The Families First Coronavirus Response Act (FFCRA) goes into
effect April 1, 2020, and over the past week, the Department of
Labor (DOL) has issued several rounds of guidance pertaining to the
FFCRA, including a list of Frequently Asked Questions (FAQs). The
FAQs address many of the issues raised by employers regarding
Emergency Paid Sick Leave (EPSL) and Emergency FMLA leave (E-FMLA),
some of which Reinhart highlighted as then-outstanding issues
during its
March 20, 2020, seminar regarding workplace issues due to
COVID-19.
One of the issues highlighted by the DOL's FAQs is what
happens when an employer temporarily or permanently lays off
employees before or after April 1, 2020, the date the FFCRA goes
into effect. Employers should consider the relief provided under
the CARES Act, which was signed into law on March 27, 2020, in
assessing their options with regard to their employees. Employers
can find information about the CARES Act in Reinhart's
Coronavirus