A flurry of publications from the United States Department of Labor (DOL) provide employers with additional details regarding the recently-passed Families First Coronavirus Response Act (FFCRA). Q&A guidance issued March 24 establishes an April 1, 2020 effective date and explains how to calculate the 500-employee threshold and hours used to determine employees’ leave entitlement. A March 24 Wage and Hour Division enforcement memorandum indicates that the Act will be subject to a 30-day limited non-enforcement period. Finally, the DOL published a required poster and guidelines for posting notices in an era of remote working. Employers subject to the FFCRA should familiarize themselves with each of these publications before the law takes effect.
The FFCRA, signed into law on March 18, 2020, provides assistance to employees and reimbursable tax credits to employees. The FFCRA requires employers with fewer than 500 employees to provide eligible employees with paid sick leave under two provisions: the Emergency Paid Sick Leave Act and the Emergency Family and Medical Leave Expansion Act. A detailed summary of the FFCRA is available here.