9. Public Health Emergency Leave Program

INTERNAL AUDIT REPORT 
Operational Audit 
Public Health Emergency Leave Program 

March 2020  July 2020 


Issue Date: October 15, 2020 
Report No. 2020-14

Public Health Emergency Leave Program 

TABLE OF CONTENTS 

Executive Summary ................................................................................................................................................ 3 
Background ............................................................................................................................................................. 4 
Audit Scope and Methodology ............................................................................................................................... 5 
Schedule of Findings and Recommendations ....................................................................................................... 6 
Appendix A: Risk Ratings ..................................................................................................................................... 13 
Appendix B: Scenarios for the use of Leave during COVID-19 (Non-Represented) ......................................... 14 













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Public Health Emergency Leave Program 
Executive Summary 
Internal Audit (IA) completed an audit of the Public Health Emergency Leave (PHEL) program for pay periods
ending March 28, 2020 through July 4, 2020. The audit was performed, at the request of the Sr. Director of
Human Resources, to determine whether the use of PHEL was in alignment with Port policy. 
The Families First Coronavirus Response Act (FFCRA) was created in March of 2020. One of the articles of
the FFCRA required employers to provide eligible employees up to 80 hours of paid sick leave when an
employee was unable to work if they met specific criteria related to the COVID-19 pandemic. In order to
comply with the FFCRA, the Port created the PHEL program, which authorized 80 hours of leave. Beginning
in April 2020, the Port approved an additional 160 unmandated hours, per employee, for COVID-19 related
leave. 
Between the pay periods ending March 28, 2020 through July 4, 2020, 952 Port employees used nearly
155,000 hours of PHEL at an estimated cost to the Port of $7.7 million. See Appendix B for additional
information on eligibility requirements for the use of PHEL. The Program is currently set to expire on
December 31, 2020. 
IA interviewed supervisors from multiple departments and reviewed documents that were used to account
for the use of PHEL. IA noted that there was a wide range of interpretations on what was considered an
allowable use of PHEL, especially earlier in the program. For example, IA observed that PHEL was approved
to care for extended family members, employees could quarantine and use PHEL without notifying Health
and Safety, and PHEL was given to staff, on a rotational basis, to allow employees an equitable opportunity
to take it. Furthermore, IA noted instances where temporary and short-term employees could use PHEL. 
Human Resources (HR) assigned an employee from Total Rewards to track employees who used PHEL, the
criteria that made them eligible, supporting documents, and the number of PHEL hours used. Total Rewards
tracking accounted for 482 of the 952 people who used PHEL in the period under review. The 470 people,
not tracked by Total Rewards, were those with exposure or confirmed COVID-19 cases, and those
employees who took PHEL as part of minimum essential staffing in circumstances when not enough work
was available for staff. HR gave individual departments latitude on how to use PHEL in instances of minimum 
essential staffing, physical distancing, or because of the lack of work. 
In general, we determined that the use of PHEL was in alignment with policy. However, if it is the Port's
intention to continue the PHEL program, management should update the policy to be more concise, and
strengthen internal controls over documentation, approval, and monitoring PHEL compliance. We identified
the following opportunities where internal controls can be enhanced or developed. These are discussed in
more detail beginning on page six of this report. Additionally, we communicated a matter to management
related to an employee's unemployment claim via a management letter. 
1.   (High) The lack of centralized administration of the PHEL program, and vague policy language increased
the potential that PHEL was abused or approved for unintended purposes. 
2.  (High) Port management did not have adequate procedures in place to monitor the potential of
employees collecting unemployment insurance benefits and receiving compensation from the Port
concurrently. This risk was increased by the large-scale state unemployment fraud. 

Glenn Fernandes, CPA 
Director, Internal Audit 

Responsible Management Team 
Katie Gerard, Sr. Director Human Resources 
Tammy Woodard, Director Human Resources - Total Rewards 

