DOL Clarifies Effective Date of Certain Provisions of FFCRA

According to information on the U.S. Department of Labor’s (DOL) website,  the paid leave provisions of the Families First Coronavirus Response Act (FFCRA),  which includes the Emergency Paid Sick Leave Act and the Emergency Family and Medical Leave Expansion Act, will become effective on Wednesday, April 1, 2020.

Additionally, the DOL announced in a Field Assistance Bulletin that there will be a temporary non-enforcement  period of FFCRA from March 18 through April 17. During this grace period, no enforcement actions will be taken against private or public employers for non-compliance as long as they are able to show that they have made “reasonable, good faith efforts to comply with the Act.” This means:

1. Any violations are remedied as soon as is practical.
2. The violations were not made willfully.
3. The employer must send written notification to the DOL stating it will comply with the Act in the future.

The DOL will begin fully enforcing the Act after April 17, 2020.