April 9, 2021
COVID-19 Leave Legislation
State and Local
State and Local Emergency Paid Sick Leave
While paid COVID-19 leave is no longer mandated on a federal level, state and local requirements are still in place. Below is a copy of the summary of Emergency Paid Sick Leave (EPSL) extensions last provided in our March 17 Statutory Update, with updates to California State, the District of Columbia and Philadelphia, PA noted.
Please see our side-by-side comparison for more details on each of the Emergency Paid Sick Leave laws.
Current Emergency Paid Sick Leave Expiration
Supplemental Paid Sick Leave under AB1867 expired December 31, 2020.
If an employee was on SPSL as of December 31, the employee was permitted to finish taking leave.
April 9 Update: On March 19 the governor of California signed SB95, which is enforceable as of March 29 and reinstates state COVID-19 Supplemental Paid Sick Leave (SPSL) retroactively, from January 1, 2021, through September 30, 2021. Below are the main components of the law, which adds sections 248.2 and 248.3* to the CA Labor Code.
• All employers with 26 or more employees (the 2020 SPSL law applied mainly to employers with 500 or more employees);
• All employees who cannot work or telework (the 2020 SPSL law applied only to employees required to leave home to perform work).
• Provides a new leave entitlement (see Employer Offset below):
• Full-time employees or those scheduled to work at least 40 hours during each of the two weeks preceding leave are eligible for 80 hours of SPSL.
• Part-time employees or those scheduled to work fewer than 40 hours during each of the two weeks preceding leave are eligible for a number of SPSL hours equal to the number of hours normally scheduled during a two-week period.
• Variable schedule employees are eligible for a number of SPSL hours equal to 14 times the average number of hours worked each day in the six-month period preceding leave (or since date of hire, if sooner); if the employee has worked for the employer for fewer than 14 days, the employee is entitled to the total number of hours worked.
• Active firefighters (as defined) scheduled to work more than 80 hours in the two weeks prior to taking SPSL are entitled to leave in an amount equivalent to the number of hours scheduled to work in that two-week period.
• An employee taking SPSL on the law’s expiration date will be permitted to finish taking leave.
• The law expands the reasons for leave covered under the 2020 SPSL law. An employee may take SPSL if he or she:
1. is subject to a COVID-19 quarantine or isolation period defined by an order or guidelines issued by State Department of Public Health, the federal Centers for Disease Control and Prevention, or a local health officer who has jurisdiction over the workplace;
2. has been advised by a health care provider to self-quarantine due to COVID-19 concerns;
3. is attending an appointment to receive a COVID-19 vaccination;
4. is experiencing symptoms related to COVID-19 vaccination preventing him or her from being able to work or telework;
5. is experiencing symptoms of COVID-19 and seeking a medical diagnosis;
6. is caring for a covered family member** to whom numbers 1 or 2 above apply;
7. is caring for a child** whose school or place of care is closed or otherwise unavailable for reasons related to COVID-19
**Covered family members are as defined under CA Labor Code Section 245.5(c)
• $511 per day, maximum $5,110
• Exempt: Calculated the same as for other forms of paid leave;
• Non-Exempt: highest of (1) regular rate for the week(s) SPSL is used; (2) state or local minimum wage; or (3) total wages excluding overtime divided by the total number of hours worked in the full pay periods of the prior 90 days of employment.
• Documentation: An employer may not deny an employee SPSL based solely on a lack of certification from a health care provider; however, it may be reasonable for documentation to be requested if the employer has reason to believe SPSL is not being taken for a valid reason.
• Interplay with Other Leaves:
• SPSL is in addition to leave provided under California's Healthy Workplaces, Healthy Families Act (CA Paid Sick Leave).
• Employer Offset: If an employer provided supplemental paid leave that is payable for the reasons covered by and at the same or a greater level of compensation as this law on or after January 1, 2021, the employer may count the hours of the other paid benefit or leave towards the total number of hours of SPSL required. This may include leave provided under similar law in effect after January 1, 2021, but may not include remaining 2020 leave provided under California’s previous SPSL laws (AB1867 or EO N-51-20). For any such leave taken, if the employer did not compensate the covered employee in an amount equal to or greater than the amount of compensation for SPSL to which the covered employee is entitled under this law, then upon the oral or written request of the employee the employer must provide the employee with a retroactive payment that provides for such compensation.