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Public Health Emergency Leave Program 
Background 
On March 27, 2020, the Federal FFCRA was signed into law. A part of the FFCRA required employers
to provide eligible employees up to 80 hours of paid sick leave if specific criteria were met, including 
when: 
The employee is unable to work because the employee was subject to a federal, state, or local
quarantine or isolation orders related to COVID19. 
The employee is advised by a health care provider to self-quarantine due to concerns related to
COVID19 or is experiencing COVID19 symptoms and seeking a medical diagnosis. 
The employee is unable to work because of a need to care for an individual subject to a federal,
state, or local quarantine or isolation order related to COVID19 or has been advised by a health
care provider to self-quarantine due to concerns related to COVID19. 
The need to care for the employee's son or daughter whose school or place of care is closed, or
whose childcare provider is unavailable, due to COVID19 related reasons. 
The employee is experiencing a substantially similar condition, as specified by the Secretary of
Health and Human Services. 
To comply with the FFCRA, the Port created the PHEL program, which authorized 80 hours of leave. 
Beginning in April 2020, the Port approved an additional 160 unmandated hours, per employee, for
COVID-19 related leave. Between the pay periods ending March 28, 2020 through July 4, 2020, 952
Port employees used nearly 155,000 hours of PHEL at an estimated cost to the Port of $7.7 million1. 
This was a special engagement requested by the Sr. Director of Human Resources. The objective of
the audit was to determine whether the use of PHEL aligned with Port policy. In order to achieve this
objective, IA utilized a risk-based approach, selected a sample of individuals who took PHEL. The table
below provides additional details for the 287 employees who were included in our sample.
Criteria                                  No. of Employees         Hours 
(Audit Sample) 
High risk                                                   37          8,334 
Children                                                16         4,132 
(school- aged/daycare closure) 
Exposure/ Confirmed COVID-19                      19        1,575 
Minimum staffing2 or rotational basis-                   215        40,034 
5 departments/teams interviewed 
Totals                   287        54,075 

During the audit, IA became aware that the Port approved active employees, who did not want to return
to work because of COVID-19 concerns, take Leave Without Pay (LWOP) so that they could apply for
unemployment benefits. IA expanded its review to determine whether individuals collected PHEL and
unemployment benefits simultaneously. 


1 Average hourly burden rate of $49.69 (average base rate $39.44 X average Port employer burden costs of 26%) multiplied
by 155,000 PHEL hours. 
2 Four of the five departments/teams interviewed primarily used a rotation basis, without priority given to those who met
other eligibility criteria. Some of the employees may have taken PHEL for reasons other than rotation. 

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Public Health Emergency Leave Program 
Audit Scope and Methodology 
We conducted the engagement in accordance with Generally Accepted Government Auditing Standards 
and the International Standards for the Professional Practice of Internal Auditing. Those standards
require that we plan and conduct an engagement to obtain enough, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our engagement objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and conclusions, based on our
engagement objectives. 
The period audited was March 2020 through July 2020 and included the following procedures: 
Compliance with PHEL Policy 
Obtained documents and reports, including: timesheets (coded to PHEL), Health and Wellness'
employee COVID-19 exposure and confirmed cases tracking spreadsheet, and departmental
schedules and timesheets. 
Interviewed managers and staff from multiple departments, including: Marine Maintenance, AV 
Maintenance, AV Electrical & Electronic Systems, Landside Operations, PCS Construction, and
AV Security. 
Obtained an understanding of how individual departments administered the use of PHEL. 
Tested a sample of employees and traced their PHEL eligibility to supporting documentation. 
Unemployment Insurance and PHEL 
Obtained the following data, documents, and reports: employees who requested LWOP after
exhausting PHEL, Washington State Employment Security Department (ESD) Claims for 2nd 
quarter 2020, payroll reports for employees who coded time to PHEL by pay period, a description
of the Pandemic Unemployment Assistance Benefits program, and the Complete Claims Activity
Report. 
Verified that active employees who elected to not return to work, met the criteria established by
the Pandemic Unemployment Assistance Benefits program. 
Compared employees who collected unemployment benefits through the ESD to those who
coded PHEL during the same period. 








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Public Health Emergency Leave Program 
Schedule of Findings and Recommendations 
1) Rating: High 

