The AICPA has recommended to Congress that they change the start date of the PPP 8-week applicable period from the date of the loan to the date that employees come back to work. This recommendation goes against the very spirit of the law! 

If Congress goes along with this suggestion, it will mean that loan money meant to be paid to employees will not be.  Employees need the money NOW.  The reason for the PPP loans is so companies can pay their employees even if the employees are not working and even if the business is not operating.

If Congress changes the starting date of the 8-week applicable period, employees will not be paid.  Employees have bills, mortgages, hunger, etc.  They can't wait until stay-at-home orders are lifted.  They need the money now.  Congress created the PPP so employees' pay would only be minimally disrupted.  Companies have the money now.  Companies need to pay their employees when they have the money.

It feels too difficult to explain because it should be obvious.  If employees are only going to get paid when businesses are operating normally, then businesses could get regular loans.  The expectation, however, is that these loans will be forgiven.  They will be forgiven because Congress knows that businesses are closed, yet employees still need to be paid.  Therefore, it follows that the goal of the law is for employees to feel as little impact of stay-at-home orders as possible, and companies should resume payroll operations as soon as they receive PPP funds.

One of our in-house CPAs, Matt, sent an email to the AICPA in April to request they reconsider their position. We will update this post as new information becomes available.