DOL FFCRA Alert – April 1 Effective Date for FFCRA Leave due to COVID-19
On Tuesday, March 24, the Department of Labor (DOL) announced that the effective date of the leaves available through the Families First Coronavirus Response Act (FFCRA) will be April 1, 2020. Based upon the bill’s original language, the effective date was widely believed to be April 2, 2020.
The DOL announced the effective date in a “Questions and Answers” document where it also provided answers to some common questions. Other than the April 1 effective date, the information is in line with prior guidance. The DOL also released two Fact Sheets, both of which appear to contain the same information. It is possible that they are building a framework for future updates with different pages for Employees and Employers. Here are the links:
- DOL/Wage & Hour – Questions and Answers
- DOL/Wage & Hour –Fact Sheet for Employees and a Poster
- DOL/Wage & Hour –Fact Sheet for Employers and Poster Questions
While the links above do not provide much new information, they are worth reviewing. We are still waiting on regulations from the DOL to answer many questions about how these leaves will be administered and how they will coordinate with other leaves (sick, PTO, etc.) as well as any corresponding offsets to other claims, like STD, TDI (in NJ, NY, HI, RI, PR, CA), and Worker’s Compensation claims.
Please speak with your Account Manager or Executive regarding any questions you may have.
Prior COVID-19 Related Guidance:
- 3/23 IRS/Treasury/DOL plan to implement Coronavirus-related paid Leave and Tax Credits
- 3/19 FFCRA – New Federal Law Mandates Paid Sick Leave & Enhanced Unemployment
- 3/16 Overwhelming Vote Passes Coronavirus Relief Bill
- 3/16 CMS FAQs on Essential Health Benefits and COVID-19
- 3/11 IRS HDHP-HSA plans may cover Coronavirus costs as preventive care
- 2/28 COVID-19 preparations, Be Prepared but don’t panic