The lack of centralized administration of the PHEL program, and vague policy language
increased the potential that PHEL was abused or approved for unintended purposes. 
The PHEL program was administered and monitored by multiple departments based on eligibility criteria. 
The following main groups were responsible to monitor PHEL: 
Total Rewards Group 
The Total Rewards group, within HR, was responsible for administering PHEL in accordance with Port
policies. Eligible employees included those, who met the criteria of a high-risk category, those who had
school-aged children, or those whose child's schools or daycare centers were closed because of
COVID-19 related purposes. Employees were required to notify the Total Rewards group in order to
take PHEL. An assigned person from the Total Rewards group tracked these employees, reviewed their
eligibility, reviewed supporting documents, if provided, and the number of hours taken. This information
was maintained in a spreadsheet. 
Health and Safety 
Health and Safety, within HR, maintained a separate spreadsheet. Health and Safety's spreadsheet
consisted of employees who were exposed to, experienced symptoms, or tested positive for COVID-19.
This group advised employees whether they needed to quarantine and the length of time. Health and
Safety did not monitor or track the number of hours an employee used. 
Departments approved for minimum essential staffing 
Minimum essential staffing included two criteria: lack of work, or staff required reduction in order to
maintain six feet of distance. The Policy did not address how PHEL was to be used for minimum staffing.
Managers and supervisors worked with Total Rewards to gain an understanding of how to use PHEL 
for minimum essential staffing; however, HR gave departments flexibility on how to allocate, track, and
monitor their PHEL use. Some managers allowed staff to take PHEL through a rotational basis, so that
there was an equitable opportunity for all their employees. Managers indicated that in some cases,
employees approved by HR for allowable conditions, volunteered to follow the rotation instead of the
approved criteria. 
There was no centralized database/spreadsheet which included names of all the employees who used
PHEL, the number of hours taken, supporting documents if submitted, and which eligible criteria were 
used. For instance, during the period under audit, Total Rewards' spreadsheet accounted for 482 of the
952 people who used PHEL. The difference was because Total Rewards did not track how individual
departments used PHEL for minimum essential staffing, or for those who took PHEL from exposure or
confirmed cases of COVID-19. 
IA judgmentally selected 72 employees from the spreadsheet provided by Total Rewards to determine
whether the use of PHEL was allowable, and appropriately supported. Additionally, IA interviewed
managers and supervisors from multiple departments who used PHEL. We noted that there was a wide
range of interpretations on what was considered an allowable use of PHEL, especially during the early
stages of the Program. 


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Public Health Emergency Leave Program 
The following table details our observations. 
Observations                                Causes Identified 
PHEL was approved to care for extended family   Unclear guidance and difficulty in understanding
members.                                   the PHEL policy, especially at the start of the
Program. 
In one department, approved for minimum        Lack of clear guidance and a centralized group
essential staffing, employees could quarantine,     to monitor the Program. 
and use PHEL without notifying Health and
Safety. 
Most of the departments that we interviewed,      Lack of one assigned person or department to
approved for minimum essential staffing, allowed  monitor the process. Lack of proper guidance in
their staff to use PHEL on a rotational basis.       the policy on the use of minimum essential
staffing. 
Departments used schedules to track hours
worked, which provided an estimate of hours
used as PHEL, but not actual hours used.
During our interviews, one department's           Lack of clear guidance and a centralized group
manager stated that some of his staff felt it was    to monitor the process. The policy did not
not fair that they were required to go to the office   address how PHEL was to be used for minimum
regularly while others did not. After the manager   essential staffing. 
consulted with other departments, his
department decided to follow a rotation, so that
everyone received a fair opportunity to use
PHEL. 
During one of our interviews, it was alleged        Employees were not required to submit
employees viewed PHEL hours as an            documentation because public health guidance
entitlement and used it for vacation. It was also    recommended that employers not ask for
alleged that some employees were not truthful     verification from medical providers in order to
when they reported COVID-19 exposure/ health   decrease the potential of overwhelming the
conditions to Health and Safety in order to utilize   health care system. The Port could have
this benefit.                                              adopted a compensating verification process,
Some of the managers we interviewed            such as requiring self-certification from
expressed concerns that they felt people took      employees. However, Port policy did reserve the
advantage of the Program but had no way to      right to request documentation should it become
substantiate it.                                         necessary. 
Instances where employees had the ability to
telework but took the full 80 hours of PHEL in a    Lack of one assigned person or department to
pay period.                                          monitor the Program. 
One employee used an additional 16 hours of
PHEL beyond the authorized 240 hours. This 
was not caught in the pay period the error
occurred. 
PHEL coding issues, between PHEL and ESL.    Lack of one assigned person or department to
Also, in one instance, an employee coded a       monitor the process. Managers did not always
holiday as PHEL on their timesheet. In another    have first-hand knowledge of their direct reports
instance, an employee coded bereavement       leave. In some groups, administrative assistants
leave as PHEL.                                 approve timesheets. 


