Businesses Only Have Until April 1 to be FFCRA Compliant, Including Posters and Policies
April 1 is the effective date of the Families First Coronavirus Response Act. It is also the deadline for any employer with fewer than 500 employees to come into compliance with the paid family leave and paid sick leave requirements of the Families First Coronavirus Response Act. This compliance includes posting or otherwise disseminating the mandatory FFCRA Employee Rights poster, and distributing a policy to your employees covering this new breed of leave.
The Department of Labor has published the required poster on its website, free to download as a PDF here. You should download it, and must post it no later than April 1.
A few notes of special import about the poster:
1. Each covered employer (any business with fewer than 500 employees) must post the notice in a conspicuous place on its premises.
2. For remote employees, an employer must also email, direct mail, or post online the notice.
3. Even if employees speak languages other than English, employers are not required to post the notice in multiple languages (but the DOL says that it is working to translate it anyway).
4. Employers do not have to provide the notice to laid-off employees, only current employees. It’s unclear if this also includes, or does not include, employees on furlough; hopefully the regulations the DOL is supposed to publish “soon” will clear this up.
For the necessary policy for your business to manage its paid leave obligations under the Act, contact any Meyers, Roman Labor & Employment Attorney prior to April 1:
Managing Partner:
Seth Briskin / sbriskin@meyersroman.com
Partner and Coronavirus Response Team Lead:
Jon Hyman / jhyman@meyersroman.com