FFCRA Emergency Paid Leave Posting

Families First Coronavirus Response Act (FFCRA) Emergency Paid Leave Posting

As many of you are aware, the Families First Coronavirus Response Act (FFCRA) Emergency Paid Family & Medical Leave Act and Emergency Paid Sick Leave provisions become effective tomorrow, April 1st.  I had hoped that the U.S. DOL would have published draft Regulations by the close of business today and prior to April 1st to give employers an indication as to how these provisions will be administered by the U.S. DOL.  As of the time of this email, the U.S. DOL has not published anything aside from the Frequently Asked Question (FAQs).  The U.S. DOL published FIELD ASSISTANCE BULLETIN No. 2020-1 that states that they will not bring enforcement actions against any employer who is out of compliance provided they can demonstrate that they have made a reasonable good faith effort to comply with the law.  We will make sure that we notify you as soon as the draft Regulations are published to ensure your organization is compliant.

In the meantime, covered employers are required to post the Federal Employee Notice or the Non-Federal Employee Notice  in the same locations that they post similar notices by April 1, 2020.  Additionally, you can email it to your employees.   I will tell you that there is an error on the notice that I had hoped the U.S. DOL would have provided an updated notice, but none has been published thus far.  The error is in the third bullet under the section titled Paid Leave Entitlements.  The maximum total amount is $10,000 and not $12,000 as printed.  I have confirmed from the actual text in the FFCRA.  The U.S. DOL also has published FAQs relative to the posting.

If members have questions about the FFCRA or other provisions, please contact the AAA.

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coronavirus, COVID-19, Department of Labor (DOL), Families First Coronavirus Response Act (FFCRA)

Scott Moore

Scott A. Moore, Esq. has been in the emergency medical services field for over 26 years. Scott has held various executive positions at several ambulance services in Massachusetts. Scott is a licensed attorney, specializing in Human Resource, employment and labor law, employee benefits, and corporate compliance matters. Scott has a certification as a Professional in Human Resources (PHR) and was the Co-Chair of the Education Committee for the American Ambulance Association (AAA) for several years. In addition, Scott is a Site Reviewer for the Commission on the Accreditation of Ambulance Services (CAAS). Scott earned his Bachelor’s Degree in Psychology from Salem State College and his Juris Doctor from Suffolk University Law School. Scott maintains his EMT and still works actively in the field as a call-firefighter/EMT in his hometown. Scott is a member of the American Bar Association, the Massachusetts Bar Association, the Society for Human Resource Management, and the Northeast Human Resource Association.

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