April 1, 2020 is the deadline for employers with fewer than 500 employees to display the poster in a conspicuous place in each of your stores or by providing it via email to every current employee who is teleworking. Do not fail to provide this notice to employees by April 1, 2020.
The poster is entitled “Employee Rights: Paid Sick Leave and Expanded Family and Medical Leave under the Families First Coronavirus Response Act.”
You can download and print the poster free of charge from the NPA website or the Department of Labor at https://www.dol.gov/agencies/whd/posters. Be sure to save the downloaded file so you can copy or scan or print for posting in the workplace and providing to all teleworkers, as well. You can order free copies from 1-866-4-WAGE, but they probably will not arrive in time to meet the April 1, 2020 deadline.
In a previous GRC Update we explained that this poster gives employees the basic details of their new rights that go into effect on April 1, 2020 and that are currently scheduled to expire on December 31, 2020. The Labor Department information states that the poster must be up – even if the store is closed.
You do not have to share the poster with recently laid-off individuals – only with current employees, whether full-time or part-time. You do not have to provide it to new job applicants. You DO have to provide the poster to new hires using email, direct mail, or by posting in your store premises or on an employee internal or external website.
The information is only required to be provided in English at this time. The Department of Labor is working on translations, but they are not yet available.
The poster is required to be provided/posted even if the state(s) in which you have stores provides greater protections than the FFCRA. Employers must comply with both federal and state laws.
This GRC Update was prepared on March 29, 2020 with information available as of noon on that date. To ensure you remain current on all requirements visit the DOL’s Wage and Hour Division website: www.dol.gov/agencies/whd. You can sign up for Key New Alerts on that site, too. Team GRC will be monitoring the Wage and Hour Division site and Updates will be provided when additional FAQs are published by the Department of Labor.
This GRC Update summarizes information provided by the Department of Labor at https://www.dol.gov/agencies/whd/pandemic/ffcra-poster-questions.
It is not intended as and should not be construed as legal advice to NPA members.
Members should consult their own lawyers for legal advice.
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