"[T]here are still open questions: [1] Whether local, state or federal 'stay at home' or 'business closure' orders could, under any circumstances, be considered 'quarantine' or 'isolation' orders allowing an employee to qualify for benefits under the paid sick leave law in any circumstance ... [2] Application of the integrated employer test to the paid sick leave provisions; [3] Whether FFCRA leave may be used intermittently; and [4] How employers with fewer than 50 employees will effectively demonstrate that compliance will jeopardize the viability of their business. (Note: The [DOL] has already indicated that it will be issuing criteria on this point.)"

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