DOL Issues Poster on the Families First Coronavirus Response Act
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March 26, 2020
Yesterday, DOL issued the required poster under the Families
First Cornvirus Response Act. In addition, the DOL issued
questions and answers to help employers to comply. See below:
1. Where do I post this notice? Since most of my workforce is
teleworking, where do I electronically "post" this notice?
Each
covered employer must post a notice of the Families First Coronavirus
Response Act (FFCRA) requirements in a conspicuous place on its premises. An
employer may satisfy this requirement by emailing or direct mailing this
notice to employees, or posting this notice on an employee information
internal or external website.
2. Do I have
to post this notice in other languages that my employees speak? Where can I
get the notice in other languages?
You are not
required to post this notice in multiple languages, but the Department of
Labor (Department) is working to translate it into other languages.
3. Do I have
to share this notice with recently laid-off individuals?
No, the
FFCRA requirements explained on this notice apply only to current employees.
4. Do I have
to share this notice with new job applicants?
No, the
FFRCA requirements apply only to current employees. Employers are under no
obligation to provide the notice of those requirements to prospective
employees.
5. Do I have
to give notice of the FFCRA requirements to new hires?
Yes,
if you hire a job applicant, you must convey this notice to them, either by
email, direct mail, or by posting this notice on the premises or on an
employee information internal or external website.
6. If my
state provides greater protections than the FFCRA, do I still have to post this notice?
Yes, all covered
employers must post this notice regardless of whether their state requires
greater protections. The employer must comply with both federal and state
law.
7. I am a
small business owner. Do I have to post this notice?
Yes. All
employers covered by the paid sick leave and expanded family and medical
leave provisions of the FFCRA (i.e., certain public sector employers and
private sector employers with fewer than 500 employees) are required to post
this notice.
8. How do I
know if I have the most up-to-date notice? Will there be updates to this
notice in the future?
The most
recent version of this notice was issued on March 25, 2020. Check the Wage
and Hour Division's website or sign up for Key News Alerts to ensure that you
remain current with all notice requirements: www.dol.gov/agencies/whd.
9. Our
employees must report to our main office headquarters each morning and then
go off to work at our different worksite locations.
Do we have
to post this notice at all of our different worksite locations?
The notice
needs to be displayed in a conspicuous place where employees can see it. If
they are able to see it at the main office, it is not necessary to display
the notice at your different worksite locations.
10. Do I
have to pay for notices?
No. To obtain notices free of charge, contact the Department's Wage and Hour Division at 1-866-4-USWAGE (1-866-487-9243). Alternatively, you may download and print the notice yourself from https://www.dol.gov/agencies/whd/posters 11. I am running out of wall space. Can I put the required notices in a binder that I put on the wall?
No, you
cannot put federal notices in a binder. Generally, employers must display
federal notices in a conspicuous place where they are easily visible to all
employees-the intended audience.
12. We have
break rooms on each floor in our building. Do I have to post notices in each
break room on each floor or can I just post them in the lunchroom?
If all of
your employees regularly visit the lunchroom, then you can post all required
notices there. If not, then you can post the notices in the break rooms on each
floor or in another location where they can easily be seen by employees on
each floor.
13. Our
company has many buildings. Our employees report directly to the building
where they work, and there is no requirement that they first report to our
main office or headquarters prior to commencing work. Do I have to post this
notice in each of our buildings?
Yes. Where an employer has employees reporting directly to work in several different buildings, the employer must post all required federal notices in each building, even if the buildings are located in the same general vicinity (e.g., in an industrial park or on a campus). |