New York Law

What is "Employment" in the Gig Economy?

July 2, 2018

By Thomas G. Eron

The task-based business model of the gig economy is transformative in every industry affected, from ride-hailing (Uber, Lyft), to housing rental (Airbnb), to food delivery (Uber Eats, Grubhub), to professional services (Upwork, Guru).  There seemingly is no end to the potential competitive disruption of gig entrepreneurs.  This expansion continues to exert significant pressure on the fundamental question:  are those who complete the tasks or provide the services employees or contractors?  The question is neither new nor novel.  The answer is pivotal to the success of the businesses and the expectations of the service providers and business owners.

Read More >> What is "Employment" in the Gig Economy?

From "Fair Share" to Simply "Unfair" for New York Public Employees

June 12, 2018

By James Holahan and Theresa E. Rusnak

Mark Janus, an Illinois child welfare worker, decided not to join the American Federation of State, County, and Municipal Employees -- the union that represents his public sector co-workers.  Under Illinois law, however, Janus is still required to pay fees to the union.  These fees are known as “fair-share” fees, a label which refers to the Illinois law requiring the union to “fairly” represent Janus and all of his co-workers, whether or not they are union members.  For this representation, non-union members like Janus must pay a “fair-share” fee,” which is approximately 78 percent of the full union dues, and in Janus’ case, amounts to $23.48 per pay period.

Janus has objected to the payment of this fee, and his case has reached the United States Supreme Court.  A ruling by the Court in Janus v. AFSCME will be released very soon, and that ruling is expected to strike down the Illinois “fair share” law and similar state laws (including the law in New York) because they violate the United States Constitution.

Read More >> From "Fair Share" to Simply "Unfair" for New York Public Employees

New Legislation Focused on Preventing Sexual Harassment Included in the 2019 New York State Budget

April 13, 2018

By Megan M. Collelo

The unveiling of New York State’s 2019 budget made it clear that the state has maintained its focus on curbing sexual harassment in the workplace.  Included in the legislation, which was delivered to the Governor on April 2, 2018, are numerous new requirements impacting both private and public employers.

Read More >> New Legislation Focused on Preventing Sexual Harassment Included in the 2019 New York State Budget

Public Employees Will Soon Be Entitled to Paid Leave for All Types of Cancer Screenings

January 18, 2018

By Hilary L. Moreira

On December 18, 2017, Governor Cuomo signed legislation that amended Civil Service Law Sections 159-b and 159-c.  Currently, those sections entitle most public sector employees to take up to four hours of paid leave per year to be screened for breast cancer (159-b) and up to four hours of paid leave per year to be screened for prostate cancer (159-c), without deducting any leave time (e.g., sick, personal, or vacation) from the employee.

Effective March 18, 2018, Civil Service Law Section 159-b will be amended by broadening the scope of that provision so that it will apply to all cancer screenings.  Because Section 159-b will now apply to all types of cancer screenings (including screenings for prostate cancer), Civil Service Law Section 159-c (relating to prostate cancer screenings) will be repealed.

Public employers should review their policies to ensure that employees are permitted to take up to a maximum of four hours of paid leave per year for any type of cancer screening, without deducting any other leave time (e.g., sick, personal, or vacation) from the employee.

Reminder: New York Minimum Wage Rates and Salary Thresholds for the Executive and Administrative Exemptions Will Increase on December 31, 2017

December 21, 2017

By Subhash Viswanathan

Although the minimum wage rate under the Fair Labor Standards Act remains $7.25 per hour and the U.S. Department of Labor’s efforts to raise the minimum salary to qualify for a white-collar exemption under federal law have stalled, employers in New York should be aware that the state minimum wage rate and the state salary threshold to qualify for the executive and administrative exemptions will increase effective December 31, 2017.

