CAMICO recognizes the unique challenges facing our policyholders in navigating through the uncertainty of the coronavirus pandemic. First and foremost, firms need to take the appropriate steps to protect the safety and health of their employees, their clients and their communities. To that end, CAMICO recommends the following minimum steps:
- Stay up-to-date on the latest developments, which includes checking the following resources:
- Centers for Disease Control and Prevention (CDC);
- World Health Organization;
- Occupational Safety and Health Administration (OSHA);
- and your local departments of health.
Given the tax filings and financial statement regulatory deadlines rapidly approaching, advocacy efforts by many state societies and other organizations have been initiated requesting coronavirus relief from regulatory bodies (SEC, IRS, etc.), with some success. For example, the SEC has provided public companies, under certain conditions, with an additional 45 days to file certain disclosure reports that otherwise would have been due between March 1 and April 30 of this year.
On March 10, 2020, Congress wrote a letter to the IRS regarding the need to extend the tax filing deadline beyond April 15th, as well as requesting relief from filing deadlines and payment penalties for those impacted by COVID-19. In addition, on March 11, 2020, the American Institute of CPAs (AICPA) called for the Treasury Department and the IRS to provide broad relief to all taxpayers in light of the uncertainty and challenges caused by the spread of the coronavirus pandemic. Firms need to closely monitor the status of applicable filing deadlines as additional information becomes available. The AICPA has a great wealth of information on their Coronavirus Resource Center at https://www.aicpa.org/content/aicpa/news/aicpa-coronavirus-resource-center.html. In addition, since each state, county and municipality will reach their own decisions regarding possible relief, it is important for the firm to consult the website for each taxing authority to determine whether applicable filing dates have been changed.
Many policyholders have contacted CAMICO seeking sample language for a client notification regarding the potential impact of the coronavirus. Such a communication is very organization-specific so a “one size fits all” template is not appropriate. CAMICO has created the below example as a starting point for such a communication; however, you will need to tailor the firm’s communications so they are appropriate for your firm and its response to the pandemic.
Sample Client Communication:At [Firm], we are keenly aware of the potential impact of the coronavirus (COVID-19). We are taking steps to provide for the continuity of our client services and the safety of our employees and clients as we navigate through the uncertainly of the outbreak.
We are staying up-to-date on the latest developments. The actions we are taking include monitoring resources such as the Centers for Disease Control and Prevention (CDC); the World Health Organization; the Occupational Safety and Health Administration (OSHA); and our local public health department.
As you know, this is one of the busiest times of the year for accounting firms with tax filings and financial statement regulatory deadlines rapidly approaching. Disaster preparedness is an integral part of our firm’s risk management program and includes a viable pandemic response plan. Below are some of the features of the plan and the actions we are taking:
- Understanding the risk: This is a rapidly evolving situation, and we are monitoring reports from the CDC and other health agencies to enhance our knowledge and understanding of the spread of the coronavirus. We are tracking regional transmission in affected areas, and are actively taking steps to support our employees, clients and our surrounding communities.
We have frequent communications with our employees, which include instructing them to stay home if they feel sick, how to recognize COVID-19 and its symptoms, the benefits of social distancing, and reminders about proper hygiene and other mitigations strategies.
- Ensuring access to our firm:1 Based on current guidance and our own standards and practices, our office currently has no plans to shut down at this time and will remain open and accessible. We have implemented enhanced cleaning measures for our office(s) for the protection of our employees and clients in accordance with the current guidelines put out by the CDC and other health agencies. If you wish to meet with us, we ask that you call and schedule an appointment with us either in-person or via a teleconference meeting.
Our top priorities are the health and safety of our employees and clients. We will continue to monitor guidance from health experts and government recommendations, and will do our very best to maintain the quality and timeliness of our services to you. We appreciate your flexibility and support during this time, and our thoughts remain with everyone affected by the COVID-19 crisis.
1 This section is organization-specific and must be modified as needed to address each firm’s unique situation.