Department of Labor’s Regulations Implementing the Paid Family and Sick Leave Provisions of the FFCRA Contain Big Changes and Clarifications

by Jonathan Hyman

Late in the afternoon on April 1, the Department of Labor published its regulations implementing the paid family leave and paid sick leave provisions of the Families First Coronavirus Response Act (“FFCRA”). These regulations contain substantive changes and clarifications to how we have (and in many key instances the DOL itself has) been interpreting the Act since its passage on March 18. You can read the full 124 pages of the DOL’s regulations and executive summary here:

https://s3.amazonaws.com/public-inspection.federalregister.gov/2020-07237.pdf

For your benefit, we have summarized the regulation’s key provisions at our Coronavirus Law Blog, which you will find here:

https://www.ohioemployerlawblog.com/2020/04/coronavirus-update-4-2-2020-dols-ffcra.html

Also be aware that the IRS has issued strict guidelines on the information that an employer must gather, keep, and submit to qualify for the available payroll tax credit for paid family leave and paid sick leave provided to employees under the FFCRA. We have summarized those requirements here:

https://www.ohioemployerlawblog.com/2020/04/coronavirus-update-4-1-2020-mechanics.html

On Friday, April 3 at 10 am ET, Partner and Coronavirus Response Team Leader Jon Hyman will be holding a live information session on these regulations. He will also be answering your coronavirus-related legal questions. You can join Jon on Zoom here:

https://zoom.us/j/976011327

For more information on how these regulations impact your business, for help bringing your business into compliance with the FFCRA (including forms, policies, and documentation), or for any other assistance with your coronavirus-related issues, contact any member of the MRFL Labor & Employment Group:

Seth Briskin, Managing Partner and Labor & Employment Chair
sbriskin@meyersroman.com

Jon Hyman, Partner and Coronavirus Response Team Leader
jhyman@meyersroman.com

Lester Armstrong, Counsel
larmstrong@meyersroman.com

Steven Dlott, Partner
sdlott@meyersroman.com

Mark Gottfried, Partner
mgottfried@meyersroman.com

Joseph Pokorny, Associate
jpokorny@meyersroman.com