• An employer may not require a covered employee to use any other paid or unpaid leave, paid time off, or vacation time prior to or instead of using SPSL. Exception: In order to satisfy the requirement to maintain an employee’s earnings when he or she is excluded from the workplace due to COVID-19 exposure under the Cal/OSHA COVID-19 Emergency Temporary Standards (ETS) or the Cal/OSHA Aerosol Transmissible Diseases Standard, an employer may require the employee to first exhaust their COVID-19 SPSL (for more information on the ETS’ requirements see our March 17 Update as well as the CA Department of Industrial Relations’ (DIR) dedicated webpage and accompanying FAQ).
• Notice to Employees/Recordkeeping:
• Employers must post a notice conspicuously; a model notice has been made available. The notice may be distributed electronically if workers do not frequent a workplace.
• SPSL time available must be included on employees’ itemized wage statements or in a separate writing provided on the designated pay date with each employee’s payment of wages. SPSL must be designated separately from paid sick days. Retroactive payments described in Employer Offset above must be on the paystub for the pay period during which payment is made (special provision for notice to variable-hour workers, see law text and/or FAQ). The wage statement requirement is enforceable on the payday of the first full pay period after March 29, 2021.
• Records of hours worked, leave provided and leave used must be maintained for 3 years.
* Section 248.3 outlines benefits for providers of in-home supportive services or waiver care services (both as defined under the Welfare and Institutions Code), which are similar to the benefits outlined here.
More information on SPSL provisions and requirements may be found in the FAQ posted on the DIR’s COVID-19 Guidance and Resources website.
No set expiration date; reviewed every 90 days.
Last extended February 26, next review due by June 4, 2021.
Terminates two weeks following the expiration of the local COVID-19 emergency period.
On February 10 the mayor’s office issued an Executive Order making the following updates:
• The original ordinance applied to individuals employed by the same employer between February 3 and March 4, 2020, who perform work within the city and who cannot work or telework. The Emergency Order redefines eligible employees as those who have been employed with the same employer for 60 days who perform work within the city and cannot work or telework.
• Leave entitlement:
• Full-Time Employees (40h/wk or classified as FT) are entitled to 80 hours of SPSL; leave is calculated based on the employee's average two week pay over the last 60 days of employment*.
• All Other Employees: An amount of SPSL no greater than the employee’s average two week pay over the last 60 days of employment
* Previously stated as the two-week average between February 3 and March 4, 2020.
These amendments do not change that SPSL requirements may be offset by any additional leave provided after March 4, 2020, for COVID-19-related reasons.
The city has posted updated regulations.
Extended via Urgency Ordinance until two calendar weeks after the expiration of the local COVID-19 emergency.
• No new EPSL entitlement if leave was taken in 2020 under the original ordinance or under FFCRA;
• As of January 1, 2021, the requirements apply to all employers in the unincorporated areas of LA County (the original ordinance only applied to those with 500 or more employees nationally).
Extended via Emergency Ordinance for the duration of Oakland’s March 9, 2020 Declaration of Emergency.
• No new EPSL entitlement if leave was taken in 2020 under the original ordinance, CA State EPSL or FFCRA.
San Francisco (City and County), CA
Extended 60 days, through April 12, 2021, via February 19
Emergency Ordinance; see updated FAQ.
• Amendments to original ordinance, effective February 11:
• Conditionally excludes Non-Profit Organizations that do not engage in Healthcare Operations (both as defined);
• Removes the requirement that employers must permit employees to use (i.e., be paid for) Public Health Emergency Leave for hours they are not scheduled to work.
Revised ordinance approved by the city council on January 5, effective January 1 through June 30, 2021:
• No new EPSL entitlement if leave was taken in 2020 under the original ordinance or under FFCRA;
• Now applies to all employers (not just those not subject to FFCRA);
• Now applies to all employees who cannot work or telework (not just those who must leave home to perform “essential work”).
The city has posted updated information on its website.
Reinstated via Urgency Ordinance (ORD-2021-001) effective February 2 through the later of March 31, 2021 or the expiration of FFCRA tax credits.
