By: Michelle De Oliveira, Esq.
On March 24, 2020, the DOL announced that the Families First Coronavirus Response Act (FFCRA) will be effective as of April 1st. The statute will be effective through December 31, 2020. This in turn means that employees may be eligible for paid sick leave under the FFCRA from April 1 through December 31, 2020.
Although regulations have yet to be published, recent DOL guidance suggests that employers with fewer than 50 employees may qualify for an exemption from the requirement to provide paid leave under the FFCRA.1
Also, employers must post a notice to current employees in a conspicuous place in the premises of the FFCRA requirements. To meet the notice requirement as to employees who are teleworking, employers will satisfy their notice obligations by emailing or direct mailing the notice to employees or posting it on an employee information internal or external website.
It is not necessary to provide notice to employees who have been laid off.
The DOL model notice may be downloaded here: https://www.dol.gov/sites/dolgov/files/WHD/posters/FFCRA_Poster_WH1422_Non-Federal.pdf
We will continue to closely monitor the developments of FFCRA, among other COVID-19 related developments, to provide helpful guidance.
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