Yesterday, the U.S. Department of Labor (DOL) provided us its first published guidance related to Families First Coronavirus Response Act (Act) and the paid sick leave and EFMLA provisions, which were in that Act. The guidance was provided in the form of two fact sheets and a FAQ document. Some key points:
- The DOL is taking the position that the Act takes effect on April 1, 2020. Most of the previous guidance stated that it would be effective April 2, 2020. This effective date took many by surprise. The DOL gave no explanation on this topic, but I would assume this was done to line up the effective date of the law with the beginning of the 2Q.
- The DOL guidance does NOT contain the model notice/poster. In these documents, the DOL announces that those documents will be available today- March 25, 2020. We will post that to our website for our clients’ use and our community’s use as soon as it is issued.
Here are links to the DOL Guidance:
- Fact Sheet for Paid Sick Leave: https://www.dol.gov/agencies/whd/pandemic/ffcra-employee-paid-leave
- Fact Sheet for EFMLA: https://www.dol.gov/agencies/whd/pandemic/ffcra-employer-paid-leave
- FAQ: https://www.dol.gov/agencies/whd/pandemic/ffcra-questions
If you have any questions, please contact Michael Bogdan or any KWGD Labor and Employment, attorney.
NOTE: This general summary of the law should not be used to solve individual problems since slight changes in the fact situation may require a material variance in the applicable legal advice.