UPDATED: $484 Billion Stimulus Package Signed Into Law

On April 24th , President Donald J. Trump approved a new stimulus relief package that includes hundreds of billions of dollars in new funding for small businesses hurt by the coronavirus outbreak. The $484 billion package also includes monies for hospitals and expanded COVID-19 testing. This proposed bill comes after the passage of a $2 trillion rescue package that Congress approved last month.

To specifically support small businesses, the stimulus authorizes an additional $320 billion to fund the Paycheck Protection Program (PPP), which was created as part of March’s unprecedented rescue package. The PPP consisted of offering forgivable loans to small businesses to pay their employees during the COVID-19 crisis. Due to a lapse in appropriations funding, as of April 17th, the Small Business Administration (SBA) was unable to accept any new applications for the PPP.

Many of the large banks who were accepting applications for the PPP carried stipulations that they would only work with businesses who were current members. In order to better serve potential applicants, $60 billion of the $320 billion earmarked for the PPP has been carved-out for community-based lenders, as well as mid-sized banks, which can better serve smaller businesses and minority-owned firms, organizations that are less likely to have an existing relationship with a larger bank.

The $484 billion stimulus package also contains $60 billion for the SBA’s Economic Injury Disaster Loan Program, which offers emergency grants of up to $10,000 to businesses awaiting funding on a disaster loan. Like the PPP, this program also ran out of funding earlier this month.

Now that this stimulus package has been signed into law by the President, funding should quickly begin again on both programs.

Other SBA Funding Programs

Due to the fact that initial funding for both the PPP and Economic Injury Disaster Loan Program ran out in a matter of days, small businesses should be aware that the SBA does offer other loan options that are not necessarily COVID-19 related. These programs include:

  • 7(a) program – This program offers loans up to $5,000,000 as an all-inclusive loan for eligible businesses. The funds can be used for working capital, expansion/renovation, new construction, land purchase or building purchase, equipment purchase, fixtures, lease-hold improvements, debt refinancing for compelling reasons, seasonal lines of credit, inventory, or to start a business.
  • Express loans – These can provide up to $350,000 for up to seven years with an option to revolve the loan. Turnaround time is about 36 hours to know if you are approved or denied.
  • 504 loan – This loan is limited for the acquisition of refinancing of fixed assets. It is to help with job creation and retention.
  • Microloans – Nonprofit lending organizations may offer microloans to underserved markets. These loans can be funded up to $50,000 and must be used for working capital, supplies, machinery, equipment, or fixtures but not real estate.
  • Export loans – The SBA offers a number of export loans for small businesses. These include the Export Express loan, Export Working Capital program, and International Trade loan program.
  • The 8(a) Business Development program was created for small businesses owned by economically or socially disadvantages entities or individuals.

The SBA has also announced the Small Business Debt Relief Program, where they will cover all loan payments on non-disaster SBA loans, including 7(a), 504, and microloans, consisting of principal, interest, and fees, for six months. This program would apply to businesses that qualify for and receive funding prior to September 27th, 2020.


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top

EEOC Updates COVID-19 Guidance on Anti-Discrimination Laws

On April 23rd, 2020, the Equal Employment Opportunity Commission (EEOC) announced additions to their technical assistance guidance, “What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws,” providing employers with crucial information on how to avoid possible workplace discrimination claims during the coronavirus pandemic.

Provided in a “question and answer” format, the frequently updated resource covers topics important to employers today dealing with the employment ramifications of COVID-19. The subject matter discussed all falls under the EEOC’s enforcement of workplace anti-discrimination laws including:

Specific COVID-19-related information within the guidance includes:

  • Disability-Related Inquiries and Medical Exams;
  • Hiring and Onboarding;
  • Reasonable Accommodations;
  • Pandemic-Related Harassment; and
  • Returning to Work

The EEOC wants to remind employers that all EEO laws are in full effect during the time of the global coronavirus pandemic. Just as the COVID-19 pandemic evolves, so does the guidance provided by the EEOC and other government agencies. To keep up to date on any releases involving workplace anti-discrimination laws during this uncertain time, employers can visit the EEOC Newsroom webpage for any new and important information.


