On Friday, March 20, we provided an update on the Families First Coronavirus Response Act (“FFCRA”). Today, the US Department of Labor released Q&A Guidance on FFCRA, which may be accessed here.
The Q&A Guidance website also includes a link to the employee notice concerning FFCRA, which may be accessed here. The notice is to be posted in a conspicuous place on the employer’s premises, which includes emailing or direct mailing the notice to employees, or posting the notice on an employee information internal or external website.
Importantly, the Q&A guidance sets the effective date of FFCRA as April 1, 2020.
At this time, we continue to await regulations implementing FFCRA to be issued by the US Department of Labor, as well as guidance from the US Department of the Treasury regarding the tax credits against an employer’s social security quarterly taxes to help offset the costs of the FFCRA. We will continue to monitor the situation and provide updates as they become available.
The COVID-19 pandemic and response is an evolving situation. All levels of government are engaged in the process of preparing new legislation, regulations and orders both to stem the spread of the virus and to provide relief to employers and employees. We will continue to monitor the situation and provide updates as applicable, especially as such updates affect healthcare providers and their practices.