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:

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

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:

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:

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

Jon Hyman, Partner and Coronavirus Response Team Leader

Lester Armstrong, Counsel

Steven Dlott, Partner

Mark Gottfried, Partner

Joseph Pokorny, Associate