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top

White House Issues Guidance on Reopening the United States

During a conference call with United States governors, President Donald Trump unveiled his guidelines for “Opening Up America Again.” The call, which took place on April 16th, outlined recommendations made by the White House for states to reopen based on several factors. The overall plan also contains three phases that must be followed by individuals and employers for states to begin easing social distancing measures and stay-at-home orders. Each phase would allow more and more restrictions to be lifted. There are some guidelines, however, that must be followed throughout the entire process of reopening and, possibly, afterwards.

Criteria for States to Achieve Before they Can Begin Phased Openings

  • Symptoms: There must be a downward trajectory of influenza-like illnesses (ILI) reported within a 14-day period AND a downward trajectory of COVID-19-like syndromic reported within a 14-day period.
  • Cases: There must be a downward trajectory of documented cases within a 14-day period OR a downward trajectory of positive tests as a percent of total tests within a 14-day period (flat or increasing volume of tests).
  • Hospitals: Hospitals must treat all patients without crisis care AND create a robust testing program for at-risk healthcare workers, including emerging antibody testing.

Guidelines for All Phases for Individuals

The guidelines call for individuals to always practice the following instructions, no matter what stage of reopening the state is in:

Continue to Practice Good Hygiene

  • Wash your hands with soap and water or use hand sanitizer, especially after touching frequently used items or surfaces.
  • Avoid touching your face.
  • Sneeze or cough into a tissue, or the inside of your elbow.
  • Disinfect frequently used items and surfaces as much as possible.
  • Strongly consider using face coverings while in public, and particularly when using mass transit.

People who Feel Sick Should Stay Home

  • Do not go to work or school.
  • Contact and follow the advice of your medical provider.

Guidelines for All Phases for Employers

Employers would also be required to follow specific steps throughout the reopening process:

Develop and Implement Appropriate Policies

  • The policies need to be in accordance with federal, state, and local regulations and guidance, and be informed by industry best practices, regarding:
    • Social distancing and protective equipment
    • Temperature checks
    • Sanitation
    • Use and disinfection of common and high-traffic areas
    • Business travel
  • Create policies and procedures on workforce contact in order to trace employee movement after a positive COVID test.

Monitor Workforce for Indicative Symptoms

  • Do not allow symptomatic people to physically return to work until cleared by a medical provider

For more information on the guidelines to reopen America, including specific information for individuals and employers for each phase of the process, the White House has posted guidance on their website.

 

 


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top

OSHA Releases Enforcement Guidance on Recording COVID-19 Cases

On April 10th, the U.S. Department of Labor’s (DOL’s) Occupational Safety and Health Administration (OSHA) issued interim guidance for enforcing OSHA’s recordkeeping requirements (29 CFR Part 1904) as it relates to recording cases of COVID-19.

Overview of OSHA Recordkeeping Requirements

Under OSHA recordkeeping rules, many employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. (Some low-risk industries are exempted from the recordkeeping rule.) Examples of work-related injuries or illnesses that must be recorded include:

  • Any work-related fatality.
  • Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
  • Any work-related injury or illness requiring medical treatment beyond first aid.
  • Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.

The records must be maintained at the worksite for at least five years and, each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. Also, if requested, copies of the records must be provided to current and former employees, or their representatives.

Recording COVID-19 Cases

Due to the wide scope of the current global pandemic, OSHA has announced that COVID-19 is now considered a recordable workplace illness and that employers are responsible for reporting cases of the virus if the following benchmarks are met:

  • The case is confirmed as a COVID-19 illness;
  • The case is work-related (i.e. an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness) as defined by 29 CFR 1904.5; and
  • The case involves one or more of the general recording criteria found in 29 CFR 1904.7, such as death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness.

