However, the regulations (i.e., the DOL's temporary final rule) only mentions joint employees in the context of determining employer coverage under the FFCRA. There are no specific requirements about paying "joint... more »
We need agricultural compliance assistance material. More information is needed on how the new FFCRA can best be implemented in the agriculture industry. We have seasonality, variable work hours, piece-rate pay structures. We need more information in Spanish to provide to employees.
Office of Compliance Initiatives
To whom it may concern,
We at the Centro Comunitario de Trabajadores (CCT), a not for profit organization based out of New Bedford, Massachusetts (MA) that seeks to improve working conditions through organizing and community building, and Justice at Work, a Boston based not for profit organization that provides technical and legal support to worker... more »
The Honorable Eugene Scalia
Secretary of Labor
U.S. Department of Labor
200 Constitution Ave NW
Washington DC 20210
Dear Secretary Scalia:
The United Food and Commercial Workers International Union (UFCW) submits these comments on the Department of Labor (DOL) Temporary Rules for the Emergency Family Medical Leave Act and the Emergency Paid Sick Leave Act (85 FR 19326; RIN 1235-AA35), enacted... more »
Thank you for organizing this massive dialogue and responding to all of our suggestions and comments. It has been a most insightful experience as an employer, attorney, and citizen/employee. In these unprecedented times, it is truly remarkable (and inspiring) to see this level of collaboration and communication... more »
1. Clarification is needed regarding the issue of substitution for EFMLEA. The preamble of the regulations are clear that existing FMLA rules apply; that employers can require substitution during the first two weeks since it's unpaid, but it has to be employee/employer agreement for the remainder of leave since it's paid. And that makes sense. But the regulations... more »
It would be very useful to have a series of question-decision flowcharts that guide employer and employee through determining eligibility for the emergency leave by reason: i.e., six flowcharts for emergency FMLA, one flowchart for paid sick leave. We will be developing such documentation if we need to, but it would help a lot to have the DOL set the standard. Thank you.