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Public Health Emergency Leave Program 
Without adequate oversight and strong internal controls, there was an increased risk that PHEL may be
used for unintended purposes or abuse. The lack of one assigned person or department, to monitor the
Program as a whole, is a major contributor to the observations noted above. 
Recommendations: 
If the intention is to continue with the PHEL program, management should update the policy to be more
concise, and strengthen the controls over documentation, approval, and compliance monitoring. 
Management Response/Action Plan: 
Human Resources (HR) concurs with many of the auditors' observations. Our intent when establishing
Public Health Emergency Leave was to have it be general enough that it could apply in the future if the
Port were again faced with a pandemic. To address the general nature of PHEL we developed an
administrative document to help guide administration of PHEL during this COVID-19 pandemic. As
information rapidly evolved about the COVID-19 virus and the Centers for Disease Control (CDC)
updated their guidelines, we updated our guidance to employees and managers but did not have
capacity to keep updating the administrative document as new information became available and
guidelines or recommendations changed. Further, managers were given authority to approve use of
PHEL when necessary,  due to minimum essential staffing needs,  so that employees all had
opportunities to work, or to ensure that appropriate social distancing requirements were maintained
within their workgroup. 
Also, in an effort to honor employee privacy and keep medical information confidential while still
managing the Port's response to employees exposed to, or diagnosed with COVID-19, we segregated
oversight of PHEL use based on the situation while facilitating communication between HR staff about
PHEL availability and usage. Finally, we developed and implemented PHEL from a position of trust and
communicated this in multiple public forums. HR approved PHEL usage consistent with the current
guidelines and the information provided by employees at the time without requiring documentation to
confirm eligibility.
To help managers stay informed and up to date on appropriate use of PHEL, employees from HR and
Labor Relations made themselves available and often met weekly, or even twice a week, with work
groups to answer questions and provide guidance. Guidance offered included appropriate use of PHEL
in specific situations, and information about changes to the PHEL program as it evolved. While these
meetings are no longer actively taking place, communications between HR, Labor Relations and work
groups continue.
We now recognize that the approach to managing the PHEL program may have added to confusion,
contributed to inconsistent application of the leave guidelines, and permitted possible utilization of PHEL
that was inconsistent with the intent of the leave benefit. To address this, HR has made changes to our
processes including centralizing administration and oversight of PHEL and designating one person as
the overall PHEL program administrator. We have communicated this across the Port and have begun
referring all questions and requests for approval to use PHEL to the one individual. We have also
updated our internal HR processes to facilitate stronger connections and communications between the
various HR employees whose subject matter expertise requires that they engage with employees or
managers and answer questions or address administration of PHEL. 
We are also updating our administrative document and reviewing the PHEL FAQs to make needed
updates. The updated administrative document will be posted on the Port's internal web site by the
middle of October and the FAQ document will be revised and the revised version posted as soon as all
the FAQs are reviewed by appropriate subject matter experts and updated as needed.
HR has also noted that time approval practices vary considerably across the Port. Because of this, HR 

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Public Health Emergency Leave Program 

is communicating the importance of managers reviewing PHEL usage of employees in their groups and
has begun stating that managers are responsible for working with time approvers to ensure submitted
PHEL time is accurately reported before it is approved. This includes ensuring that PHEL is only paid
when it was taken as approved. To further support this HR plans to initiate conversations with other
departments to begin strengthening manager oversight and approval of time reporting. 
Finally, we are encouraging employees to contact our central PHEL program administrator with
questions or concerns about potential inappropriate use of PHEL. HR will follow up and address
questions or concerns as appropriate. 
DUE DATE: 12/01/2020 















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Public Health Emergency Leave Program 
2) Rating: High 