The increases to the state minimum wage effective December 31, 2017, are as follows:

  • Employers outside of New York City, Nassau, Suffolk, and Westchester counties:  $10.40 per hour
  • Employers in Nassau, Suffolk, and Westchester counties:  $11.00 per hour
  • Employers in New York City with 10 or fewer employees:  $12.00 per hour
  • Employers in New York City with 11 or more employees:  $13.00 per hour

Fast food employees will be entitled to an even higher wage rate effective December 31, 2017, as follows:

  • Fast food employees outside of New York City:  $11.75 per hour
  • Fast food employees in New York City:  $13.50 per hour

The salary threshold to qualify for the executive and administrative exemptions effective December 31, 2017, are as follows:

  • Employers outside of New York City, Nassau, Suffolk, and Westchester counties:  $780.00 per week
  • Employers in Nassau, Suffolk, and Westchester counties:  $825.00 per week
  • Employers in New York City with 10 or fewer employees:  $900.00 per week
  • Employers in New York City with 11 or more employees:  $975.00 per week

New York does not set a salary threshold to qualify for the professional exemption, so employees must meet the current federal salary threshold of $455.00 per week to qualify for the professional exemption.  For all of the white-collar exemptions, employees must also meet the applicable duties requirements.

A chart summarizing the minimum wage rates, tip credits, uniform maintenance allowances, meal and lodging credits, and exempt salary thresholds under the Miscellaneous Industries Wage Order can be found here.  A chart summarizing this same information under the Hospitality Industry Wage Order can be found here.

NYC Passes Amendment to Earned Sick Time Act to Include “Safe Time” for Domestic Violence Victims

November 14, 2017

By Jacqueline A. Smith

On November 6, 2017, New York City Mayor Bill de Blasio signed into law an amendment to the City’s administrative code which would afford leave time to victims of family offense matters, sexual offenses, stalking, and human trafficking, and their family members.  The amendment will take effect 180 days after the Mayor’s signing (May 5, 2018), and New York City will join a host of other states and municipalities that already provide similar leave time for domestic violence victims and their families.

Chapter 8 of Title 20 to the NYC Administrative Code, previously titled the “Earned Sick Time Act,” will now be referred to as the “Earned Safe and Sick Time Act.”  Under the amendment, employers with five or more employees are required to provide a minimum of one hour of safe/sick time for every thirty (30) hours worked by an employee.  Employers are not required to provide more than forty (40) hours of safe/sick time in a calendar year.

A covered employee who is a victim or who has a family member who has been the victim of a family offense matter, sexual offense, stalking, or human trafficking is entitled to use safe time for any of the following reasons:

  • To obtain services from a domestic violence shelter, rape crisis center, or other shelter or services program for relief from a family offense matter, sexual offense, stalking, or human trafficking;
  • To participate in safety planning, temporarily or permanently relocate, or take other actions to increase the safety of the employee or employee’s family members from future family offense matters, sexual offenses, stalking, or human trafficking;
  • To meet with a civil attorney or other social service provider to obtain information and advice on, and prepare for or participate in any criminal or civil proceeding, including but not limited to, matters related to a family offense matter, sexual offense, stalking, human trafficking, custody, visitation, matrimonial issues, orders of protection, immigration, housing, discrimination in employment, housing, or consumer credit;
  • To file a complaint or domestic incident report with law enforcement;
  • To meet with a district attorney’s office;
  • To enroll children in a new school; or
  • To take other actions necessary to maintain, improve, or restore the physical, psychological, or economic health or safety of the employee or the employee’s family member or to protect those who associate or work with the employee.

Employers may request documentation for an absence of more than three (3) consecutive work days for safe time.  Documentation signed by an employee or volunteer of a victim services agency, an attorney, a member of the clergy, or a medical or other professional service provider constitutes reasonable documentation under the Act.  The production of a police or court record, or even a notarized letter from the employee explaining his/her need to take safe leave may also be considered reasonable documentation.  Employers are prohibited from requiring that the documentation specify the details of the family offense matter, sexual offense, stalking, or human trafficking.

Employers are required to provide notice to employees of their right to safe leave within thirty (30) days of the amendment’s effective date.

In January 2017, the New York State Senate introduced a bill which would amend the State Labor Law to similarly provide unpaid leaves of absence for victims of domestic or sexual violence.  To date, this bill — Senate Bill S2856 — remains before the Senate Labor Committee and has not yet been calendared for presentation before the State Senate.  Versions of this bill have been introduced by the State Senate in prior years without much success.  However, in light of New York City’s recent addition of safe time, the presentation and passage of this bill may be more likely than in previous years.

New York Proposes New “Call-In” Pay and Scheduling Requirements

November 14, 2017

By Andrew D. Bobrek

Employers in New York will be subject to new “call-in” pay and scheduling requirements under recently-proposed state Regulations.  Governor Andrew Cuomo recently announced these proposed Regulations, which the New York State Department of Labor (“DOL”) will reportedly publish in the State Register on November 22, 2017.

