As a result of the COVID-19 crisis, the Connecticut Commission for Human Rights and Opportunities (“CHRO”) has announced it will provide extensions of time for certain deadlines for COVID-19 related reasons.
Sexual Harassment Training
The CHRO posted on its website that it will consider a 90-day extension of the deadline for employers to provide sexual harassment training to new employees hired on or after October 1, 2019. We confirmed with the CHRO that this extension does not apply to employees hired before that date. The current deadline to train new hires is six months after their date of hire. In seeking the extension, the employer must explain how COVID-19 issues prevented it from providing training to their new hires. Examples of restrictions preventing an employer from providing training include a lack of access to technology including computer/the internet, illness of the employee or other unforeseeable circumstances.
The CHRO’s announcement is available here.
Answers to CHRO Charges, Mandatory Mediation Conferences, Fact Finding Conferences and Document Requests
The CHRO may also provide 30-day extensions or continuances to the parties for response deadlines and conferences. Similar to the training deadline extension, the request must be COVID-19 related. Upon request, the extensions are as follows:
- Answers. Employers will be provided an additional 30 days to submit answers and Schedule A responses. Generally, employers may only obtain to a 15-day extension.
- Mandatory mediation conferences. The CHRO will provide a 30-day continuance for mandatory mediation conferences.
- Fact finding conferences. The CHRO will also provide a 30-day continuance for fact finding conferences scheduled on a date where in-person meetings are prohibited. Additional continuance requests will be decided on a case-by-case basis and should be granted for reasons such as non-essential business closure, healthcare entities whose priority is COVID-19, illness, quarantine, or child or dependent care due to COVID-19. If there are further continuance requests, a CHRO investigator can choose to proceed with available parties/witnesses and follow up or reschedule parties and/or witnesses for COVID-19 related reasons.
- Document requests. Parties will also receive a 30-day extension to comply with document requests. Additional requests will be decided on a case-by-case basis and granted for reasons such as documents that need to be copied and are not available electronically, administrative, clerical or secretarial staff shortages, non-essential business closure, health care entities whose priority is COVID-19, illness, quarantine, or child or dependent care due to COVID-19.
The CHRO’s announcement is available here.
As always, if you have any questions, please contact us.
D. Charles Stohler
(203) 575-2626; cstohler@carmodylaw.com
Giovanna T. Weller
(203) 575-2651; gweller@carmodylaw.com
Domenico Zaino, Jr.
(203) 578-4270; dzaino@carmodylaw.com
Alan H. Bowie
(203) 784-3117; abowie@carmodylaw.com
Stephanie E. Cummings
(203) 575-2649; scummings@carmodylaw.com
Maureen Danehy Cox
(203) 575-2642; mcox@carmodylaw.com
Pamela Elkow
(203) 252-2672; pelkow@carmodylaw.com
Vincent Farisello
(203) 578-4284; vfarisello@carmodylaw.com
Sarah S. Healey
(203) 578-4225; shealey@carmodylaw.com
Lauren M. Hopwood
(203) 784-3104; lhopwood@carmodylaw.com
Howard K. Levine
(203) 784-3102; hlevine@carmodylaw.com
Mark F. Williams
(203) 575-2618; mfwilliams@carmodylaw.com
Holly G. Wheeler
(203) 784-3158; hwheeler@carmodylaw.com
Sherwin M. Yoder
(203) 784-3107; syoder@carmodylaw.com