Families First Coronavirus Response Act

The Families First Coronavirus Response Act was signed into law March 18th, 2020. Section 5103 of that Act states that within 7 days of the enactment, the Department of Labor would provide model notices for employers to communicate key provisions to employees. 

Those notices are now available – one for the private sector and the other for federal workers: 

• Employee Rights: Paid Sick Leave and Expanded Family and Medical Leave under The Families First Coronavirus Response Act (FFCRA)

• Federal Employee Rights: Paid Sick Leave and Expanded Family and Medical Leave under The Families First Coronavirus Response Act (FFCRA)

The DOL has also provided a list of frequently asked questions (FAQ), in an effort to provide much-needed clarification for employers struggling to understand and plan for implementation of the Act.
Families First Coronavirus Response Act Notice – FAQ

The DOL has determined the Act will take effect on April 1, which notably is one day earlier than the anticipated April 2 date suggested by the statute’s language. As such, the appropriate employee notice must be posted in a conspicuous place in the workplace on or before that date. For employees who are working remotely, employers should provide the notice via email or US Mail, or by posting on an internal or external website.   The notice must only be provided to employees currently working and applicants.

The DOL has indicated it intends to continually issue additional guidance on a rolling basis – and is currently soliciting public input for use in developing compliance materials and regulations. At this time, the DOL has not provided a specific date when it plans to publish regulations, only that it will be sometime in April 2020 – which unfortunately will be after the Act’s effective date. We will continue to monitor the DOL’s release of clarification, along with other COVID-19-related developments, and will update you, as additional guidance and information become available.  In the meantime, please contact a member of our Labor and Employment Law Group with any questions.

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