Update: Families First Coronavirus Act

webinarThe Department of Labor issued new guidance over the weekend regarding the Families First Act, including important definitions and clarifications.  I broke down the new guidance into the overall framework of the new EFMLA and EPSLA in this recorded webinar.

If you have any questions or need assistance, please contact any member of our Labor, Employment and Employee Benefits Team.

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Department of Homeland Security Relaxes Standards for Verifying Work Authorization

 

As a result of the COVID-19 pandemic, the Department of Homeland Security has relaxed its standards requiring in-person review of work authorization documents required to complete the I-9 form. Specifically, if an employer has no employees physically present at a work location to be able to perform in-person review of documents, the employer is now permitted to review work authorization documents remotely in order to complete an I-9 form within three days of a new hire. Employers doing so, however, must provide written documentation of their remote onboarding and telework policy to each employee being hired.

If an employer continues to have any employees working physically on site, the relaxed standard is not available to that employer. Once normal operations resume, all employees who were onboarded using remote verification must receive in-person verification of identity and employment eligibility within three business days to remain in compliance with the I-9 requirements.

As you continue to navigate the myriad employment issues arising as a result of the pandemic, Mirick O’Connell’s Labor and Employment team stands ready to assist. Please contact any member of our team with questions.

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Congress Passes Families First Coronavirus Response Act

On March 18, 2020, Congress passed a bill entitled “Families First Coronavirus Response Act” (the “Act”) aimed at alleviating several major burdens families are currently facing as a result of the coronavirus (COVID-19). The Act, which goes into effect on April 2, 2020, contains several relevant provisions that will directly impact employers including:

  1. The Emergency Family and Medical Leave Expansion Act that creates a new category of job protected leave referred to as “Public Health Emergency Leave”; and
  1. The Emergency Paid Sick Leave Act that requires employers to provide employees with a specific amount of paid sick leave to be used for purposes directly related to COVID-19.

Notably, the Emergency Family and Medical Leave Expansion Act and the Emergency Paid Sick Leave Act apply to employers with fewer than 500 employees, and all political subdivisions of the Commonwealth, including school districts and municipalities. In light of the April 2, 2020 effective date, employers should begin familiarizing themselves with the laws’ provisions. To assist you in that process, we have developed the following FAQs:

Emergency Family and Medical Leave Expansion

For what purpose may an employee take Public Health Emergency Leave?

An eligible employee is entitled to take Public Health Emergency Leave when the employee is unable to work or telework due to a need to care for the employee’s child under eighteen if the child’s school or place of care has been closed, or if the child care provider of the child is unavailable, due to a public health emergency. The Act defines “public health emergency” as an emergency with respect to COVID-19 declared by a Federal, State, or local authority.

Which employees are eligible for Public Health Emergency Leave?

To be eligible for Public Health Emergency Leave, employees must have been employed for at least thirty (30) calendar days.

However, an employer of an employee who is a health care provider or emergency responder may exclude such employees from being eligible for Public Health Emergency Leave.

How much leave are employees eligible for?

Employees are eligible for up to twelve (12) weeks of Public Health Emergency Leave. However, the Emergency Family and Medical Leave Expansion Act does not increase the total amount of FMLA time otherwise available to employees. In this regard, if an employee takes six weeks of Public Health Emergency Leave, he/she would only be eligible for six more weeks of FMLA qualifying leave (assuming the employer is subject to the FMLA).

Is Public Health Emergency Leave paid or unpaid?

The first ten working days of leave may be unpaid. During this time, employees may, but are not required to, use accrued vacation, personal leave, or paid sick leave.

Following the initial ten-day period, an employee’s Public Health Emergency Leave will be paid in an amount that is at least two-thirds of their regular rate of pay up to $200 per day. Employees are entitled to receive such paid leave only for the number of hours they are otherwise normally scheduled to work.

For employees whose weekly hours vary, the employee shall be paid based on the average number of hours the employee was scheduled per day over the 6-month period ending on the date on which the employee first takes such leave, including hours for which the employee took leave of any type. If the employee did not work over such period, the employee is entitled to receive paid sick time based on the employer’s reasonable expectation at the time of hiring of the average number of hours per day that the employee would normally be scheduled to work.

