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DOL Issues Q&A – Federal COVID-19 Paid Leave Effective Date Moved Up to April 1

by | Mar 26, 2020 | Business And Corporate Law

This post provides an update on the new federal paid sick leave and emergency FMLA related to the coronavirus pandemic, which was established by H.R. 6201, titled, “Families First Coronavirus Response Act (“FFCRA”).

The U.S. Department of Labor released “Questions and Answers”, attempting to provide answers to preliminary questions related to FFCRA. This Q&A has surprised the public because it states that FFCRA goes into effect April 1. Up until now, the general consensus was that the new federal emergency paid leave related to the coronavirus pandemic went into effect April 2. The legislation imposed an effective date no later than 15 days after the bill became law, which is April 2. DOL has given no reason why it chose to move up implementation by one day, but there is speculation it was done to line up with the calendar quarter.

The DOL Q&A also provides guidance on how employers should count their number of employees to determine if the employer is exempt from FFCRA. Under the law, employers with more than 500 employees are excluded from the law.

In addition, DOL published on its website the required workplace poster for FFCRA. This poster is available here. Despite its availability, you may wish to wait and download the poster on March 31, as it would not be surprising if the current version is updated over the next week. Any corrected version would be available under the “Posters” section of DOL’s website.