CLIENT ALERT: DOL Provides Notice-of-Rights Poster for "Families First"
The Families First Coronavirus Response Act (the “Act” or “Families First”) requires employers to post a notice of rights in a conspicuous place on its premises. On March 25, the DOL provided a copy of the model notice, available here. Recognizing that many employees are working remotely, the DOL has clarified that employers can satisfy the poster requirement by sending a copy of this notice by email or regular mail or by posting it on the employer’s internal or external website. A copy also must be provided to any new hires between April 1 and the end of the year. The notice currently is available only in English; although languages other than English are not required, the DOL plans to provide translations in the near future.
Notably, the DOL has clarified that the rights in the notice apply only to current employees, so employers need not send copies to employees who have already been laid off, even recently. Although not expressly stated by the DOL, likely the notice need not be provided to any employees laid off between now and the end of March, either, since the Act (and the rights created by the Act) will not be in effect until April 1, 2020.
These and other issues are addressed by the DOL in a new Q&A, available here.