April 9 Update: The city’s website has been updated to reflect the expiration date as September 30, 2021.
• No new EPSL entitlement if leave was taken in 2020 under the original ordinance or under FFCRA.
• Now applies to all employers (the original ordinance only applied to those with 500 or more employees nationally).
• Specifies that leave is available if the employee is “unable to work”.
• The original ordinance specified the paid benefit as regular rate of pay up to $511/day with an aggregate maximum of $5,110 for all types of leave. The Urgency Ordinance amends this to 66 2/3% of pay, up to $200/day with a maximum of $2,000, for leave associated with care for a family member or due to the unavailability of a minor child’s school or place of care.
• Employers must now provide written notice to all current employees and to any new employee within his or her first week of employment. A model notice has been posted on the city’s COVID-19 Paid Sick Leave webpage.
• If the employer can show that the need for an employee’s requested leave is due to the employee’s intentional violation of a health order, the employer may deny the benefit.
Extended through June 30, 2021 via Urgency Ordinance; amendments to the original ordinance may be forthcoming.
On February 9 the county’s Board of Supervisors approved Ordinance No. 6336, which replaced the original Supplemental Paid Sick Leave Ordinance (Ord. No. 6320) effective immediately. The requirements are almost identical to those of the original ordinance, with a few notable changes:
• The original ordinance applied to employers with 500 or more employees within the unincorporated areas of the county; the new ordinance requires that employers of all sizes must provide Supplemental Paid Sick Leave.
• Healthcare providers and emergency responders are (still) covered, however a leave request from an employee in either classification may be denied or limited if the need for leave is due to school or place of care closure and the employer makes a good faith determination that granting such leave would create a staffing shortfall.
• The new Ordinance does not provide additional leave time. Employers may credit COVID-19 paid sick leave hours already provided under FFCRA, CA State SPSL (AB 1867), Cal/OSHA regulations and the original Sonoma County Ordinance, as well as any substantially similar COVID-19 paid sick leave legislation that may be enacted in the future, against the Ordinance's requirements.
• Effective through June 30, 2021, unless extended.
• A model notice has been provided. The notice must be posted in English and Spanish in the workplace, on any intranet or app-based platform, or via email
The Healthy Families and Workplaces Act (HFWA) featured COVID-19 Emergency Paid Sick Leave (EPSL), which was effective July 15 and ended December 31, 2020, as well as permanent accrued paid sick leave (PSL) and accompanying public health emergency leave (PHEL) effective January 1, 2021. It was previously unclear whether the public health emergency declared due to COVID-19 in 2020 would trigger PHEL entitlement in 2021. However, a December 23 emergency rule and CDLE’s recently released INFOs #6C confirm that, since the COVID-19 public health emergency was “re-declared” after HFWA’s July 14 effective date and continues into 2021, employees are entitled to a new allotment of up to 80 hours of paid leave under HFWA’s PHEL beginning January 1.
• Employers are required to supplement an employee’s accrued HFWA leave so that, as of the date a public health emergency, the employee has immediate use of the following amounts of paid leave:
• FT (40 hours/week): 80 hours
• Other: The greater of (1) the amount of hours the employee is scheduled to work in a 14-day period, or (2) the average number of hours the employee usually works during a 14-day period
• Leave an employee may have taken under 2020’s EPSL requirements may not be counted against PHEL entitlement.
• Employees may use PHEL for up to four weeks after the official termination of a public health emergency. The current declaration, under Executive Order D 2021 068, expires April 15, which would permit PHEL leave to be taken through May 13, 2021.
Also, while accrued paid sick leave (PSL) is not required of employers with fewer than 16 employees until January 1, 2022, PHEL is required of all employers as of January 1, 2021.
* An updated version of the rules was adopted on February 23, 2021, which clarified that calculation of PHEL entitlement for employees who normally work fewer than 40 hours per week is based on when the leave is requested.
See our December 15 Statutory Update for our most recent coverage of HFWA.
• April 9 Update: Paid Public Health Emergency Leave was extended on March 12 via D.C. Act 24-30, through June 10, 2021. No new leave entitlement.
• DC FMLA amendments are set to expire May 22, 2021.
