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Thursday, March 26, 2020

COVID-19 Update: Required Posting and April 1, 2020 Effective Date for FFCRA

The Families First Coronavirus Response Act (“FFCRA”) was passed last week, requiring private employers with 500 or fewer employees to provide two types of paid leave to their employees. Our summary of the FFCRA, including which employees are eligible and when the two leaves apply, was first published on March 19, 2020 and can be found here

The Department of Labor (“DOL”);has now released their “Employee Rights” poster under the FFCRA, which can be found here.  This notice is required for all qualified employers and, by April 1, 2020, must be: (a) posted in a “conspicuous place” on the employer’s premises which is accessible to all employees; (b) emailed or mailed to employees; or, (c) posted on an employee information website. Which of these constitutes adequate notice may depend on whether your employees are working remotely at this time.

The DOL has also announced that it interprets the FFCRA to be effective beginning April 1, 2020. This is different than the date previously provided in the text of the FFCRA.

There will likely be an exception to the FFCRA leaves for employers with less than 50 employees, where providing the leaves would jeopardize the viability of the business as a going concern.  However, the details of that exception, including eligibility and the process to qualify, have not yet been established or announced.  We expect that further information will be available from the DOL within the next week or so and will provide further updates.

The FFCRA has increased and changed many employers’ legal obligations to their employees.  Employers should carefully review their particular situation to determine whether the FFCRA will apply to their business and what impact it will have.

The foregoing is for informational purposes only and does not constitute legal advice regarding any particular situation and should not be relied on as such.  Please contact one of our labor and employment lawyers if you have any questions.

This update was prepared by Charles S. Elbert, David A. Castleman, Kevin A. Sullivan, D. Leo Human, and Erin M. Leach.


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