The City of Pittsburgh has provided much needed clarity regarding several lingering questions concerning the Paid Sick Days Act (the Act), which requires all private employers of full- or part-time employees within the City of Pittsburgh to provide paid sick leave benefits.

In July 2019, the Pennsylvania Supreme Court upheld the Act following a nearly four-year long legal battle. At that time, the effective date of the Act and the status of prior guidelines issued by the City was unsettled. This week, the City addressed some of those unsettled issues.

First, the City announced that the Act will take effect on March 15, 2020.

Employers with 15 or more employees should take notice that existing employees must accrue paid sick time in accordance with the Act beginning on that effective date (March 15, 2020) and any new employees hired after that date must begin to accrue paid sick time at the commencement of their employment.

Employers with less than 15 employees are required only to provide unpaid sick time during the first year after the Act takes effect. However, beginning on March 15, 2021, such smaller employers also will have to provide paid sick time in accordance with the Act.

Second, the City published a sample notice that employers can use to comply with the general notice requirements under the Act. To that end, the Act requires employers to display a sign at each worksite providing notice to employees of their right to sick time, available limits, terms of use, that retaliation against employees who request or use sick time is prohibited, and their right to file a complaint regarding suspected violations of the Act. The City’s notice template is intended to provide such information.

Finally, the City also published guidelines to assist employers in understanding how the Act will be administered and enforced. As we summarized in a prior article, the Act establishes various requirements with which employers must comply, including, for example, those pertaining to carrying over an employee’s accrued sick time, calculating accrued time for exempt and non-exempt employees, acceptable uses of sick time, paid sick time record keeping and retention requirements, and prohibitions on retaliation against employees for utilizing their paid sick time Through its guidelines, the City clarifies many questions that have lingered over the past few years while Pittsburgh employers awaited the outcome of the aforementioned legal challenge.

With only a short time before the Act takes effect, it is imperative that all private employers with Pittsburgh-based employees take action now to review their policies and practices so as to ensure compliance with the Act.