NPRC is concerned that sufficient time is not available to implement an option to defer employee Social Security tax by September 1.  IRS still needs to issue guidance on how such deferrals will work and any related reporting and other requirements before programming changes can be made.    

The programming changes are substantial.  Payroll systems are designed to apply a single Social Security tax rate for the full year, and to all employees equally.  Applying a different tax rate for part of the year, beginning in the middle of a quarter, and applying such a change to some employers but not others, and to some employees but not others, is quite complex.  Not all employers and payroll systems will be able to make these complex changes by September 1.

NPRC provided the IRS with the attached recommendations to facilitate implementation.