Employee travel and FFCRA

We are looking for some guidance about what counts as a “qualifying reason” for paid sick leave through FFCRA. One of our employees went to Mexico this week for vacation. Per CDC, she will need to quarantine for 14 days upon return to the U.S. We are trying to figure out if we should/need to pay her for those 14 days of quarantine. Telework is not an option for her position. Thank you for any guidance you may have!

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The DOL says:

Under the FFCRA, an employee qualifies for paid sick time if the employee is unable to work ( or unable to telework ) due to a need for leave because the employee:

  1. is subject to a Federal, State, or local quarantine or isolation order related to COVID-19;
  2. has been advised by a health care provider to self-quarantine related to COVID-19;
  3. is experiencing COVID-19 symptoms and is seeking a medical diagnosis;
  4. is caring for an individual subject to an order described in (1) or self-quarantine as described in (2);
  5. is caring for a child whose school or place of care is closed (or child care provider is unavailable) for reasons related to COVID-19; or
  6. is experiencing any other substantially-similar condition specified by the Secretary of Health and Human Services, in consultation with the Secretaries of Labor and Treasury.

The CDC’s isolation order for international-travel quarantine would qualify as reason #1.

As a health care practice, you can exercise an exemption from FFCRA if you wish. If you choose to pay her, it’s only 10 days (80 hours), not 14.