Late on Tuesday, March 24, 2020, the U.S. Department of Labor
("DOL") released its first guidance for employers
attempting to navigate the paid leave provisions of the Families
First Coronavirus Response Act ("FFCRA"). Because the DOL
has yet to issue any regulations to implement the Emergency Paid
Sick Leave Act ("EPSLA") and the Emergency Family and
Medical Leave Expansion Act ("EFMLEA"), the guidance
addresses some of the questions that have arisen since the
law's passage.
The following is a brief recap of what we believe are the most
important points from the guidance. However, for more information,
you can download the guidance here.
Effective Dates
- The law takes effect on April 1, 2020 and lasts through
December 31, 2020. Before this guidance, it was believed that the
law would take effect on April 2, 2020 but the DOL guidance states
that it will go into effect a day earlier.
