Leap Year’s Impact on Compliance Requirements in 2024
January 29, 2024
Leap Year’s Impact on Compliance Requirements in 2024

In 2024, leap day will occur on Thursday, Feb. 29. A leap year can create administrative and compliance challenges for organizations every four years. For example, a leap year can impact payroll processing or tax reporting obligations by adding an extra payday to the year. This can increase the number of pay periods from 26 to 27 for employees paid biweekly or from 52 to 53 for employees paid weekly, potentially altering how employees are paid. As a result, it’s essential that employers understand their compliance obligations and assess how an extra day in 2024 may impact any compliance requirements and deadlines.


This article explores how the 2024 leap year can impact compliance deadlines and how employers can proactively prepare and navigate any potential changes. However, the compliance considerations presented in this article are only examples. Employers should consult with their legal counsel to address any specific issues.


Payroll Considerations

Adding an extra day in February 2024 can create an additional pay period for employees who are paid on a weekly or biweekly basis. In 2024, there will be 53 Mondays and 53 Tuesdays. Therefore, weekly or biweekly salaried employees paid on either of these days will have an extra pay period. However, salaried employees paid monthly or semimonthly and employees paid hourly will not be impacted.


When faced with an extra pay period, most employers decide not to change how they pay employees each pay period despite the additional cost. As a result, impacted employees receive an additional pay period for the year, resulting in slightly higher salaries. Other organizations may opt to change their pay frequency or date to account for a leap year.


Some employers may decide to keep employees’ total annual salary the same but spread it out over the entire year. Employers can do this by counting the number of pay periods that will occur during the year and adjusting employee paychecks to account for an extra pay period. However, because of the extra pay period, employees would receive slightly less each paycheck, even though their total annual salary will remain the same. This can create confusion or negatively impact employees unless employers explain ahead of time why workers will receive slightly less each pay period, allowing employees time to prepare. Additionally, employers can explain that an extra pay period may impact employee deductions for benefits and contributions to retirement or health savings plans.


IRS tax withholding requirements do not change when there’s an additional pay period during the year. Therefore, employers must adjust their withholding calculations to ensure they withhold sufficient federal, state and local income taxes. To help avoid errors and ensure accurate payroll calculations, employers can review their payroll systems to ensure they can address leap-year payroll correctly. This can include accounting for an additional pay period, if applicable; withholding taxes correctly; and reviewing pay dates so employees are paid on time. Organizations can also prepare for an additional pay period by ensuring proper budgeting and cash flow to avoid any issues.


Benefits Considerations

Health plan deductions are typically determined by the number of pay periods. As a result, a leap year may force employers to recalculate health plan deductions. Additionally, a leap year can impact employee contributions to 401(k)s, health savings accounts and flexible savings accounts, requiring employees to adjust how much is deducted from each paycheck to ensure they contribute the maximum amount by the end of the year. Therefore, it’s important employers communicate how a leap year may impact employee contributions and allow employees sufficient time to adjust.


The IRS recently finalized reporting regulations under the Affordable Care Act that established a permanent 30-day automatic extension from Jan. 31 for employers to furnish Form 1095-C to employees. According to IRS guidance, applicable large employers must furnish Forms 1095-C to their employees no later than March 2. However, because of the 2024 leap year, the deadline this year is March 1, 2024.


Moreover, the Medicare Modernization Act requires organizations whose health care policies include Medicare prescription drug coverage to notify Medicare-eligible policyholders whether their prescription drug coverage is creditable. These entities must report the credible coverage status of their prescription drug plan to the Centers for Medicare (CMS) no later than 60 days from the beginning of a plan year. If a plan year starts at the beginning of the year, employers typically have until March 1 to report to the CMS. In 2024, however, the reporting must be done by Feb. 29.


Employer Compliance Considerations

The 2024 leap year may also impact certain employer compliance requirements. Employers should review their compliance obligations to ensure they avoid any potential violations.


While many laws are silent on the impact of a leap year, employer obligations are not altered. For example, the Fair Labor Standards Act (FLSA), which establishes minimum wage, overtime pay, recordkeeping and youth employment standards, does not specifically address leap-year considerations. However, since a leap year can create 27 or 53 pay periods (rather than 26 and 52), an employee’s weekly salary may drop below the federal or state-exempt salary threshold in certain circumstances. If this occurs, that employee would lose their FLSA exempt status, which could result in wage and hour violations if not properly addressed. Calculating any pay period adjustments at the start of the year can help employers prepare and avoid potential FLSA overtime and meal and rest break violations that may occur if employees lose their FLSA exempt status due to the additional pay period.


