to expand existing emergency responder tax exceptions for all employees temporarily teleworking in their home state because of COVID-19.
April 17, 2020: Letter to state tax administrators and commissioners with APA’s request for COVID-19 relief for employees temporarily teleworking in their home state.
March 31, 2020: Letter to Kansas House Committee on Taxation in support of H.B. 2722, which would establish a 30-day safe harbor from income tax withholding for nonresident employees who travel into Kansas to perform work.
March 31, 2020: Letter to Minnesota House and Senate Committees on Taxes in support of H.F. 4128 and S.F. 3188, which would establish a 30-day safe harbor from income tax withholding for nonresident employees who travel into Minnesota to perform work.
March 20, 2020: Letter to Kentucky General Assembly regarding proposed legislation on pay statement requirements.
March 2, 2020: Letter to New Jersey Senator Pou on early wage access.
January 31, 2020: Letter to Eugene, Oregon regarding administrative rules for implementing the city's payroll tax.
January 29, 2020: Letter to the New Jersey Senate Commerce Committee on S.B. 866, Earned Income Access Services.
January 24, 2020: Letter regarding state use of IRS Form 1099-NEC for reporting nonemployee compensation. The letter was sent to 39 states and Washington, DC.
January 6, 2020: APA joint comments with the National Payroll Reporting Consortium on Maryland's re-proposed rule on the restaurant tip credit wage statement.
2019
August 23, 2019: Letter to Connecticut Payroll Commission with an offer of assistance regarding a possible state payroll tax.
August 13, 2019: APA Letter in Support with Recommendations of California S.B. 472 regarding early wage access.
August 9, 2019: APA and NPRC Comments on Maryland proposed rule on restaurant tip credit wage statement.
August 9, 2019: APA and NPRC Letter on State Use of IRS Form W-4 withholding elections (sent to Colorado, Delaware, Nebraska, New Mexico, North Dakota, South Carolina, and Utah).
• August 28, 2019: Nebraska Department of Revenue Response to APA and NPRC.
• August 15, 2019: South Carolina Department of Revenue Response to APA and NPRC.
April 29, 2019: Letter to Michigan Legislature on S.B. 40 on occupational licensing to protect APA's certification program.
February 7, 2019: Letter to Mississippi House of Representatives in opposition to H.B. 301 on excluding overtime pay from gross wages for state income tax purposes.
February 5, 2019: Testimony before the California Consumer Privacy Act Public Forum with concerns about employment data.
January 31, 2019: Request for an Advisory Opinion from the New York Department of Taxation and Finance regarding a Form W-2 conflict and state response.
2018
September 26, 2018: Letter to Massachusetts Legislature on H. 4640 regarding calculating pay by shift.
August 30, 2018: Letter to Ohio Legislature on S.B. 255, the Reform Occupational Licensing Act, to protect APA's certification program.
February 19, 2018: Letter to Washington House of Representatives opposing a bill that would prevent outsourcing of payroll functions by colleges and universities.