Wednesday, March 25, 2020

Coronavirus Update 3-25-2020 number 2: Someone needs to tell the DOL that 15 days from March 18 is April 2, NOT April 1

The Families First Coronavirus Response Act has an effective no later than 15 days after President Trump signed it. He signed in late in the day on March 18. We all did the math, and calculated an effective date of April 2. We all did the math.

Which is why we were all surprised when the DOL published a Q&A yesterday and announced an effective date of April 1.
What is the effective date 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? 
The FFCRA’s paid leave provisions are effective on April 1, 2020, and apply to leave taken between April 1, 2020, and December 31, 2020.

Apparently, everyone can count to 15 except the Department of Labor.

Yes, I understand that the statute says “not later than 15 days.” But everyone has been assuming this means 15 days. Instead, the DOL chose a nice round 14 days / April 1 start date. So everyone better roll out those policies ASAP. We have a day less than originally planned to comply.