In no event, however, shall an employee’s paid leave under the Public Health Emergency Leave exceed $200 per day and $10,000 in the aggregate. Employers, of course, are free to exceed these amounts if they wish.

Are small businesses exempt from the Public Health Emergency Leave?

The law, as written, applies to all employers with fewer than 500 employees. However, the Secretary of the Department of Labor has the authority to issue regulations exempting small businesses with fewer than fifty (50) employees when providing the leave would jeopardize the viability of the business as a going concern. We will keep you posted if, and when, such regulations are issued.

Can I require employees to provide prior notice of their need for Public Health Emergency Leave?

Yes. Where the need for leave is foreseeable, employers can require employees to provide as much prior notice of the leave as is practicable. For emergency situations, employers should require notice as soon as it can reasonably be provided by the employee.

Is an employee entitled to be restored to their job once their Public Health Emergency Leave ends?

Generally, employers must reinstate employees to their job following their use of Public Health Emergency Leave.

However, for employers with fewer than 25 employees, reinstatement is not required when the position no longer exists due to economic conditions or other changes in the operating conditions of the employer that (i) affect employment and (ii) are caused by a public health emergency during the period of leave. If an employee’s position is eliminated, the employer is required to make reasonable efforts to restore the employee to a position equivalent to the position the employee held when the leave commenced, with equivalent benefits, pay, and other terms and conditions of employment.

If, despite an employer’s reasonable efforts to locate an equivalent position, no equivalent positions exist, the employer is required to contact the employee if an equivalent position later becomes available within a one (1) year period beginning on the earlier of the date on which the qualifying need related to a public health include emergency concludes or twelve (12) weeks after the employee’s leave began.

When does the Public Health Emergency Leave take effect?

Employees may begin taking Public Health Emergency Leave on April 2, 2020. An employee’s entitlement to Public Health Emergency Leave ends on December 31, 2020.

Emergency Paid Sick Leave Act 

For what purposes can employees use paid sick leave? 

Employees may use paid sick leave if the employee is unable to work or telework due to a need for leave because:

  1. The employee is subject to a Federal, State, or local quarantine or isolation order related to COVID-19.
  2. The employee has been advised by a health care provider to self-quarantine due to concerns related to COVID-19.
  3. The employee is experiencing symptoms of COVID-19 and seeking a medical diagnosis.
  4. The employee is caring for an individual who is subject to a Federal, State, or local quarantine or isolation order related to COVID-19, or who has been advised by a health care provider to self-quarantine due to concerns related to COVID-19.
  5. The employee is caring for a son or daughter of such employee if the school or place of care of the son or daughter has been closed, or the child care provider of such son or daughter is unavailable, due to COVID-19 precautions.
  6. The employee is experiencing any other substantially similar condition specified by the Secretary of Health and Human Services in consultation with the Secretary of the Treasury and the Secretary of Labor.

An employer of an employee who is a health care provider or emergency responder may exclude such individuals from being eligible for paid sick leave.

Which employees are eligible for paid sick leave?

All employees, irrespective of how long they have been employed by an employer, are eligible for paid sick leave under this law.

Can an employer require that an employee exhaust his/her other paid leave before using paid sick leave under this law?

No.

How much paid sick leave can an employee take?

Full-time employees are entitled to up to eighty (80) hours of paid sick time. Part-time employees are entitled to paid leave for a number of hours equal to the number of hours that the employee works, on average, over a two-week period.

Do I have to provide paid sick leave under this law even though I already offer paid sick leave under the Massachusetts Earned Sick Time Act?

Yes. The law explicitly provides that it does not diminish the rights or benefits that an employee is entitled to under any state or local law. Similarly, the law does not diminish any rights or benefits the employee may be entitled to under a collective bargaining agreement or existing employer policy.

At what rate does the sick time have to be paid?

The employee’s sick time will be paid at the greater of: (i) the employee’s regular rate of pay, (ii) the federal minimum wage (currently $7.25 per hour); or (iii) the current minimum wage in the applicable state or locality (currently $12.75 per hour in Massachusetts).

If an employee uses paid sick leave for his/her own health (as set forth in paragraphs 1, 2 & 3 of the first Emergency Paid Sick Leave FAQ above), the employee is entitled to receive the full amount of their regular pay (subject to the maximum amounts referenced below).