New York regulators have recently focused their enforcement sights on the so-called “just-in-time” or “on-demand” scheduling of workers.  According to Governor Cuomo, this practice entails the scheduling or cancelling of a worker’s shift with little or no advance notice.  At the Governor’s direction, the DOL recently held hearings across the state on this issue, which then led to issuance of the proposed Regulations.

If enacted, the proposed Regulations would amend New York’s catch-all “Miscellaneous Industries” minimum wage order, including those portions applicable to non-exempt “nonprofitmaking institutions” across the state.

Call-In Pay Under Current New York Law

Under the Miscellaneous Industries minimum wage order, non-exempt employees who report to work are currently entitled to call-in pay equal to the lesser of four hours of pay or pay for the number of hours in the regularly-scheduled shift, at the state minimum wage rate.  Notably, the DOL has interpreted this provision, such that it only effectively applies to non-exempt workers who earn at or very near the state minimum wage.  In this regard, the DOL previously stated in Opinion Letter No. RO-09-0133, dated December 2, 2009:  “[I]f the amount paid to an employee for the workweek exceeds the minimum and overtime rate for the number of hours worked and the minimum wage rate for any call-in pay owed, no additional payment for call-in pay is required during that workweek.” (emphasis added).

In other words, under DOL’s interpretation, New York employers could potentially apply an “offset” — for amounts paid to workers above the state minimum wage and overtime rates during the same workweek — against any “call-in” pay otherwise due to workers.

Additionally, under current law, employers are generally free to schedule, and, when necessary, cancel shifts before employees report for work, without incurring any additional payment obligation.

Call-In Pay Under the Newly-Proposed DOL Regulations

  • The recently-proposed Regulations would create a number of new circumstances when non-exempt employees will be eligible to receive “call-in” pay, including the following:
  • Employees who report to work for a shift that was not scheduled at least 14 days in advance will be entitled to an additional two hours of call-in pay;
  • Employees whose shifts are cancelled within 72 hours of the start of that shift will be entitled to at least four hours of call-in pay;
  • Employees who are required to be on-call and available to report to work for any shift will be entitled to at least four hours of call-in pay; and
  • Employees who are required to be in contact with their employer, within 72 hours of the start of a shift, to confirm whether or not to report to work for that shift will be entitled to four hours of call-in pay.

Under the Regulations, the above call-in pay must be calculated at the current state minimum wage rate (which now varies by location and workforce size) without any allowances, and employees must receive their “regular rate” for their actual time of attendance.  However, these new requirements will not apply to otherwise covered employees whose weekly wages exceed 40 times the applicable state minimum wage.

The proposed Regulations will also replace current “call-in” pay requirements with the following:

  • Employees who report to work for any shift will be entitled to at least four hours of call-in pay.

Notably, the proposed Regulations state:  “Call-in pay shall not be offset by the required use of leave time, or by payments in excess of those required under” the applicable minimum wage order.  Although this provision is not entirely clear on its face, conceivably, it was drafted with the intent of curtailing application of the above-referenced weekly “offset” provided under prior DOL interpretation.

Finally, the proposed Regulations state that the above requirements will not apply to certain employees “who are covered by a valid collective bargaining agreement that expressly provides for call-in pay.”  Further, the requirements may not apply in certain other circumstances, such as when a business cannot begin or continue operations due to a state of emergency or other “Act of God” beyond its control.

Employers should also be mindful that New York City recently passed a similar law that will become effective on November 26, 2017.  This other local law places somewhat similar requirements on retail employers, and also places additional requirements on certain fast food establishments.

According to DOL, the proposed Regulations will be subject to a 45-day comment period after official publishing.  We will update this article with any further developments, and will be announcing a free webinar on the proposed Regulations in the coming days.

If you have any questions about this issue in the meantime, please contact Andrew D. Bobrek, any of the attorneys in our Labor and Employment Law Practice, or the attorney in the firm with whom you are regularly in contact.

Author’s Note:  A special thanks to Richard White, who assisted in drafting this article.