In effect for the duration of any COVID-19 quarantine or isolation order issued by the state, the department of health, local board of health, or any government entity duly authorized to issue such order due to COVID-19.
On January 20 NY DOL issued guidance stating that:
1. Other than nursing home staff, employees who have completed a mandatory quarantine or isolation period are not required to be tested prior to returning to work. However, an employee who subsequently receives a positive COVID-19 test must not report to work and will be considered subject to a mandatory order of isolation by the Department of Health and therefore eligible for COVID-19 Sick Leave – regardless whether he or she already received sick leave as required by the law for the first period of quarantine or isolation. The employee must submit documentation that he or she has received a positive test result, unless the test was administered by the employer.
2. While employees are not required to be tested to discontinue a period of quarantine or isolation, an employee who chooses to be tested at the end of such period and continues to test positive must not report to work, and will be considered subject to a second mandatory order of isolation from the Department of Health and therefore entitled to COVID-19 Sick Leave. The employee must submit documentation that he or she has received a positive test result after the initial period of isolation, unless the test was administered by the employer.
3. An employee not otherwise subject to a mandatory or precautionary order of quarantine or isolation who has been removed from the workplace by the employer due to exposure concerns must continue to be paid at his or her regular rate of pay until the employer permits the employee to return to work* or the employee becomes subject to a mandatory or precautionary order of quarantine or isolation. If the latter, the employee will be entitled to COVID-19 Sick Leave for the period of time he or she is subject to the mandatory or precautionary order of quarantine or isolation.
* Note: This is a departure from the law text, which specifically states that COVID-19 Sick Leave is only available if the employee is subject to a mandatory or precautionary order of quarantine or isolation issued by an authorized government agency. Therefore, it would seem that leave provided under this circumstance does not technically qualify as an instance of COVID-19 Sick Leave under the law, unless and until the employee “officially” becomes or is deemed subject to an order of quarantine or isolation.
4. Employees are entitled to COVID-19 Sick Leave for up to three orders of quarantine or isolation. The second and third orders must be based on a positive COVID-19 test in accordance with items 1 and 2 above.
For more details on COVID-19 Sick Leave, please refer to our March 20 Update, as well as the state’s website and FAQ.
Public Health Emergency Leave under Bill No. 200303 expired December 31, 2020.
A covered individual may use all or a portion of PHEL at any time during the public health emergency and for one month following the conclusion of such emergency.
April 9 Update: On March 29 the mayor of Philadelphia signed Bill No. 210122-A, which requires employers to provide employees with “2021 Public Health Emergency Leave” (PHEL). The Ordinance was effective immediately (but not retroactively) and will extend until the expiration of the governor’s Proclamation of Disaster Emergency (most recently renewed on February 19).
• Applies to:
• All employers with 50 or more employees (regulations may clarify whether this number applies only to workers in Philadelphia);
• Employees who have worked for a given employer for 90 or more days and:
1. work within Philadelphia;
2. normally work within Philadelphia but are currently teleworking from any other location as a result of COVID-19; or
3. work from multiple or mobile locations, provided that 51% or more of work time is spent in Philadelphia.
Provides a new leave entitlement (see Interplay with Other Leaves below):
• Employees who work 40 hours or more per week are eligible for 80 hours of PHEL.
• Employees who work fewer than 40 hours per week are eligible for a number of PHEL hours equal to the average number of hours worked or scheduled to work, whichever is greater, in a 14-day period.
• Variable schedule employees are eligible for a number of PHEL hours equal to 14 times the average number of daily hours that the employee was scheduled over the past 90 days of work, including hours for which the employee took leave of any type.
• PHEL may be used until 1 week following the official termination or suspension of the public health emergency
• Employees who take PHEL are entitled, upon return from leave, to be restored to the position held prior to leave.
