COVID-19: April 1 Effective Date for FFCRA Leaves
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 on the language in the bill, the effective date was widely believed to be April 2.
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 what we have been advising. The DOL also released two Fact Sheets, both of which appear to contain the same information, but it’s possible they will each be updated in the future with information that is geared more toward employees or employers.
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 interact with other leaves. We will post updated information in the BASIC Blog as soon as it is released.
This information was provided by BASIC’s HR Support Center. To receive regular law alerts, online HR forms, checklists, documents, and unlimited access to HR Pros for questions, request a proposal for BASIC’s HR Assist Lite solution!
If I have employees that are out prior to April 1 for Covid-19 reasons should we be paying the paid sick leave? Can we pay these employees and still get the payroll tax credit?
Leave Given Prior to Effective Date of Law Cannot be Credited Later
As expected, the DOL Q&A confirms that expanded FMLA and paid leave are effective beginning on April 1. Any paid leave provided before April 1 will not count towards the new requirements and will not be eligible for the tax credits available under the law.