Quick Signature: Fix DC Paid Family Leave regulations!

Tell the DC Office of Paid Family Leave: Fix the proposed regulations!

DC’s Office of Paid Family Leave recently released proposed benefit regulations for the District’s paid leave program and unfortunately, there’s a serious problem with these proposed regulations. But if we speak up about this problem, we can fix it!

The proposed regulations include a “current employment” requirement that means tens of thousands of workers may not be able to access the paid family and medical leave benefits they’re promised by the law.

>>> Tell DC’s Office of Paid Family Leave: DROP the “current employment” requirement in section 3500.1(c)(1)(A) of the regulations!

The Universal Paid Leave Act is supposed to apply to everyone who has worked in DC in the past year. The 'current employment' requirement means that people who are between jobs for any reason — whether they were laid off when they’re pregnant, or are temporarily unable to work for medical reasons or because they are caring for a loved one — don't get the financial support that was already paid for and that the Universal Paid Leave Act promises them.

Dear Associate Director Madison:

Thank you for the opportunity to comment on the proposed benefit regulations on the Universal Paid Leave Act. It is clear that the Office of Paid Family Leave (OPFL) has put a lot of thought into strengthening and refining the program's regulations, an essential blueprint for how DC can better support families experiencing life's joys and challenges — thank you!

I am very concerned that the proposed regulations continue to restrict program eligibility to only currently employed people. This provision violates both the plain language and intent of the law to cover everyone who has worked in DC within the past year, and it will harm working families. I urge you to remove section 3500.1(c)(1)(A) from the regulations.

More than 58,000 people in DC work for companies of fewer than 20 employees, and so will not qualify for DCFMLA when taking paid leave. Further, thousands of employees of larger companies will not qualify for DCFMLA or FMLA due to tenure requirements. Without the employment protections provided by DCFMLA and /or FMLA, a 'current employment' requirement may unfairly put paid leave out of reach for these individuals.

A 'current employment' requirement may also incentivize bad actor employers to discriminate against many thousands of the District's junior-level, administrative, and lower wage workers whom employers often see as easily replaceable. Firing a pregnant or caregiving worker — disproportionately likely to be women — is still an all too common occurrence, and section 3500.1(c)(1)(A) adds perverse financial incentives for employers to retaliate when an employee needs time off to tend to their family.

Paid family and medical leave is an opportunity for the District to lead the nation in correcting a long history of discriminatory policies that have created barriers to economic opportunity for women and people of color. Rather than reinforce these systemic barriers that produce economic disparities, paid leave regulations should reflect the intent of the law: to fix the injustice of vulnerable workers suffering financially due to caregiving, whether or not their employer retains them. To create an inclusive economy that provides working families with pathways to the middle class, DOES must allow workers who have been laid off — or who work seasonally, needed to leave their job, are between jobs, or are otherwise not presently employed — to remain eligible for paid leave based on wage history as prescribed by the Universal Paid Leave Act.

I additionally encourage you to revise the proposed regulations' claims process for intermittent leave. The current process assumes individuals will have standardized leave need schedules, and I fear this process will not work for many health needs in reality. Caregivers need simpler and more flexible scheduling and payment processes. Please work with medical professionals, policy experts, HR specialists, and individuals who have needed to take different types of intermittent leave to devise a more commonsense approach to processing these unique leave claims.

Thank you for considering my feedback on the proposed regulations. I look forward to supporting your efforts to establish a world-class paid leave program for our workforce.

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