FFCRA Poster/Enforcement Guidance

Newsbrief

Yesterday, the DOL released the FFCRA poster that covered employers need to post by April 1.  You can download a copy here:

https://www.dol.gov/sites/dolgov/files/WHD/posters/FFCRA_Poster_WH1422_Non-Federal.pdf

If your office is open, post this in a common area.  Otherwise – or if you have employees working remotely – either post it on your intranet or external website or email it to your employees. You do not need to post this in any language other than English.  You do need to provide it to new hires on or after April 1.  Finally, this posting requirement applies only to covered employers, that is employers with less than 500 employees or public employers.

The DOL also issued a field bulletin on FFCRA enactment.  For the first 30 days of the FFCRA’s enactment – that is, through April 17 – it is not to be enforced if the employer is in good faith.  Good faith means (1) you agree to remedy any violations, including making employees whole, as soon as practicable, (2) you were not acting willfully, and (3) you commit in writing to comply with the FFCRA in the future.

Stay safe and keep the course.  And please let us know if we can be of any help.

Thanks, Jack, Elizabeth and Jim

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