On March 18, 2020, the President signed the Families First Coronavirus Response Act (the “Act”). Yesterday, the U.S. Department of Labor provided sample posters for private and public employers to post prior to April 1, 2020.
Also, the DOL provided guidance regarding the manner of providing notice to employees where offices are closed or employees are not regularly reporting to the office. Specifically, the DOL authorized posting the notices on a company’s intranet, internet, emailing the notices to the employees and other methods of notifying employees. Here is a link to the DOL guidance on notice posting requirements.
The DOL has issued some initial guidance on the Act, and plans to provide further guidance in April, 2020. Notably, the DOL has stated that it will not issue guidance on whether the Act will apply to employers with less than 50 employees until the regulations are published in April 2020.
Finally, the DOL has advised that the DOL “will not bring enforcement actions against any public or private employer for violations of the Act occurring within 30 days of the enactment of the FFCRA, i.e. March 18 through April 17, 2020, provided that the employer has made reasonable, good faith efforts to comply with the Act.”
HMB Legal Counsel will continue to provide updates as the situation evolves. The ongoing issues related to the spread of the Coronavirus (COVID-19) have had and will continue to have a significant impact on individuals, families, businesses and markets. Visit our collection of resources providing guidance during these fast-changing circumstances. Please reach out to your HMB team member to answer specific questions.
Guidance and references are subject to change due to developments in laws.