Do we pay past ee's?

Under regulations, we are required to give our employees a COLA increase every year. The increase is given after we receive confirmation of our grant award and it retroactive back to January (the fiscal year goes from Jan to Dec for this particular program, but July to June for the rest of the programs). If an employee resigns, are we required to hand out COLA checks? (We give these checks seperate to ee's, not in the regular pay)
I know with bonuses, you are required to pay all ee's who worked in that time period, even if they have resigned. I just need to know if DOL would consider this the same concept. (Also, if you know where I can print this fact out so that I can show my ED; she will want to see it in writing) Thanks.

Comments

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  • I'm not sure, but I would think so. I would start by carefully reading the statute or whatever requires that you grant annual COLAs. As with anything that is 'owed' to an employee, it belongs to them and I would think you would owe it to them retroactively whether or not they happen to still be on the payroll when the actual grant is awarded. This applies to 401K matches, bonuses, monetary awards for achievement; so, why would it not apply to a COLA?
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