Additionally, employers can review offer letters and other compensation-related documents, including collective bargaining agreements, to determine how best to account for any extra pay periods. In some instances, these documents may state how frequently employees must be paid (e.g., weekly, biweekly). Reviewing these documents can help organizations comply with their legal obligations when determining how to adjust employee compensation during a leap year.


Summary

The additional day in 2024 may present various administrative and compliance challenges for some organizations. Understanding how a leap year impacts compliance requirements can enable employers to prepare and help them avoid costly mistakes. By taking a proactive approach and reassessing timelines, employers can help ensure they meet any compliance requirements and mitigate any potential legal risks.



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March 24, 2025
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Employee Appreciation Day, which falls on March 7th this year, is an ideal occasion to express gratitude for the hard work and dedication of your employees. At Simco, we recognize that employee appreciation shouldn’t be limited to just one day, but this day presents a special opportunity to go above and beyond in showing your team how much they mean to the success of your organization. When employees feel recognized and valued, it enhances morale, engagement, and ultimately, productivity. Here are several thoughtful and impactful ways to celebrate Employee Appreciation Day, creating lasting positive effects for both your employees and your company. 1. Personalized Appreciation Nothing shows employees you truly value them more than personalized recognition. Tailor your appreciation efforts to each individual, acknowledging their unique contributions and the impact they’ve made. 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Wellness Incentives : Gifts that promote health and wellness—such as fitness trackers, yoga classes, or access to mental health resources—show employees you care about their overall well-being. Company Merchandise : High-quality, branded merchandise like apparel, accessories, or tech gadgets can serve as a lasting reminder of your appreciation. 4. Invest in Professional Development One of the most meaningful ways to honor your employees is by helping them grow professionally. Employee Appreciation Day is a great time to invest in their future, whether through formal training, new opportunities, or fostering leadership skills. Ways to offer growth opportunities include: Learning Stipends : Offer financial support for employees to pursue further education, certifications, or online courses that align with their career goals. Internal Development Programs : Launch mentorship initiatives or leadership programs that enable employees to expand their skill sets within the organization. Growth Opportunities : Encourage employees to explore new roles or responsibilities that align with their career aspirations, reinforcing your commitment to their long-term success. 5. Encourage Peer Recognition Employee appreciation doesn’t have to be a one-way street from management to employees. Encouraging peer-to-peer recognition helps build a strong team culture, where employees feel supported and valued by their colleagues as well. This helps foster camaraderie and teamwork, which benefits the entire organization. Ideas for peer recognition: Peer-to-Peer Appreciation Platforms : Create an internal platform where employees can nominate or thank their colleagues for their contributions, highlighting specific ways they've gone above and beyond. Recognition Wall : Set up a virtual or physical wall where employees can post messages of appreciation for their peers, encouraging a culture of gratitude. Monthly Recognition : Implement a peer-nominated “Employee of the Month” program to recognize and reward employees for their ongoing contributions. 6. Give Back Employee Appreciation Day also provides an opportunity to show gratitude by giving back to the community. Many employees value working for companies that have a strong sense of corporate social responsibility. By organizing a charitable event or initiative, you demonstrate that your organization cares about making a positive difference beyond the workplace. Ideas for giving back include: Company Volunteer Days : Organize a day of service where employees can volunteer at a local charity or nonprofit, allowing them to contribute to causes they care about while bonding with their colleagues. Matching Donations : Offer to match employee donations to their favorite charities, demonstrating that you support their personal values and causes. Charitable Fundraising Events : Host fundraising activities or auctions with proceeds going to a charitable organization chosen by the team. 7. Seek Feedback Finally, a key part of showing appreciation is listening to your employees and gathering feedback on how they feel valued. Employee Appreciation Day offers the perfect occasion to ask for input on what makes them feel appreciated and what could be improved. This helps ensure that future efforts are even more meaningful. Ways to gather feedback: Anonymous Surveys : Send out a survey asking employees what makes them feel most appreciated and if they have any suggestions for improving recognition practices. One-on-One Check-ins : Arrange individual meetings with employees to hear their thoughts on workplace culture and recognition, providing an opportunity for honest feedback. Cultivating a Culture of Appreciation Year-Round Employee Appreciation Day is a special occasion, but the benefits of recognizing your team should last well beyond this single day. When employees feel consistently valued and appreciated, it leads to higher morale, greater job satisfaction, and increased engagement. By investing in recognition efforts, offering meaningful rewards, and fostering a culture of appreciation, you ensure that your team remains motivated, happy, and productive all year long. At Simco, we believe that lifting and supporting employees is integral to creating a thriving workplace. Whether you celebrate Employee Appreciation Day with gifts, events, or personalized recognition, taking the time to show gratitude is a small gesture that can have a lasting impact on both your employees and your business.

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