OSHA does realize, however, that in areas where there is ongoing community COVID-19 transmission, employers other than those in the healthcare industry, emergency response organizations, and correctional institutions may have difficulty making determinations about whether workers who contracted COVID-19 did so due to exposure at work. Accordingly, until further notice, OSHA will not enforce its recordkeeping requirements to require these employers to make work-relatedness determinations for COVID-19 cases, except where:

(1) There is objective evidence that a COVID-19 case may be work-related; and

(2) The evidence is reasonably available to the employer. Employers of workers in the healthcare industry, emergency response organizations, and correctional institutions must continue to make work-relatedness determinations pursuant to 29 CFR Part 1904.

The guidance took effect the date of release (April 10th, 2020) and, even though it is intended to be time-limited for the duration of the coronavirus pandemic, will remain in effect until further notice.


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top

Reminder: Retaliating Against Workers Who Report Unsafe Pandemic Conditions is Illegal

In this incredibly uncertain time, when things seem to be changing on a daily basis, the U.S. Department of Labor (DOL) wants to remind employers that some things have not changed: it is still illegal to retaliate against workers who report unsafe and unhealthful conditions to the Occupational Safety and Health Administration (OSHA). Acts of retaliation can include:

  • terminations,
  • demotions,
  • denials of overtime or promotion, or
  • reductions in pay or hours.

During the global COVID-19 pandemic, some employees may feel that their supervisors are not doing enough to keep them safe from exposure. Those employees could find themselves requesting better conditions from their managers, but then suffering consequences due to that request. In that situation, OSHA welcomes feedback.

“Employees have the right to safe and healthy workplaces,” said OSHA Principal Deputy Assistant Secretary Loren Sweatt. “Any worker who believes that their employer is retaliating against them for reporting unsafe working conditions should contact OSHA immediately.”

Employers who have retaliated against workers for voicing their concerns about unsafe conditions are in violation of OSHA’s Whistleblower Protection Program. This Program enforces the whistleblower provisions of more than 20 whistleblower statutes, protecting employees for reporting violations of various workplace safety and health laws and for engaging in other related protected activities.

Any affected worker has a right to file a whistleblower complaint online with OSHA (or 1-800-321-OSHA) if they believe their employer has retaliated against them for exercising their rights under the whistleblower protection laws enforced by the agency. Each law has a filing deadline, varying from 30 days to 180 days, which starts when the retaliatory action occurs.

A whistleblower complaint must allege four key elements:

  • The employee engaged in activity protected by the whistleblower protection law(s) (such as reporting a violation of law);
  • The employer knew about, or suspected, that the employee engaged in the protected activity;
  • The employer took an adverse action against the employee;
  • The employee’s protected activity motivated or contributed to the adverse action.

Employers who are found to have violated an employee’s rights under the whistleblower statutes could be subject to fines and penalties.

By responding to employee complaints and avoiding any appearance of retaliating against the individual making those complaints, employers will be meeting their OSHA obligations as well as keeping workers safe and protected in this difficult time.

 


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top

Final Rule Clarifies FFCRA Paid Sick Leave and Emergency Leave Obligations

On Monday, April 6th, the United States Department of Labor (DOL) released a final rule in the Federal Register interpreting the emergency paid sick leave (EPSL) and emergency family & medical leave (EFML) provisions of the Families First Coronavirus Response Act (FFCRA or Act). This latest rule offers more clarification into different parts of the Act, most notably requirements for proper documentation, recordkeeping, and exemption rules.

Documentation

There are different kinds of documentation that employers should require employees to submit depending on the reason for leave. If an employee is applying for leave under the EPSL provisions of the FFCRA, which allows for two weeks of paid leave, employees must provide:

  • A signed statement containing their name;
  • The date leave requested;
  • The COVID-19 qualifying reason for leave; and
  • A statement that they are unable to telework or work because of the COVID-19 reason.