New York State Releases Paid Family Leave Certification Forms

October 19, 2017

By Kerry W. Langan

The New York State Workers’ Compensation Board (“WCB”) has just released the long-awaited Paid Family Leave (“PFL”) forms. There is a general application form (PFL-1), as well as various certification forms depending on the type of leave requested:

  1. To apply for PFL to bond with a newborn or a newly adopted or fostered child, the WCB has developed the PFL-1 form and PFL-2 (a bonding certification form) https://www.ny.gov/sites/ny.gov/files/atoms/files/bonding.pdf
  2. To apply for PFL to care for a family member with a serious health condition, the WCB has developed the PFL-1 form, as well as PFL-3 (a release of personal health information form) and PFL-4 (a health care provider certification form) https://www.ny.gov/sites/ny.gov/files/atoms/files/careforfamilymember.pdf
  3. To apply for PFL for a qualifying exigency arising from service of a family member in the U.S. Armed Forces, the WCB has developed the PFL-1 form and PFL-5 (a form to certify the military qualifying event) https://www.ny.gov/sites/ny.gov/files/atoms/files/military.pdf

As we mentioned in a previous blog post, the WCB has already released the waiver form (PFL-Waiver) and two forms regarding voluntary coverage (PFL-135 and PFL-136).  We will continue to provide additional updates on PFL as they become available.

New York State Releases Waiver and Voluntary Coverage Forms

October 6, 2017

By Kerry W. Langan and Caroline M. Westover

The New York Workers’ Compensation Board recently released three key forms associated with Paid Family Leave (“PFL”):

  1. PFL-Waiver:  “Employee Opt-Out of Paid Family Leave Benefits”
  2. PFL-135:  “Employer’s Application for Voluntary Coverage” (No Employee Contribution)
  3. PFL-136:  “Employer’s Application for Voluntary Coverage” (Employee Contribution Required)

These are the first forms that the WCB has formally published in connection with PFL, which will become effective on January 1, 2018.  We are still waiting for the WCB to provide the requisite PFL certification forms and will provide additional updates as they become available.

Paid Family Leave: Week 3 of Q&As

August 16, 2017

By Christa Richer Cook and Kristen E. Smith

So here is Week 3 of Bond’s New York Paid Family Leave (“PFL”) Q&As.  This week we are focusing on which employers are and are not covered.  We also answer your questions about what certain exempt employers (i.e., those who are not required to have PFL coverage) must do in order to opt in for voluntary PFL coverage.  In fact, certain exempt employers have an obligation to make a decision by December 1, 2017, as to whether to opt in for PFL coverage and will be required to report their decision to the NYS Workers Compensation Board (“WCB”).

Question:  Are there any employers in New York that are not covered by PFL?

Answer:  Yes.  In light of the fact that PFL is intended to piggy back onto the Disability Benefits Law (“DBL”), it applies to any entity considered a covered employer under DBL.  While all private sector employers in New York that have one or more employees are subject to and have to comply with DBL, and now PFL, the same exclusions as to who is a “covered employer” apply.  Thus, employers exempt from DBL are also exempt from PFL.  PFL does not apply to public sector employers, including the state, any political subdivision of the state, a public authority, or any other governmental agency or instrumentality.  This exemption applies to cities, villages, towns, public libraries, public authorities, municipalities, fire districts, water districts, and school districts.

There are also a few others who are not required to provide PFL benefits, including owners/shareholders of a corporation with no employees, owners/shareholders of partnerships, LLCs, LLPs with no employees, individuals who employ personal or domestic workers that work less than 40 hours per week, Native American enterprises (i.e., casinos), self-employed individuals, or sole proprietors and members of an LLC/LLP.

Question:  Can public sector employers choose to be covered under the PFL law?

Answer:  Yes.  The PFL regulations lay out the process a public employer must follow if it elects to opt in.  The process is slightly different for unionized and non-unionized employers.  If a public employer chooses to cover its non-unionized workers, it must provide 90 days’ notice of its decision to opt in.  The notice must tell employees that the payroll deduction will not exceed the maximum amount allowed by law.

Not surprisingly, in order for a public employer to cover its employees who are represented by a union, it must engage in collective bargaining and obtain the agreement of the union.  Once an agreement is reached, the employer must notify the WCB for approval.

Notably, public employers are the only employers who can elect to provide DBL only, PFL only, or both DBL and PFL coverage.  Public employers who elect to provide PFL must maintain it for at least one year.  Prior to discontinuing voluntary PFL coverage, the public employer must provide 12 months’ written notice to the WCB and the affected employees.  Those employers will also need to have made provisions for the payment of any benefits incurred on and prior to the effective termination date of such benefits.

