Employers and Employer Groups

Question on Small Employer under 500 Employees

We are a holding company with 30 separate entities, one parent company. We are having a hard time determining if we are an employer under 500. If the DOL uses the criteria for regular FMLA, then we would probably considered an employer over 500. Has the DOL given consideration as to using the same guidelines for determining the size of an employer as you are currently using for the already established FMLA? The rules/regs for the current FMLA was thoroughly vetted with input and consideration over a extensive period. Since the new FMLA paid leave has been implemented so quickly, I would think DOL would rely on the FMLA rules already in place.

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Idea No. 634