Employees must also provide additional documentation based on the reason for leave:

  • If the employee is under quarantine, they need to provide the name of the government entity or health care provider that issued the quarantine order.
  • For leave to care for a child due to closure of school or daycare, documentation must include the name of the child being cared for, name of the school or child care provider and statement that it is closed due to COVID-19, and a statement that no other suitable person is available to care for the child during the period of requested leave.
  • For the care of an individual, the documentation needs to include the name of the government entity or isolation order that the individual is subject to, or the name of the health care provider advising the quarantine due to COVID-19 reasons.

Employees applying for leave under the EFML provisions, which allow 12 weeks of paid leave, need to provide the following:

  • For leave to care for their child due to closure of school or daycare, employees must include the name of child being cared for, name of school or child care provider and that it is closed due to COVID-19, and a statement that no other suitable person is available to care for the child during the period of requested leave.
  • For leave taken for an employee’s own serious health condition related to COVID-19, or that of employee’s spouse, son, daughter, or parent with a serious health condition related to COVID-19, normal FMLA requirements apply.

Small Employer Exemption

The DOL’s latest Final Rule also clarifies the small business exemption included within the FFCRA. The exemption includes such requirements as:

  • It’s limited to small private employers with less than 50 employees.
  • Employers should document the facts and circumstances to justify the denial of leave to employees and retain with its records. This documentation does not have to be sent directly to the DOL, but should be retained in the event of an audit or investigation.
  • FFCRA paid sick leave may be denied if the leave would jeopardize the viability of the business as a going concern. Permissible reasons for denial of leave as listed in the final rule include having business expenses and obligations exceeding business revenues; lack of available qualified workers to perform the duties of the employee requesting leave; and when the employee’s leave would jeopardize the continuity of the business due to their specialized knowledge and abilities.

Recordkeeping

The Final Rule also states that an employer is required to retain all documentation provided by employees for four years, regardless of whether leave was granted or denied. If an employee provided oral statements to support his or her request for paid sick leave or expanded family and medical leave, the employer is required to document and retain that information also for four years. If an employer denies an employee’s request for leave pursuant to the small business exemption, as mentioned earlier, the employer must document its authorized officer’s determination that the prerequisite criteria for that exemption are satisfied and retain such documentation for four years. The Rule also explains what documents the employer should create and retain to support its claim for tax credits, from the Internal Revenue Service (IRS), including Form 7200 and Form 941. That tax credit documentation should also be kept for four years.


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top

New OSHA Poster Created to Help Reduce Exposure to COVID-19

On Monday, April 6th, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced that they have issued a new poster listing steps that all workplaces can take to reduce the risk of exposure to coronavirus. The release is the latest effort by OSHA to educate and protect America’s workers and employers during the coronavirus pandemic.

The non-mandatory poster highlights 10 infection prevention measures every employer can implement to protect workers’ safety and health. Safety measures include:

  • encouraging sick workers to stay home;
  • establishing flexible worksites and staggered work shifts;
  • discouraging workers from using other workers’ phones, desks, and other work equipment; and
  • using Environmental Protection Agency-approved cleaning chemicals with label claims against the coronavirus.

The new poster is available for download in English, or Spanish.

General Duty Clause

Even though the poster is not mandatory to be displayed in the workplace, all employers have an obligation to provide their employees with a place of employment that is “free from recognized hazards that are causing or are likely to cause death or serious physical harm.” This requirement is included within OSHA’s General Duty Clause. By following the suggested steps listed on the poster, employers can reasonably state that they took preventative measures to keep workers safe from contracting COVID-19 in the workplace.

Other Critical OSHA Resources on COVID-19

In addition to the poster, OSHA has several other resources available to provide guidance for employers to keep workers safe & comply with existing regulations during the COVID-19 crisis:

In this time of uncertainty due to the global COVID-19 pandemic, employers have a responsibility to keep the workplace safe from hazards, coronavirus being one of them. By following the information provided on the latest OSHA poster, employers can showcase their attempts to keep employees healthy and avoid receiving possible fines and penalties.


