What is the effective date of the Families First Coronavirus
Response Act ("FFCRA")?
The DOL has indicated the effective date for FFCRA is April 1,
2020, and the paid leave provisions only apply to leave taken
between April 1, 2020 and December 31, 2020. According to what
we've seen from the Department of Treasury, leave provided
before April 1 will NOT be eligible for offsetting tax credits.
Do workers who cannot work due to the Governor Whitmer's
Shelter-in-Place Order qualify for paid sick leave pursuant to the
FFCRA?
Neither the Federal government nor State of Michigan has
provided official guidance on whether the Governor Whitmer's
Shelter-in-Place Order is considered a State quarantine or
isolation order related to COVID-19. We believe it is, but know
that there are other law firms who have taken exception to that
conclusion. If we're wrong, then unless workers have another
qualifying reason to be off work besides the Governor's order
– and there are
