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Families First Coronavirus Response Act

The first legislation to address the current pandemic dealt with preparedness and federal agencies.  The second bill, the Families First Conoravirus Response Act, requires all employers to offer up to two weeks (80 hours, or a part-time employee’s two-week equivalent) of paid sick leave in certain situations from April 1 through December 31, 2020 when the employee:

  1. is subject to a Federal, State, or local quarantine or isolation order related to COVID-19;
  2. has been advised by a health care provider to self-quarantine related to COVID-19;
  3. is experiencing COVID-19 symptoms and is seeking a medical diagnosis;
  4. is caring for an individual subject to an order described in (1) or self-quarantine as described in (2);
  5. is caring for his or her child whose school or place of care is closed (or child care provider is unavailable) due to COVID-19 related reasons;
  6. is experiencing any other substantially-similar condition specified by the U.S. Department of Health and Human Services.

This is not optional — but since the paid leave is a fully refundable through a tax credit via your quarterly form 941, it will not add to the congregation’s expenses.

This leave must be paid at a rate of at least:

  • 100% of their regular pay for qualifying reasons #1-3 above, up to $511 daily and $5,110 total;
  • 2/3 of their regular pay for qualifying reasons #4 and 6 above, up to $200 daily and $2,000 total;
  • up to 12 weeks of paid sick leave and expanded family and medical leave paid at 2/3 for qualifying reason #5 above for up to $200 daily and $12,000 total.

Employers must notify their employees and must provide paid leave before using any regular sick leave, family leave, or vacation leave.  You can download the required posting from the Department of Labor website.  Clearly, posting it in your church building won’t work now, but you should e-mail it to your employees.

There is a webinar on the FFCRA recorded by Heather Kimmel, General Counsel for the United Church of Christ on March 27, 2020.