If an employee uses sick leave for one of the other reasons (as set forth in paragraphs 4, 5 & 6 above), the employee’s sick leave will be paid at two-thirds the amount the employee would receive if he/she had used sick leave for his/her own health (subject to the maximum amounts referenced below).

If an employee is not scheduled to work, is he/she entitled to paid sick leave?

The employee is entitled to such amounts for the number of hours he/she would otherwise be normally scheduled to work.

For those employees who work part-time and whose schedule varies weekly, employees are entitled to be paid based on the average number of hours that the employee was scheduled per day over the 6-month period ending on the date on which the employee takes the paid sick time, including hours for which the employee took leave of any type.

If the employee did not work over such period, the employee is entitled to receive paid sick time based on the employer’s reasonable expectation at the time of hiring of the average number of hours per day that the employee would normally be scheduled to work.

Is there a cap on the amount of pay the employee is entitled to receive while on sick leave?

Yes. If an employee takes leave for his/her own health (as set forth in paragraphs 1, 2 & 3 above), the employee is entitled to no more than $511 per day, and $5,110 in the aggregate.

If an employee takes leave for one of the other reasons (as set forth in paragraphs 4, 5 & 6 above), the employee is entitled to no more than $200 per day, and $2,000 in the aggregate.

Are smaller employers exempt from providing paid sick time?

The Secretary of the Department of Labor has the authority to exempt small businesses with fewer than fifty (50) employees from the obligation to provide paid sick leave to allow an employee to care for his/her child if the school or place of care of the child has been closed, or the child care provider is unavailable, due to COVID-19 precautions, if allowing this leave would jeopardize the viability of the business as a going concern. There is no such exemption for small businesses under paragraphs (1), (2), (3), (4) and (6).

Are there any posting requirements?

Yes, employers must post and keep posted a notice that will be prepared or approved by the Department of Labor outlining the above requirements. The notice must be posted in a conspicuous place on the premises of the employer where notices are customarily posted.

When can employees start using paid sick leave?

April 2, 2020. An employee’s entitlement to paid sick leave shall end on December 31, 2020. Employees are not entitled to carry-over any unused sick time into 2021.

Mirick O’Connell’s Labor, Employee and Employee Benefits Group will continue to monitor the latest developments regarding the Families First Coronavirus Response Act and will update you accordingly. Please contact any member of our team if you have any questions

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Executive Order Loosens Open Meeting Law Requirements During Coronavirus Emergency

Governor Baker signed an Executive Order relieving government boards and committees from compliance with certain Open Meeting Law requirements during the novel Coronavirus (COVID-19) emergency. The Order gives public bodies greater leeway to hold closed-door and remote meetings, so that government agencies may conduct business while also complying with public health recommendations regarding social distancing.

Under the Order:

  • Public bodies may hold meetings without providing physical public access so long as the public has access to deliberations through alternative means.
  • Alternative means include telephone or video conferencing and other methods of providing real-time public access to government meetings.
  • When public participation at a meeting is required by law (such as a public hearing), the alternative means of public access must allow for active, real-time participation (such as an open conference call or live stream video with a comment option).
  • Public bodies may allow for remote participation in meetings by all members, including the chair, with no members being physically present at the meeting location.
  • All other provisions of the Open Meeting Law remain in effect (posting meeting notices, recording and approving meeting minutes, executive session requirements, etc.).

The Order is effective immediately and remains in effect until rescinded or until the Governor’s State of Emergency is terminated.

Please contact one of our attorneys with any questions about the Executive Order.

Mirick O’Connell will continue to update clients about legal issues associated with the Coronavirus pandemic.

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The Coronavirus and Its Impact on the Workplace

With cases of the novel coronavirus (COVID-19) significantly on the rise, the World Health Organization declaring the coronavirus outbreak a pandemic, and Governor Baker recently declaring a state of emergency in the Commonwealth, employers should be prepared to address a number of potentially complicated employment-related issues that may result. This Client Alert is intended to assist employers in addressing scenarios that are likely to arise as the coronavirus spreads.

