Document, Document, Document – The Employer’s Guide to Documenting Paid Sick and Family Leave in Uncertain TimesOn April 10, 2020 by Schnader in Client Alerts
Schnader’s Karen Baillie has published a new Client Alert, “Document, Document, Document – The Employer’s Guide to Documenting Paid Sick and Family Leave in Uncertain Times.” It reads in part:
Employers providing the mandated new Emergency Paid Sick Leave (EPSL) and Enhanced Family and Medical Leave Act (EFMLA) benefits created by the Families First Coronavirus Relief Act (FFCRA) will want to start collecting documentation now. This documentation may be needed later to submit to the IRS for tax credits, defend against claims brought in court, or to defend against Department of Labor (DOL) enforcement, which is scheduled to begin on April 18, 2020.
Both the Internal Revenue Service (IRS) and the DOL have issued FAQs and other guidance documents identifying the pieces of information that employers may later be asked to show. The situation is rapidly changing with new regulations and guidance providing additional information daily and these guidance documents do not yet have the force of law and are subject to change.