Port management did not have adequate procedures in place to monitor the potential of
employees collecting unemployment insurance benefits and receiving compensation from the
Port concurrently. This risk was increased by the large-scale state unemployment fraud. 
When a former employee applies for unemployment benefits through the Washington State Employment
Security Department (ESD), the ESD will make the determination if they are eligible for benefits and will
pay the former employee. On a quarterly basis, the ESD submits a billing statement to the Port for
reimbursement. The ESD's billing statement includes the name of the claimant, the effective date of the
first claim submitted, and the benefit payment amount. The billing statement does not have a breakdown
of each weekly submittal. 
Normally, unemployment benefits are only available for employees who are involuntarily no longer
employed by the Port. However, when the COVID-19 pandemic began, the FFCRA included a provision
called the Pandemic Unemployment Assistance Benefits. The change in unemployment eligibility, under
the FFCRA, created an opportunity for employees to collect unemployment benefits while still employed.
Even if the employees were called back to work, they could claim unemployment if they met specific
criteria that was established by the Center for Disease Control (CDC). The criteria included: 
Part-time workers and others who had lost work due to COVID-19. 
Parents who had lost child-care due to COVID-19. 
People at high risk of contracting COVID-19. 
People sick or caring for someone with COVID-19. 
People who were unemployed due to COVID-19 and were not eligible for regular unemployment
benefits. 
Multiple departments, and one third-party vendor had separate roles in monitoring the PHEL program
and unemployment claims. Under normal circumstances, the Port's internal controls would catch an ineligible
unemployment benefit claim. However, given the eligibility changes in unemployment benefits
that were established from the FFCRA, Port management did not adjust procedures to cover the new 
risks that emerged where an active employee could collect unemployment benefits and receive
compensation from the Port at the same time. 
The ESD billing statement, for the second quarter of 2020, included 84 former and current employees
who received unemployment benefits. We compared those names to payroll reports that showed all
employees who had PHEL coded to their timesheets. Through this, we identified five employees who
may have reported compensable time on their timesheets and received unemployment benefits
simultaneously. However, we were unable to verify the results because neither the Port nor the thirdparty
vendor obtained detailed, weekly unemployment claim reports from the ESD. 
There is a possibility that the unemployment claims for these five employees may be part of the larger
unemployment fraud that occurred in the State of Washington during this time. 




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Public Health Emergency Leave Program 
Recommendations: 
HR should reconcile the timesheets, of the five employees identified, to ESD weekly claim reports
in order to determine whether the employees received both unemployment benefits and payroll 
concurrently. 
If any discrepancies are identified, HR should work with the responsible departments and/or
agencies to correct the errors. 
If misconduct or fraud is identified, HR should notify Workplace Responsibility as appropriate. 
Management Response/Action Plan: 
Human Resources (HR) concurs with the Audit findings. We are committed to improving our
unemployment administration procedures. Specifically, we are taking the following steps to better
monitor the potential for employees to receive unemployment benefits and Port compensation
simultaneously. 
Upon receipt of notice from Employer's Edge, the Port's third-party unemployment program
administrator, of an unemployment claim filed by a Port employee, a Total Rewards Specialist runs
a labor distribution report for the last pay cycle to see if the employee/claimants has been
compensated by the Port (regular time, PHEL, ESL, E-FMLA Port Paid Family Leave, or accrued
leave) to assess for potential fraud. 
Upon receipt of notice from Employer's Edge of an unemployment claim filed by a Port employee,
the PHEL program administrator will verify whether the employee/claimant has been approved for
PHEL, ESL, or LWOP because of PHEL exhaustion. If the employee/claimant has not been
approved  for  these  timecodes,  the  PHEL  program  administrator  will  reach  out  to  the
employee/claimant and manager to verify appropriate use. 
If the Total Rewards Specialist sees regular hours, PHEL, ESL, E-FMLA Port Paid Family Leave, or
accrued leave worked in the previous pay cycle, they contact the employee/claimant to ask if they
filed the claim; and if so, why. In some circumstances, employees file unemployment claims in
advance of pending schedule changes resulting in LWOP due to limited staffing/PHEL exhaustion.
The Total Rewards Specialist shares this information with Employer's Edge, the PHEL program
administrator,  and  the  Sr.  Employee  Relations  Consultant,  who  will  reach  out  to  the
employee/claimant's manager to verify work schedule and time reporting. 
Upon receipt of notice from Employer's Edge of an unemployment claim filed by a Port employee,
the PHEL program administrator will verify whether the employee/claimant has been approved for
PHEL, ESL, or LWOP because of PHEL exhaustion. If the employee/claimant has not been
approved  for  these  timecodes,  the  PHEL  program  administrator  will  reach  out  to  the
employee/claimant and manager to verify appropriate use. 
If the Total Rewards Specialist sees regular hours, PHEL, ESL, E-FMLA Port Paid Family Leave, or
accrued leave) worked in previous pay cycle, they contact the employee/claimant to ask if they filed
the claim and if so, why. In some circumstances, employees file unemployment claims in advance
of pending schedule changes resulting in LWOP due to limited staffing/PHEL exhaustion. The Total
Rewards Specialist shares this information with Employer's Edge, the PHEL program administrator,
and the Sr. Employee Relations Consultant, who will reach out to the employee/claimant's manager
to verify work schedule and time reporting.
Upon receipt of the ESD quarterly bill and benefits charges details report, the Sr. Employee Relations
Consultant and PHEL program administrator will work closely with Payroll to review labor distribution
reports for employees who received unemployment benefits and Port compensation during the
relevant time period to ensure no overpayment occurred. 
If overpayment is found, the Sr. Employee Relations Consultant will contact the employee/claimant's
manager to review the claim. The Sr. Employee Relations Consultant will also direct Employer's
Edge to notify ESD that the employee/claimant received unemployment benefits and Port
compensation simultaneously during the relevant time period. 
If the overpayment reflects potential fraud, HR will notify Workplace Responsibility for follow up. 