As an initial matter, employers are well-advised to review the latest interim guidance for employers and businesses from the Centers for Disease Control (CDC) which can be found here. Among other recommendations, the CDC advises that employers should “actively encourage sick employees to stay home,” separate employees who “appear to have acute respiratory illness symptoms (i.e., cough, shortness of breath) upon arrival to work or become sick during the day” and send them home immediately, and perform “routine environmental cleaning” of the office.

In addition to the CDC’s guidance, we have laid out several FAQs addressing anticipated employment-related scenarios that may result from the coronavirus. This is not an exhaustive list of possible situations and each particular circumstance may differ depending on the facts involved. For these reasons, it is recommended that employers consult with counsel if they are unsure about a particular course of action.

Q & A

If one of my employees is traveling, may I ask him/her where they are going or where they have been?

Yes. Employers are permitted to inquire about the travel destinations of their employees, even if travel is personal. To the extent an employer begins this practice of inquiring about employee travel, it should do so uniformly to avoid potential claims of disparate treatment based on membership in a protected class.

May I instruct employees who have been to a region where coronavirus is prevalent, or who otherwise believe they may have been exposed, to stay home?  

Yes. Employers may instruct employees who have traveled to a location where coronavirus is prevalent, or who believe they may have been exposed to coronavirus, to stay home. Employers must, however, be sure that they apply this practice uniformly across the workforce.

If I instruct an employee not to physically come into the office, do I have to pay him/her when he/she is at home?

The answer here depends upon the employee’s FLSA status (i.e., exempt/non-exempt) and whether the employee is, in fact, working while they are at home.

If a non-exempt employee is not performing any work while home, he/she is not entitled to any wages. If, however, a non-exempt employee is working at home, the employee should be instructed to keep track of, and be paid for, all hours worked. In this situation, the best practice is to have employees email their hours worked each day to their supervisor. In addition, although employees are not physically in the office, they are nonetheless entitled to an uninterrupted thirty (30) minute meal break for every six consecutive hours they work.

An exempt employee must be paid his/her full salary for any workweek in which the employee performs any work. Thus, if the employee works only one day during the week, he/she is nonetheless entitled to his/her full salary for the week, subject to limited exceptions. One exception permits an employer to reduce an exempt employee’s pay for “absences of one or more full days due to sickness or disability if the deduction is made in accordance with a bona fide plan, policy or practice of providing compensation for salary lost due to illness.” Finally, if an exempt employee does not perform any work for an entire workweek due to a self-quarantine, he/she is not entitled to his/her salary for that week.

What are my wage/salary payment obligations to my employees if I decide to temporarily close my operations?

As noted above, non-exempt employees are not entitled to wages if they render no services to the employer. Therefore, during a company shutdown, non-exempt employees would not be entitled to wages (assuming they perform no work during the shutdown).

With respect to exempt employees, if a company shutdown lasts a full week, and the exempt employee does not otherwise perform any work during that time, the exempt employee is not entitled to a salary for that week. The analysis differs slightly where an employer shuts down its operations for only part of a week. In that regard, exempt employees must be fully compensated for those days during the week that the Company is shutdown. This means that the employee must receive their full salary – or an amount equal to their full salary (i.e., paid vacation) – for that week. A failure to pay exempt employees’ full salaries could lead to the employees losing their “exempt” status and becoming eligible for overtime.

If I require an employee to stay home, or the employee voluntarily chooses to self-quarantine, is the employee entitled to use his/her earned sick time?

The Massachusetts Earned Sick Time Law allows employees to use earned sick time for several reasons including, but not limited to, “car[ing] for the employee’s own physical or mental illness, injury, or other medical condition that requires home, preventative, or professional care” and/or “car[ing] for a child, parent, spouse, or parent of a spouse who is suffering from a physical or mental illness, injury, or other medical condition that requires home, preventative or professional care.”

Thus, if, while at home, the employee is not sick and is not caring for a sick family member, he/she is not entitled to use earned sick time (although employers may decide to relax their policy requirements during this time). Notwithstanding the foregoing, there is an argument that such time away from the office may constitute preventative care and, thus, entitle the employee to use his/her earned sick time. Separate and apart from an analysis under the Earned Sick Time Law, if the employee otherwise has banked sick time, the employer could certainly allow the use of such sick time even if the employee is not symptomatic.

Of course, if the employee and/or a family member are sick with the coronavirus, the employee is entitled to use his/her earned sick time.

