March 25, 2020
For those who have been following along or keeping up with Federal legislative updates in response to the COVID-19 pandemic, you are aware that the Families First Coronavirus Response Act (FFCRA) was signed into law one week ago, March 18, 2020. There are still a number of “unknowns” out there with regard to these requirements that we will continue to monitor and update. For today, there are a few updates and responses to some common questions I’d like to share.
As always, for specific questions related to your unique situation, you are best off checking with your legal and/or accounting team.
- The law goes into effect on April 1, 2020. Any previous statements that the law goes into effect on April 2, 2020, were in error. Additionally, the law is NOT retroactive, meaning there are no requirements to provide the leave before April 1, 2020, nor are the tax credits available for that type of leave given voluntarily before April 1, 2020. The Department of Labor – today – released the model notice that must be posted in the workplace. You can find a link to that notice here.
- If your workplace is currently closed, those can be posted upon your reopening; providing this information virtually before the workplace reopens is likely also a prudent step. If you have been able to convert some or all of your workforce to a remote system, these notices should be shared with your employees in whatever manner you are communicating with them while working remotely.
- With Wisconsin’s Safer at Home Order from Governor Evers, all non-essential businesses have been ordered to close. As this is unprecedented and a developing area, the best resources to check how this order impacts your business and what your official “status” is are this website and the Order.
Keep returning here for updates and more information. We will be sharing additional information on small business resources and the tax credits in the coming days.
1) The information above does not constitute legal advice, nor does it create an attorney-client relationship. Please consult your attorney with specific questions.
2) As this situation is constantly changing, we will make every effort to stay current on this topic, however, this information is provided as general guidance and may not apply to your situation, nor should it be relied upon exclusively; Please consult and confirm with your attorney if you have questions about these updates or their applicability.
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