Public comments for: Paid Sick Leave Rules

Comments

Comment:
See attached testimony.
Supporting Document:
Agency: DCA
Comment:
Why is the exception for coverage under the rules -- "if they call in for work assignments at will, determine their own work schedule, have the ability to reject or accept any assignment referred to them, and are paid an average hourly wage, which is at least four times the federal minimum wage" -- apparently limited to the small category of physical therapists, occupational therapists, speech language pathologists, and licensed audiologists? Shouldn't any part-time professional worker who fits those criteria be exempted? For example, a contract lawyer or a tutor might not qualify for the independent contractor exemption if they're working for a company that parcels out assignments, but it doesn't seem appropriate to apply the new rules if the worker simply reschedules their missed assignment.
Agency: DCA
Comment:
We currently provide paid time off beyond the 40 hours to our full-time employees as part of our Vacation policy. Are employers required to distribute the new Sick Leave Notice to all employees or only those affected?
Agency: DCA
Comment:
"Up to 40hours of unused sick leave can be carried over to the next calendar year. But the employers is only required to let you use up to 40hours of sick leave per calendar year." How does this work, if the employee banks 40hrs from the previous year and uses them in the following year, what happens to the current accure sick time. The employee will always have to carry over sick days. How does this benefit the employee?
Agency: DCA
Comment:
I wonder if the department has considered making an exception for substitute teachers or other on-call employees. As the rule stands, a substitute teacher could accrue enough hours to earn paid sick time, and could then conceivably demand to be paid for it even during a period when that employee is not called to work and effectively has time off.
Agency: DCA
Comment:
Are employees paid from federal and government grants excluded from sick leave?
Agency: DCA
Comment:
Current proposed rules exempt Students in federal work study programs. Since many Colleges supplement federal work study programs, must a student be paid 100% from federal work study only? In addition, some students paid from federal work study also have secondary jobs paid from grants or other sources are these positions excluded from sick leave?
Agency: DCA
Comment:
Under the current proposed rules City and Government employers are exempt, why are non-profit employers not excludes.
Agency: DCA
Comment:
I understand that the employer can only mandate a "reasonable" amount of accrued time to be applied when the employee is out, but that the minimum cannot exceed 4 hours. If an employee has accrued 40 hours of sick time, this means they have up to 10 permissible absences per year. Ten days out?? This will have a very negative impact on a small employer like ourselves. I think the stipulation should be that employers can mandate that the employee use the number of hours they would have normally been scheduled to work. So if they were assigned to work a 7 hour shift, that's what they would be required to use. We don't allow our staff who receive a full compliment of PTO benefits to use those hours at their own discretion / at self selected amount. If they are out, and they have Sick time, that's what they use for their full day absence, based upon the normal work day - which for us is 7.5. I believe that this section of the law needs to be modified or changed entirely.
Agency: DCA
Comment:
Most colleges and Univerisities use a time and attendance system (Ellucian Banner system) that can only accrue sick and vacation on a per pay or monthly basis. Requiring accrual to be tracked based on hours worked will result in additional expense and labor for tracking of hours. Recommendation is to allow for accrual based on current system requirements and not based on hours worked. This would provide employers with flexability to administer sick leave requirements within existing systems without having to track hours worked, but rather the number of times employee is paid in the year or reports to work.
Agency: DCA

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