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top

Newly Enacted CARES Act Offers Loan Assistance to Small Businesses

Signed into law on March 27th, the Coronavirus Aid, Relief and Economic Security (CARES) Act creates a half-dozen new programs to help distressed businesses and workers deal with the global COVID-19 pandemic and any related shutdowns. Among those programs are forgivable small business loans and other types of loan assistance. A small business as defined under the CARES Act is one that employs fewer than 500 workers or fewer than the level set by the SBA for the employer’s industry.

Paycheck Protection Program

The Paycheck Protection Program, developed under the CARES Act, is a new forgivable loan program created to help small businesses pay their expenses and continue to keep their workers employed during the health crisis.

The Program provides loans of up to 250% of the employer’s average monthly payroll costs, with a cap of $10 million. Average monthly costs are determined by looking back one year from the date of the loan. An employer may use this loan to cover salaries, group health benefits, rent, utilities, and other specified expenses. Under the Act, however, the employer cannot use the loan to pay for other coronavirus-related benefits, such as paid leave under the Families First Coronavirus Response Act (FFCRA).

The Act gives the U.S. Small Business Administration (SBA) the authority to implement the program and make the loans available through existing lenders. The SBA will also waive standard fees and personal-guarantee requirements — no collateral is required. Instead, the SBA will require employers to certify that:

  • the employer needs a loan to support its operations;
  • the employer will use the loan to retain its workers, maintain payroll, or pay other qualifying expenses;
  • the employer does not have another application for the same purpose pending; and
  • the employer has not already received a loan covering the same period.

The loan comes with an interest rate of 4% or less but will be forgiven if the employer maintains its workforce for the covered period: February 15th, 2020, to June 30th, 2020. If the employer reduces its workforce during the covered period relative to last year, or reduces the salary or wages paid to an employee by more than 25%, the loan forgiveness will drop by the same percentage.

Small Business Debt Relief Program

For small businesses that currently already have non-disaster SBA loans, the CARES Act provides immediate relief for the carriers of those 7(a) loans, 504 loans, and microloans. Under the relief program, the SBA will cover all loan payments on these loans, including principal, interest, and fees, for six months. This relief will also be available to new borrowers who take out loans within six months of when President Trump signed the bill into law. Employers who are interested in applying for a 7(a), 504, or microloan can consult with the Small Business Administration for eligibility requirements.

Economic Injury Disaster Loans & Emergency Economic Injury Grants

Also under the CARES Act, small business owners in all U.S. states, Washington D.C., and territories are eligible to receive an Emergency Economic Injury Grant, which is an emergency advance of up to $10,000. First, however, employers must apply for an Economic Injury Disaster Loan (EIDL) and then they can request the advance. The advance does not need to be repaid under any circumstance, and may be used:

  • to keep employees on payroll;
  • to pay for sick leave;
  • meet increased production costs due to supply chain disruptions; or
  • pay business obligations, including debts, rent, and mortgage payments.

According to the SBA, employers requesting the advance can expect to receive it within three days of applying for an EIDL.

Mid-Sized Business Loan Program

It isn’t just small businesses that are covered under the CARES Act; there are provisions for mid-sized employers as well. Under the Act, mid-size businesses (those with 500 to 10,000 employees) can obtain a loan through the U.S. Treasury Department with no greater than a two-percent annualized interest rate, and no interest or principal payments for six months. This is to try and enable employers to retain at least 90 percent of their workforce, at full compensation and benefits, until September 30, 2020. One of the stipulations under this program, however, is that the borrowing employer must make a “good-faith certification” that they “will remain neutral in any union organizing effort for the term of the loan.” In other words, if a mid-sized company receives the loan, it is agreeing to waive its free speech rights and allow campaigns to unionize employees during the length of the full loan term. More information about this specific program should be released in the coming days.