Question:  Are public sector employers who are already providing voluntary DBL coverage required to also provide PFL?

Answer:  No.  However, public sector employers who currently provide voluntary DBL to their employees must notify their employees and the WCB whether they will or will not be providing PFL to their employees.  This decision must be made and reported to the WCB by December 1, 2017.

*****

Please continue to visit our blog for weekly Q&As during August 2017 and other PFL updates throughout the fall.

If you have any questions about PFL, please contact the authors of this post, any of the attorneys in our Labor and Employment Law Practice, or the Bond attorney with whom you regularly work.

Paid Family Leave: Week 2 of Q&As

August 9, 2017

By Christa Richer Cook and Kristen E. Smith

Welcome to Week 2 of Bond’s New York Paid Family Leave (“PFL”) Q&As.  Many of the most commonly asked questions during Bond’s PFL webinars focused on the intersection of the federal Family and Medical Leave Act (“FMLA”), the Disability Benefits Law (“DBL”) and PFL.  In this post, we answer some of those questions.

Question:  Can an employee save their PFL time and take it after having already taken 12 weeks of FMLA?  Or vice versa, save their FMLA time and use it after taking PFL?

Answer:  Like every good legal question, the answer is . . . it depends.  More specifically, it depends on the reason for the leave.  It is important to bear in mind that the qualifying reasons for FMLA and PFL are like intersecting circles.  While there are some reasons that fall under both laws, there are some leaves that will be covered only by FMLA, and some that will be covered only by PFL.  So, an employee can only “save” one type of leave or “stack” the two leaves if one of the leaves (or part of a leave) qualifies under only one law.

To demystify this interplay, let’s take a few potential scenarios:

  • Karen takes leave to care for a grandparent with a serious health condition beginning in January 2018 for 8 weeks.  This is a PFL qualifying reason, but not an FMLA qualifying reason.  (Grandparents are a covered family member under PFL, but not under FMLA.)  Therefore, when Karen returns to work, she still has her full 12-week entitlement under FMLA.  In October 2018, Karen’s daughter has surgery and she needs 6 weeks off.  Although she has exhausted her PFL leave, she still has her entire FMLA bank of 12 weeks available (assuming the 1,250 threshold of hours is met) because the January leave did not count against her FMLA entitlement.  Karen ends up taking 14 job-protected weeks off in 2018 (and still has 6 weeks of FMLA time to spare!).
  • Ed takes leave in February 2018 because he is having bunion surgery.  His surgeon takes him out of work for 6 weeks.  This is an FMLA qualifying leave, but not PFL because an employee’s own serious health condition is not covered under PFL.  In July 2018, Ed’s father has a stroke.  Ed requests 10 weeks off because his father is undergoing rehabilitation.  Ed only has 6 more weeks of FMLA.  However, he still has 8 weeks of PFL leave that he has not yet touched!  Here is where things get more complicated:  Is Ed entitled to a total of 14 more weeks (6 FMLA + 8 PFL)?  No!  The first 6 weeks would count as both FMLA and PFL.  His father’s serious health condition is covered under both laws.  After 6 weeks, FMLA runs out, but Ed can stay out an additional 2 weeks under PFL.  In the end, he is entitled to only 8 more weeks — not the 10 he requested.  The employer could deny the additional 2 weeks.
  • Jeremy is a new father in 2018.  He has heard about these laws, and knows that FMLA provides 12 weeks and PFL provides 8 weeks (in 2018).  He requests 20 weeks to bond with his new baby boy.  Is he eligible for 20 weeks?  No.  In this case, the reason for the leave (bonding) qualifies under both laws.  Assuming Jeremy has met the eligibility requirements under both laws, the employer can require that the leaves be taken concurrently.  The 12 weeks (FMLA) and 8 weeks (PFL) run at the same time.  He can only take a total of 12 weeks of job-protected leave.

Question:  In that last example, couldn’t Jeremy say that he does not want to be paid for the first 12 weeks (the FMLA period) and refuse to file a PFL claim, in an attempt to save the PFL leave?

Answer:  No.  The PFL regulations provide that if a leave qualifies under FMLA and PFL, the employer designates the leave under FMLA, and the employee is notified that it is covered under both laws, the FMLA leave time will count against the employee’s PFL entitlement even if the employee refuses to file a PFL claim.

