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Families First Coronavirus Response Act Update:  DOL Issues Corrected Temporary Regulations

David A. Moore, Andrew S. Goldberg, Chad R. DeGroot

On Friday, April 10, 2020, the U.S. Department of Labor (DOL) issued corrections to its temporary regulations interpreting the Families First Coronavirus Response Act (FFCRA).  Importantly, the DOL clarified the inconsistencies we identified regarding the interaction between the preexisting paid time off benefits and the new emergency paid sick leave and expanded FMLA benefits under FFCRA, among other more minor changes.  You should consult with your Laner Muchin attorney to understand how this significant update impacts your current FFCRA practices, including requests and approval forms, payroll programming, and tax reporting.

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