Health & Welfare Plans Newsletter

BULLETIN
June 28, 2020

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[Official Guidance]

Text of DOL FAB 2020-4: FFCRA Leave Based on the Closure of Summer Camps, Summer Enrichment Programs, or Other Summer Programs (PDF)

"The expectation that employees take FFCRA leave based on planned summer enrollments is not different from the closing of other places of care, such as a day care center. An employee generally could not take FFCRA leave to care for his or her child based on the closing of a day care center that the child has never attended, unless there were some indication that the child would have attended had the day care center not closed in response to COVID-19....

"The Department's existing guidance provides that a closed summer camp or program may be considered to be the place of care for an employee's child if the child was enrolled in the camp or program before the summer camp or other summer program announced closure.... Affirmative steps short of actual enrollment may also be sufficient. For example, if the summer camp or program has an application process, submission of an application before the camp's closure may establish the camp or program as the child's planned place of care during the summer; submission of a deposit may also establish intent to enroll. Prior attendance and current eligibility may also establish a summer camp or program as the child's planned place of care....

"The multitude of possible circumstances under which an employee may establish [1] a plan to send his or her child to a summer camp or program, or [2] that even though the employee had no such plan at the time the summer camp or program closed due to COVID-19, his or her child would have nevertheless attended the camp or program had it not closed, prevents a one-size-fits-all rule here."

Wage and Hour Division [WHD], U.S. Department of Labor [DOL]

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