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Public Health Emergency Leave Program 
The Sr. Employee Relations Consultant will confirm receipt of reimbursement by ESD to the Port of
the overpayment in the quarterly bill and benefits charges details report. 
We are still collecting data from ESD regarding the five employees identified as receiving both
unemployment benefits and Port compensation simultaneously during 2nd quarter. ESD has yet to
provide the Port its quarterly bill and benefits charge details report for 2nd quarter. Once we receive the
benefits charge details report for 2nd quarter 2020, we will review Port compensated time (labor
distribution reports) to determine if the Port compensated the five employees for dates, they received
unemployment benefits. If so, we will advise ESD of the overpayment and request reimbursement. 
It should be noted that during this time, widespread unemployment fraud occurred in Washington State
and several Port employees were impacted. 
DUE DATE: 12/01/2020 














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Public Health Emergency Leave Program 
Appendix A: Risk Ratings 
Findings identified during the audit are assigned a risk rating, as outlined in the table below. Only one
of the criteria needs to be met for a finding to be rated High, Medium, or Low. Findings rated Low will
be evaluated and may or may not be reflected in the final report. 
Financial      Internal                                               Commission/
Rating                                   Compliance      Public 
Stewardship  Controls                                         Management 
High probability
Missing or not   Non-compliance
for external audit    Requires
with Laws, Port
High       Significant     followed                          issues and / or     immediate
Policies, 
negative public     attention 
Contracts 
perception 
Partial controls   Partial              Potential for
compliance with   external audit
Requires
Medium   Moderate                  Laws, Port       issues and / or
attention 
Not functioning  Policies            negative public
effectively         Contracts           perception 
Functioning as
Low probability
intended but     Mostly complies                       Does not
for external audit
could be        with Laws, Port                       require
Low      Minimal                                   issues and/or
enhanced to     Policies,                            immediate
negative public
improve        Contracts                           attention 
perception 
efficiency 









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Public Health Emergency Leave Program 
Appendix B: Scenarios for the use of Leave during COVID-19 (Non-Represented) 

Last Updated: 5/18/2020 
This document is subject to change as more                      = Depending on
Legend:                          = Yes, Applicable                                                   = Not available for use 
information becomes available.                                                                         circumstance 
COVID Related Leaves Available                               Other Available Leaves 
Public Health
Emergency Sick Leave     Expanded FMLA       PTO/Vac       Sick Leaves        LWOP        FMLA/ADA 
Emergency Leave 

All Eligible Employees  All Eligible Employees    All Employees
All Employees            All Employees          Employees >30 days      (Represented - check   (Represented - check   (Represented - check   All Eligible Employees 
CBA)            CBA)            CBA) 

Employee is mildly ill with a
diagnosed case of COVID-19                                                                           

Employee is severely ill with a
diagnosed case of COVID-19                                                                           

Employee was exposed and
quarantined by a health care
professional. Port remains open.                                                                          
Employee is unable to or refuses
to telework. 
Employee is caring for sick family
member with a diagnosed case of                                                                         
COVID-19. 

Employee's family member
advised by Health Provider to
quarantine or isolate and needs                                                                           
care. 
Schools are closed because of
COVID-19 and employee has no
childcare. Employee is unable to                                                                       
or refuses to telework. 
Employee is immunecompromised
or in a high risk
group and advised by a health
care professional to self-                                                                            
quarantine. Employee is unable
to telework. 
Employee is afraid of gathering in
a group and refuses to go to
work. Employee is unable to or                                                                           
refuses to telework. 

Port closes employee's primary
work location due to quarantine.                                                                         

Full or partial pay             Full Pay              Full Pay             Partial Pay 
TRC 215             TRC 216             TRC 217 
Time Reporting Code 
Program Code 8100      Program Code 8100      Program Code 8100 
Effective Dates            3/15/2020-tbd      4/1/2020-12/31/2020    4/1/2020-12/31/2020 
2 weeks with ESL and 10 
Maximum Amount Available    240 hours for full time    80 hours for full time 
weeks without 

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