No. The CARES Act does not require employers to pay qualified wages.  In addition, Eligible Employers may elect to not claim the credit for the Employee Retention Credit.  (The FFCRA does require certain employers to pay sick or family leave wages to employees who are unable to work or telework due to a COVID-19 circumstance.  These employers may be entitled to a refundable tax credit for those wages paid, although the employers may elect not to claim the credit.)
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