Recently we were able to get a few answers on how the EDD wants the AB 1513 wages reported. We will be creating a special DE-9/DE-9C report specifically for these wages. It will be a separate process from the regular quarterly reporting workflow. The late notice that the EDD gave employers means that it will take some time before the this reporting software is ready. The best estimate that we can provide right now is that it will be ready sometime in February.
This special DE-9/DE-9C will find all of the safe harbor checks that you issued during the fourth quarter by selecting checks issued with the special Safe Harbor wage type. It will then look at the Safe Harbor Detail file to determine which quarters each employee worked and allocate the total Safe Harbor wages earned among those quarters.
Ideally the EDD would have wanted the AB 1513 wages to be reported separately from regular wages. However, many customers have already filed their quarterly reports and included the Safe Harbor wages in their regular quarterly report for the fourth quarter of 2016 (a number of employers filed their reports even before the EDD sent the notices out). To keep things simple, we will not be doing any special programming for the quarterly report to exclude the Safe Harbor wages. This means that you should not delay filing your regular electronic reports and making tax deposits for all wages issued in the fourth quarter.
When you file your AB 1513 quarterly reports, you will need to include a note to the EDD indicating that your electronic report for the fourth quarter of 2016 included the AB 1513 wages that you are reporting. This way, the EDD will not double count these wages when entering them into their systems.
The EDD cannot accept electronic reports for the AB 1513 wages. This means you will need to submit reports on paper (!) for up to 14 quarters (July 2012 thru December 2015) for the safe harbor wages that you have issued. You should have received a notice from the EDD with a special address for submitting these reports.
If you have any additional questions, please leave a reply to this post.