Yesterday afternoon, on March 25, 2020, the U.S. Department of Labor’s Wage and Hour Division issued its model notices that meet the requirements of the Families First Coronavirus Response Act (“FFCRA”). The DOL provided a model notice for private sector employees and for public employees. All employers covered by the paid sick leave and expanded family and medical leave provisions of the FFCRA are required to post the notice in a conspicuous place at work.
In addition to the model notices, yesterday the DOL also provided guidance regarding the posters, in the form of a Frequently Asked Questions document, which can be found here. Of note, the DOL addressed dissemination of the notice to employees currently teleworking and explained that the notice-posting requirement may be satisfied by emailing or direct mailing the notice to employees or posting the notice on the company intranet or external website.
The DOL was under a tight deadline to issue the notices. Therefore, it is possible that the notices may be fine-tuned between now and the Act’s effective date: April 1. Employers should continue to check the Wage and Hour Division’s website to ensure they remain current with all notice requirements.
If you have questions, please contact Kean Miller labor and employment attorneys, Brian R. Carnie (318.562.2652), Chelsea G. Caswell (225.382.3405), A. Edward Hardin, Jr. (225.382.3458), Scott D. Huffstetler (225.389.3747), Erin L. Kilgore (225.389.3712), Michael D. Lowe (318.562.2653), Zoe W. Vermeulen (504.620.3367), and David M. Whitaker (504.620.3358).