DOL Guidance Clarifies Nuances on How FFCRA Leave May Be Used: Part Three of a Five-Part Series (US)

    View Author April 2020

    The first two installments of our five-part in-depth analysis of the emergency paid sick leave and public health emergency paid family leave provisions of the Families First Coronavirus Response Act (FFCRA) – see here and here – analyzed the statutory language and regulations governing employer coverage, employee eligibility, the circumstances under which employees can request leave under the FFCRA, and what documentation an employer can require to support those requests.

    In Part Three, we now look at how employees may use leave under the FFCRA, including how the paid leave provisions of the FFCRA coordinate with existing employer and state law paid leave policies, how the two types of FFCRA paid leave coordinate with each other, and an issue under the FFCRA that vexes employers under even under non-pandemic circumstances: when can leave be used intermittently?