If an employee calls out sick, can I ask if they are experiencing symptoms of the coronavirus?

The Americans with Disabilities Act (ADA) permits employers to ask employees if they are experiencing coronavirus-like symptoms, such as fever, cough, and shortness of breath. Employers who keep records of this inquiry must ensure that the information is kept confidential and separate and apart from an employee’s personnel file.

Employers should also be aware that, under the Massachusetts Earned Sick Time Law, they may ask for written documentation, like a doctor’s note, only in limited circumstances, including, but not limited to, when the employee is absent from work for more than 24 consecutively-scheduled work hours and/or the employee is absent for three consecutively-scheduled work days. In requesting written documentation, an employer should not require the employee to disclose the details of the medical condition.

If my company is covered by the federal Family and Medical Leave Act (FMLA), are employees entitled to use FMLA leave if they are required to stay home?

The FMLA allows an employee of a covered employer to take an unpaid leave of absence for up to twelve weeks to care for the employee’s own serious health condition and/or to care for a family member with a serious health condition. Generally, an employee who is forced to stay home or who voluntarily chooses to self-quarantine as a precaution would not be eligible for FMLA leave.

However, because the coronavirus is very likely to qualify as a serious health condition under the FMLA, if an employee and/or the employee’s family member contracts the virus, the employee will likely be eligible for FMLA leave (assuming the employee meets the additional statutory criteria).

If I force an employee to stay home, or an employee chooses to self-quarantine, can I require the employee to use his/her paid time off?

Employers must follow their paid time off policies as written. Therefore, an employer may require its employees to use available paid time off if permitted by its policy.

To the extent that an employer has a paid time off policy that lumps vacation and sick time together, and the employee’s absence does not qualify as an allowable purpose under the Earned Sick Time Law, the employer must be careful to ensure that its employees are nonetheless able to use up to at least forty (40) hours of the paid time off per year for the purposes allowed under the statute.

If an employee shows up to work with coronavirus-like symptoms, can I require them to go home?

Yes. As noted above, the CDC recommends that employees who arrive at work showing coronavirus-like symptoms be sent home immediately.  Moreover, pursuant to the federal Occupational Safety and Health Act, employers have a general duty to furnish each worker with “employment and a place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.” Sending an employee home who is demonstrating coronavirus-like symptoms would almost certainly fall under the umbrella of an employer’s duty to furnish a safe workplace.

Similarly, the Equal Employment Opportunity Commission (EEOC) has advised that sending an employee home who is demonstrating symptoms of an illness would be permissible because the illness, if mild, would not constitute a disability under the ADA (or G.L. c. 151B). However, even if the illness was severe enough, such that it would constitute a disability under the ADA (or G.L. c. 151B), sending an employee home would nonetheless be justified under a direct threat to the workplace analysis.

Is there anything I have to do if an employee contracts coronavirus at the office?

Yes. As many employers are aware, the Occupational Safety and Health Administration (“OSHA”) recordkeeping requirements mandate that covered employers record certain work-related illnesses and injuries on their OSHA 300 log. Although employers are not required to record when an employee is infected with the common cold and flu on the job, OSHA recently issued guidance stating that if an employee is infected with coronavirus while on the job, the employer must include this illness in their 300 log.

For additional OSHA related considerations, employers are well advised to review OSHA’s recently published “Guidance on Preparing Workplaces for COVID-19” which can be found here .

Employers should also consider contacting their workers’ compensation insurance carrier in the event an employee contracts coronavirus in the office.

Can I require an employee who has been out of the office as a result of the coronavirus to provide a doctor’s note certifying that the employee is fit to return to work?

Yes, requiring an employee to submit a doctor’s note clearing the employee to return to work would be job-related and consistent with business necessity because having an employee in the workplace not fully recovered from the coronavirus would pose a direct threat to the workplace. As such requiring such a doctor’s note would not run afoul of the ADA or state-law statutory equivalent (G.L. c. 151B).

Employers are always free to go above and beyond legal requirements and, thereby, elect to pay wages for employees either during a company-wide shutdown or for employees who must remain out of work on self-quarantine, due to showing signs of illness, or when mandated by the employer as a precautionary measure. Certainly, such generosity on the part of an employer will be well received and will go a long way toward the preservation of positive morale.

