The first three installments of our five-part series analyzing the US Department of Labor regulations interpreting the Families First Coronavirus Response Act (FFCRA) examined eligibility and coverage issues. Part One looked at which employees are eligible to take, and which employers are required to provide, emergency paid sick leave and public health emergency paid family leave under the FFCRA. Part Two addressed the coronavirus-specific reasons why an eligible employee may take job-protected paid sick leave or paid family leave. Part Three analyzed the unique rules regarding how emergency paid sick leave and public health emergency paid family leave may be used.
In this fourth installment, we consider how employers are to calculate the “regular rate of pay” in order to pay employees exercising paid leave rights under the FFCRA, a concept far easier in theory than in practice.
Click here to download Part Four of the series.