• Reasons for Leave - an employee may take PHEL if he or she is unable to work due to one or more of the following reasons:
1. A determination by a public official, public health authority, healthcare provider or employer that the employee’s presence on the job or in the community might jeopardize the health of others due to the employee’s exposure to or symptoms of COVID-19;
2. The employee’s need to self-isolate and care for oneself because of COVID-19 symptoms or diagnosis, or to seek medical diagnosis, care or treatment for COVID-19-related symptoms;
3. To care for a family member to whom numbers 1 or 2 above apply;
4. To care for a child whose school or place of care is closed or otherwise unavailable for reasons related to COVID-19
5. To obtain a COVID-19 vaccination;
6. To recover from any injury, disability, illness or condition related to a COVID-19 vaccination.
• Pay: Greater of regular rate of pay or state minimum wage
• Documentation: An employer may only to request that an employee submit a self-certified statement asserting that leave was used for PHEL purposes.
• Interplay with Other Leaves:
• PHEL is in addition to all other paid leave benefits offered by an employer, and may not be reduced by the amount of any paid leave an employee has previously received, including any public health emergency leave provided in 2020. In addition, an employer may not reduce the amount of any paid leave a PHEL-eligible employee was otherwise entitled to use or accrue under such employer’s existing policies as of March 1, 2021.
• Employers who adopted a COVID-19 paid leave policy on or after March 6, 2020, may substitute that policy for requirements under this Ordinance; however, the employer must provide additional leave where the Ordinance's requirements exceed the provisions of the employer’s COVID-19 policy available to a particular employee on or after January 1, 2021.
• An employer may not require an employee to use other paid leave available to the employee before the employee is eligible to use PHEL, unless state or federal law requires otherwise.
• Employers may substitute leave under federal or state COVID-19 paid leave law for its PHEL obligations to the extent they coincide and the relevant federal or state law permits concurrent use of paid leave. Employers shall provide additional PHEL if the requirements of this Ordinance exceed the requirements of those laws and as permitted under the federal or state law.
• Employers are not required to change existing policies or provide additional paid leave if an existing company policy provides a minimum amount of paid leave in 2021 that can be used for the same purposes and under all of the same conditions as PHEL:
• Employees who perform the majority of their work through telework: a minimum of 80 hours;
• All other employees: a minimum of 160 hours (as long as this time is not specifically designated as sick leave).
• Notice to Employees/Recordkeeping:
• A notice must be distributed to all employees or posted conspicuously, in all languages spoken by 51% of population, within 15 days of the law's effective date (i.e., by 4/13/21). The notice may be provided electronically to remote employees or if the employer does not maintain a workplace. A model notice has been posted on the city’s website.
• Records of hours worked, leave provided and leave used must be maintained for 2 years.
Terminates upon expiration of the state's or city's emergency disaster declarations, whichever is sooner.
Employees may use COVID-19 Sick Time until one week following the official termination of the public health emergency.
Food Production Workers
In effect until the termination or expiration of State of Emergency.
In effect until 180 days after the end of the civil emergency
Oregon Family Leave Act Amendment
We previously reported on the 2020 amendment to the Oregon Family Leave Act (OFLA)’s sick child leave* to include care for an employee’s dependent child whose school or place of care has been closed in conjunction with a statewide public health emergency declared by a public health official. The Oregon Bureau of Labor and Industries (BOLI) issued permanent rules around the change, effective March 18, 2021.
*OFLA’s sick child leave allows eligible employees to take an additional 12 weeks of leave to care for a child suffering from an illness, injury, or condition that requires home care but is not a serious health condition.
New York COVID-19 Vaccination Leave Guidance
Our March 17 Update included notice that, effective March 12, 2021, employers are required to provide their employees paid time off to obtain COVID-19 vaccination. New York’s Department of Labor has since issued FAQ that provide guidance on items not included in the law itself, such as:
- Leave is available only for the employee’s own vaccination, not in order to assist another person;
- Employers may require employees to provide advance notice;
- Employers may request proof of vaccination, though employers are cautioned to consider confidentiality;
- The law’s requirements, including pay for time off, are not applicable retroactively.
The FAQ also provide direction for employees who have been denied leave or feel they have been retaliated against for taking leave.
Other Leave News
Paid Sick Leave
In our April 8, 2020 Update we noted that Dallas’ Earned Paid Sick Time Ordinance was postponed due to a court ruling only days before its enforcement date of April 1, 2020. On March 31, 2021, a federal district court granted an injunction that permanently prevents the ordinance from becoming effective. The court’s decision is in line with those made regarding paid sick leave ordinances in Austin (petition for review denied June 5, 2020) and San Antonio (temporary injunction upheld March 10, 2021). All of the rulings hold that the ordinances conflict with the state’s minimum wage law and therefore violate the Texas Constitution. While the Austin and San Antonio cases are still technically open, it is likely that the Dallas decision will influence their fates.