Please contact any member of the Labor, Employment, and Employee Benefits team if you have any questions about this Client Alert, or any issues that may arise in your workforce due to the coronavirus. 

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NLRB Issues Employer-Friendly “Joint Employer” Definition

On February 25, 2020, the National Labor Relations Board (the “NLRB”) announced the final rule governing “joint employer” status under the National Labor Relations Act. The determination of whether an entity is a “joint employer” with a direct employer for purposes of the NLRA informs whether the entity may be liable for the unfair labor practices committed by the direct employer and/or has a duty to bargain with a representative of the employees of the direct employer.

Under the final rule, to be a “joint employer,” an entity must “share or codetermine the employees’ essential terms or conditions of employment.” Specifically, the entity must “possess and exercise substantial direct and immediate control over one or more essential terms and conditions of employment of another employer’s employees as would warrant a finding that meaningfully affects matters relating to the employment relationship with those employees.”

This employer-friendly definition is similar to the definition used by the NLRB prior to its landmark 2015 decision in Browning-Ferris, which endorsed a definition that relaxed the requirements for proving a joint employer relationship.

The final rule also defines key terms, including:

  • “Essential terms and conditions of employment” is defined to mean “wages, benefits, hours of work, hiring, discharge, discipline, supervision and direction.”
  • “Substantial direct and immediate control” is defined to mean “direct and immediate control that has a regular or continuous consequential effect on an essential term or condition of employment of another employer’s employees.”
    • Direct and immediate control with respect to wages, is defined to mean “actually determin[ing] the wage rates, salary, or other rate of pay that is paid to another employer’s individual employees or job classifications.”
    • Direct and immediate control with respect to hours of work is defined to mean “actually determin[ing] work schedules or the work hours, including overtime, of another employer’s employees” and does not mean “establishing an enterprise’s operating hours or when it needs the services provided by another employer.”
    • Direct and immediate control with respect to discharge is defined to mean “actually decid[ing] to terminate the employment of another employer’s employee” and it does not mean “refusing to allow another employer’s employee to continue performing work under a contract.
  • “Indirect control” means “indirect control over essential terms and conditions of employment of another employer’s employees” but does not include “control or influence over setting the objectives, basic ground rules, or expectations for another entity’s performance under a contract.”

The final rule makes clear that evidence of “indirect control” over the essential terms and conditions of employment is probative of joint employer status, but only to the extent that such indirect control supplements and reinforces evidence of direct and immediate control over essential terms and conditions.

By issuing a comprehensive definition in the final rule, the NLRB has provided much-needed clarity that conflicting NLRB and Court decisions could not reach regarding the determination of whether employers are “joint employers.” The final rule will become effective on April 27, 2020.

If you have any questions regarding joint employer status or any other human-resource related issue, please contact one of our Labor and Employment attorneys.

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Act Requiring the Hands-Free Use of Mobile Devices Went into Effect Yesterday

On November 25, 2019, the Commonwealth of Massachusetts approved Chapter 122 of the Acts of 2019. Under this Act, operators of motor vehicles cannot use handheld electronic devices while driving. The Act specifically holds that no operator of a motor vehicle shall use a mobile electronic device unless the device is being used in a hands-free mode. No operator of a motor vehicle shall read or view text images or video displayed on a mobile electronic device provided, however, that an operator may view a map generated by a navigation system application “on a mobile electronic device that is mounted on or fixed to a vehicle’s windshield, dashboard or center console in a manner that does not impede the operation of the motor vehicle.” 

These prohibitions do not apply to emergency first responders or if the vehicle is parked and not in a travel lane. The Act also does not prohibit emergency use including if the vehicle is disabled or if there is a need for police, fire, or medical services for the personal safety of the operator or passengers.

A violation of the law is subject to a $100 fine for first offense; $250 fine for second offense; and a $500 fine for third and subsequent offenses. In addition, for a second offense, the Registrar of Motor Vehicles is charged with requiring violators to attend a training program. 

Employers should review their handbooks and prohibit employees from using hand-held devices while operating an employer’s motor vehicle. 

The Act went into effective on February 23, 2020. If you have any questions on this Act, please feel free to contact a member of the Labor and Employment Law Practice Group.  

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