Families First Coronavirus Response Act: Effective April 1, 2020

On Tuesday, March 24, 2020, the Department of Labor (“DOL”) announced that the effective date of the emergency leaves provided through the Families First Coronavirus Response Act (FFCRA) will be April 1, 2020. Based on the language in the bill, the effective date was believed by many to be April 2.

The DOL announced the effective date in a “Questions and Answers” document where it also provided helpful answers to some common questions:

Questions and Answers

The DOL also released the Employee Rights poster that must be posted in a conspicuous place in the workplace by employers who have fewer than 500 employees:

FFCRA Poster  ← click for poster  

For employees who are working remotely, the posting requirement can be satisfied by e-mailing or direct mailing the notice to employees, or posting it on an employee information internal or external website. You are only required to provide the notice to current employees; therefore, you are not required to share this notice with any employee who has already been laid-off.

We are still waiting for the DOL’s regulations to answer questions about how these emergency leaves will be administered and how they will interact with other leaves.

We will post further, updated information as soon as it becomes available.

By: Rebecca L. Gombos, Esq.