"Except for owner-employees, the amount of health insurance premiums paid for by the employer may also be included for those paid or incurred during the chosen covered period.... [T]hese should also include health reimbursement arrangement [HRA] and health savings account (HSA) employer contributions.... Because guidance has so far strayed from the 'paid and incurred' to 'paid or incurred' standard, it's possible (absent further guidance) that employers could pay their full 2019 retirement contributions, 2020 match contributions (safe harbor or not), and even potentially their full year's 2020 profit sharing, money purchase pension, or other defined contribution plan contributions to the plan during the chosen coverage period, and have it count towards payroll costs eligible for loan forgiveness. If this interpretation stands in some form of Treasury and/or SBA final guidance, there are numerous operational issues to consider[.]"  MORE >>