For a full analysis of all the provisions under the CARES Act, the SBA has released a comprehensive guide for employers to better understand the new programs that are available to them.


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top

Enforcement of COVID-19 Paid Sick Leave Law Begins April 17th, 2020

Employers struggling to comply with new COVID-19 Paid Sick Leave provisions should note that official government enforcement actions will not begin until April 17th.

According to a Field Assistance Bulletin issued on March 25th, 2020, the U.S. Department of Labor (DOL) will not bring enforcement actions against any public or private employer for violations of the Families First Coronavirus Response Act (FFCRA) until April 17th, 2020, provided that the employer has made reasonable, good faith efforts to comply with the law.   The April 17th enforcement date coincides with a 30-day “stay period” beginning from the date the FFCRA was signed into law, which was March 18th, 2020.

The new law (which took effect on April 1st) requires businesses with less than 500 employees to provide up to two weeks of paid sick leave, plus emergency family and medical leave, to eligible employees for qualifying reasons related to the COVID-19 health crisis.   The paid sick leave will be refunded to the employer dollar-for-dollar via a refundable tax credit.

The DOL’s bulletin further explains that any employer who is found to have violated the FFCRA will be determined to have acted “reasonably” and “in good faith” when all of the following facts are present:

  1. The employer remedies any violations, including by making all affected employees whole as soon as practicable.
  2. The violations of the Act were not “willful”
  3. The Department receives a written commitment from the employer to comply with the Act in the future.

Conversely, employers who are found to willfully violate the Act and do not demonstrate a commitment to future compliance and employee protections will be subject to potential fines and penalties.

After April 17th, 2020, this limited stay of enforcement will be lifted, and the Department will fully enforce violations of the Act, as appropriate and consistent with the law.  The agency will retroactively enforce violations back until the effective date of April 1, 2020, if employers have not remedied the violations.  These penalties could cost the employer up to $10,000 for each willful violation or result in imprisonment.

For information and communication solutions regarding the COVID-19 pandemic, please visit our online COVID-19 Resource Center. 


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top

Recent & Upcoming Compliance Deadlines and Effective Dates for Employers

As America’s business owners continue to cope with the harsh realities of the COVID-19 pandemic, it’s easy to lose sight of key dates and deadlines pertaining to workplace compliance.  Though federal guidelines can change, the following important effective dates and compliance deadlines have not yet been delayed or postponed due to the national health crisis:

March 16th, 2020 – The U.S. Department of Labor’s (DOL) final rule on joint employer status under the Fair Labor Standards Act (FLSA) officially took effect.  The final rule provides updated guidance for determining joint employer status when an employee performs work for his or her employer that simultaneously benefits another individual or entity, including guidance on the identification of certain factors that are not relevant when determining joint employer status.

April 1st, 2020 – The emergency paid sick leave provisions of the Families First Coronavirus Response Act (FFCRA) take effect for businesses with less than 500 employees on payroll.  The new law provides two weeks of paid sick leave related to COVID-19 for qualifying workers. Additionally, employers must post a new mandatory workplace poster regarding these provisions.

April 17th, 2020 – Enforcement of the FFCRA paid sick leave provisions officially begins on this date, according to a Field Assistance Bulletin issued by the DOL.   The agency had initiated a 30-day “stay” period regarding enforcement after the law was enacted on March 18th, 2020.

April 30th, 2020 – Employers must begin using the revised Form I-9 (version 10/21/19) for all new hires by no later than this date.  Prior to April 30th, the previous version (07/17/2017 N) was still acceptable for use.

Personnel Concepts will continue to notify and remind customers of important dates and deadlines as the nation’s business community continues to face challenges from the global pandemic.  We will also notify customers if any of these dates are postponed or changed.   Please continue to check our blog for the latest information.


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
GoTo top Top