Question:  Can you review the maternity leave scenario again?

Answer:  Maternity leave promises to be the most confusing to administer because of the intersection of PFL, FMLA, and DBL.  Here is how it could play out in a typical pregnancy:  The first 6-8 weeks after childbirth is usually considered a period of disability, so the mother could use her DBL benefits without touching her PFL bonding benefit.  Then, when she completes that 6-8 week period, she could transition to PFL bonding leave and receive the 8 (eventually 12) week benefit after the DBL benefit.  Meanwhile, FMLA runs concurrently with both the DBL and then the PFL leave.  However, the mother’s leave entitlement does not end at the expiration of the 12 weeks of FMLA leave because under state law, she is entitled to the full 8 week PFL benefit once she finishes her DBL benefit.  The total job-protected time taken (assuming 6 weeks of DBL) is 14 weeks (6 + 8) in 2018.

Question:  Can a mother choose to forego DBL and go straight to PFL?

Answer:  Yes, once the baby is born, but it will reduce the total number of weeks she can be out on job-protected leave.  The mother could elect to start PFL bonding leave on the delivery date.  The 8 weeks of PFL would run concurrently with FMLA, and she would be entitled to a total of 12 weeks of leave.

Question:  We heard that intermittent leave under PFL can be taken in full day increments, and nothing shorter.  If an employee wants to take shorter increments, can the employee use just FMLA leave?  Does that count against his/her PFL entitlement?

Answer:  Luckily, the regulations address this very scenario.  If an employee takes FMLA leave in increments shorter than a day, and if the reasons for the leave would also qualify under PFL, the employer may track this time, and when “the total hours taken for FMLA in less than full day increments reaches the number of hours in an employee’s usual work day, the employer may deduct one day of paid family leave benefits from an employee’s annual available family leave benefit.”  However, “[t]he employer shall not be entitled to reimbursement from its carrier for such paid FMLA hours.”  12 N.Y.C.R.R. § 380-2.5(g)(5).

*****

Please continue to visit our blog for weekly Q&As during August 2017 and other PFL updates throughout the fall.

If you have any questions about PFL, please contact the authors of this post, any of the attorneys in our Labor and Employment Law Practice, or the Bond attorney with whom you regularly work.

Paid Family Leave: Week 3 of Q&As

July 31, 2017

By Christa Richer Cook and Kristen E. Smith

Thank you to everyone who attended Bond’s webinar on New York Paid Family Leave (“PFL”) on Tuesday, July 25, 2017.  We had a tremendous turnout and received hundreds of questions.  While we didn’t have the opportunity during the webinar to address all of the inquiries that we received, we noted afterwards that many employers raised the same questions.  Accordingly, for the month of August, we will be posting a weekly blog article dedicated to answering some of the most frequently asked questions we received during the webinar.  We hope this follow-up will be helpful to employers in preparation for the launch of PFL in 2018.

Today’s PFL Q&As focus on taking leave to provide care for a family member with a serious health condition.

Question:  Can I use PFL to care for my family member with a serious health condition, if the family member lives in a different state?

Answer:  The PFL regulations are not entirely clear on this point.  However, the Workers’ Compensation Board (“WCB”) takes the position that an eligible employee may take PFL to care for a family member who lives in another state.  The key here is that the employee is in “close and continuing proximity to the care recipient,” which the WCB has interpreted to mean in the same general location as the family member receiving the care.  So, for example, if an employee requests PFL to care for a grandparent living in Texas, the employee would need to physically go to Texas to provide care in order to be covered under the PFL.

Question:  What constitutes “providing care” for a family member with a serious health condition?

Answer:  Providing care includes necessary physical care, assistance with essential daily living matters, assistance in treatment, and personal attendant services.  It also includes emotional support, visitation, transportation, and/or arranging for changes in care.

Question:  Can I take PFL to care for an adult child?

Answer:  Yes.  Unlike the FMLA, which contains limits on an individual’s ability to take leave for an adult child, the PFL permits a qualified employee to care for any child with a serious health condition, regardless of the child’s age.

*****

Please continue to visit our blog for weekly Q&As during August 2017 and other PFL updates, as appropriate.

If you have any questions about PFL, please contact the authors of this post, any of the attorneys in our Labor and Employment Law Practice, or the Bond attorney with whom you regularly work.