On March 30 the governor of Virginia signed H2137, which requires employers to provide home health care workers with paid sick leave effective July 1, 2021.
- All employers except any agency of the federal government
- Home health workers who work an average of at least 20 hours per week or 90 hours per month
- A home health worker is defined as someone who provides personal care, respite, or companion services to an individual who receives consumer-directed services under the state plan for medical assistance services
- Excludes any individual who (1) is licensed, registered, or certified by a health regulatory board within the Department of Health Professions; (2) is employed by a hospital licensed by the Department of Health; and (3) works, on average, no more than 30 hours per month.
- Workers accrue 1 hour of paid sick leave for every 30 hours worked, beginning their date of employment, up to 40 hours per year.
- Employers may frontload all paid sick leave a worker is expected to accrue in a year at the beginning of the year.
- Paid sick leave carries over from one year to the next; however, use may be limited to 40 hours per year.
- Employers are not required to provide additional leave if they have a policy (e.g., PTO) that provides paid leave in an amount equivalent to, and that may be used for the same reasons as, the law’s requirements.
Reasons for Use: The diagnosis, care or treatment of the worker’s or a covered family member’s illness or injury, including preventive care.
- Workers should provide notice of the need for leave as soon as possible, and make a reasonable effort to schedule leave in a manner that does not unduly disrupt the operations of the employer.
- Notice may be made verbally, in writing, electronically, or by any other means acceptable by the employer.
- Employers may request documentation for leaves exceeding three consecutive work days.
Anti-Discrimination and Accommodation
On February 4 the governor of Arizona signed HB2045, which amends §41-1461 and §41-1463 of the Arizona Civil Rights Act, adding “because of or on the basis of pregnancy or childbirth or related medical conditions” to protections against employment discrimination “based on sex”, and expressly stating that “women who are affected by pregnancy or childbirth or related medical conditions shall be treated the same for all employment-related purposes, including receipt of benefits under fringe benefit programs, as other persons not so affected but similar in their ability or inability to work”. The amendment is effective on or around July 19, 2021.
On February 19 the governor of Virginia signed H1848, which adds individuals with disabilities as a protected class under the Virginia Human Rights Act (VHRA) effective July 1, 2021. The VHRA prohibits employers from discriminating against employees or applicants on the basis of race, color, religion, sex, sexual orientation, gender identity, marital status, pregnancy, childbirth or related medical conditions including lactation, age, veteran status, disability, or national origin. The amendment also makes it unlawful for an employer to refuse to make reasonable accommodation to the known physical and mental impairments of an otherwise qualified person with a disability if necessary to assist such person in performing a particular job, unless the employer can demonstrate that the accommodation would impose an undue hardship on the employer. Employers should engage in a timely, good faith interactive process with the employee to determine what accommodation may be available, but may not require the employee to take leave if another reasonable accommodation can be provided.
Employers are required to post in a conspicuous location and include in any employee handbook information concerning an employee’s rights to reasonable accommodation for disabilities. This information must also be directly provided to (1) new employees upon commencement of their employment and (2) any employee within 10 days of providing notice to the employer that he or she has a disability. The Office of Civil Rights has posted an updated model notice on its website.
Kentucky Adoption Leave Amendment
On March 15 the governor of Kentucky signed HB210 to amend the state’s adoption leave law (KRS 337.015). Currently the law provides that employers provide six weeks of “reasonable personal leave” upon an employee’s adoption of a child under age 7. Effective June 30, 2021, the law will require that more generous employer policies for birth parents, paid or unpaid, must be made available to adoptive parents as well, and increases the adopted child age to 10. The law does not apply to adoption by kinship based on social agreements, step-parent, step-sibling, blood relative (including relative of half-blood, first cousin, aunt, uncle, nephew, niece, or any person of a preceding generation), or to a foster parent who adopts a foster child already in their care.
Please contact your Trion Account Team members for specific questions about these or other updates.
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