5 Changes to the Procedures for Processing Disability Claims at the Department of Labor

On April 1, 2018, the U.S. Department of Labor (DOL) implemented new procedures for processing disability claims.  This change impacts employer-sponsored plans, which deal with disability claims.  The Society of Human Resource Management recommends amending plans as needed, with the significant change in procedure processing.  The final rule was published in the Federal Register in December of 2016 and initial implementation was scheduled for January 1, 2018.  In November 2017, the DOL delayed the rollout of the new procedure until April 1, 2018.

Federal Register: Claims Procedure for Plans Providing Disability Benefits

90 Day Delay Information

The 5 changes for disability claims:

  1. “Requires that the reason for a denied claim be provided as soon as possible and sufficiently in advance of the date that the plan’s decision on appeal is due, to give the claimant a reasonable opportunity to respond.
  2. Ensures that disability claimants receive a clear explanation for why their claim was denied, as well as information on their rights to appeal a denial and to review and respond during the course of an appeal to any new or additional evidence the plan relied on in connection with the claim.
  3. Requires that a claims adjudicator cannot be hired, promoted, terminated or compensated based on the likelihood of denying claims.”[i]
  4. The new procedures can impact disability claims under the employee benefit plan, which is covered by the Employee Retirement Income Security Act (ERISA). In some circumstances, this can impact retirement plans, as well as medical coverage and other perks.  “Nonqualified deferred compensation or supplemental retirement plans…may have different benefit terms or entitlements based on disability.”[ii]
  5. “If employers have fully insured plans, they should monitor their insurance providers to ensure that the new procedures are being followed, Mindy said. For the most part, insurers have started implementing these procedures,” and they have reason to do so, since the courts can hold them liable as plan fiduciaries for a fully insured plan, he noted.  For self-funded plans, typically managed by a third-party administrator (TPA), there’s obviously more for plan sponsors to look at” because the employer bears greater liability for noncompliance.”[iii]

The reporting and disclosure guide for employee benefit plans outlines the required steps plan sponsors and organizations need to take when communicating changes to the summary plan description or summary of material modifications.  The modifications should outline the claims procedures and distribution should take place 120 days after the end of the plan year in which the change is made or as outlined in the reporting disclosure guide.  As discussed in previous articles, we continue to see significant changes in laws and compliance requirements.  Ensure your organization is working with your plan sponsors to communicate the required information.

Reporting and Disclosure Guide for Employee Benefit Plans

 

– Matthew Burr, HR Consultant

 

 

 

[i] https://www.shrm.org/resourcesandtools/hr-topics/benefits/pages/new-disability-claims-procedures-take-effect.aspx

[ii] https://www.shrm.org/resourcesandtools/hr-topics/benefits/pages/new-disability-claims-procedures-take-effect.aspx

[iii] https://www.shrm.org/resourcesandtools/hr-topics/benefits/pages/new-disability-claims-procedures-take-effect.aspx

 

3 Thoughts on What Should and Should Not Be Included in the Personnel Files

In a March 2015 article written by the Society of Human Resource Management, the article provided guidance on separating employee files for relevancy and confidentiality.  Employee records can be separated into three types of files.  “A general personnel file, a confidential employee file and a common file.”[i]  Organizations should always consider and be aware of sensitive information (date of birth, marital status, Social Security numbers, HIPAA protected information, criminal history, court orders, financial history, etc.), that can be included in any of the three separated files.  Other considerations should include relevancy to the supervisor or management of the workforce.  “Is it related to the employee’s performance, knowledge skills, abilities or behavior?”[ii]  This should also be a determining factor, when separating information and organizing new files.  Does the supervisor or manager need access to all the information?

The Basic Personnel File (supervisor and manager relevant):

  • Recruiting information, resumes, job application and academic transcripts
  • Job descriptions (signed)
  • Job offer, promotion, rates of pay, compensation information, training records
  • Handbook and policy acknowledgements (including revised policies)
  • Recognition
  • Disciplinary information, warnings, coaching and counseling
  • Performance evaluations
  • Termination records, exit interview, closure of the file (goes without writing)

The Confidential Personnel File:

  • EEO records
  • Reference and background checks
  • Drug test results
  • Medical and insurance records
  • Child support and garnishments
  • Legal documents
  • Workers compensation and short-term disability claims
  • Investigation notes
  • Form I-9*

The Common File:

  • Form I-9 Audits
  • Form I-9’s* (my recommendation is to put active employee’s I-9’s in a binder that is accessible, confidential and locked in a cabinet, for auditing and reviews).

Regardless of the filing process(s) your organization has implemented, the information contained in any of the employee files needs to be kept confidential and locked in secure filing cabinets.  During trainings with supervisors and managers, my statement is simple, treat your employee’s information as it is your own confidential information.  The last thing we want is open personnel files on desks, doctor’s notes attached to calendars and unlocked filing cabinets.  When an employee exits the organization, I consolidate all files and information into one folder and store in a terminated employee file section, with the exit interview (if applicable).  “Maintaining records in separate files as discussed above allows managers, employees and outside auditors to see the information they need to make decisions, yet does not allow inappropriate access.”[iii]  Filing and organizing paperwork is not always fun, but it is necessary to ensure legality and confidentiality.  If you are confused on employee files and appropriate storage, seek guidance.  Electronic files and legal requirements related to electronic filing can vary by state, a thorough understanding of these laws is necessary prior to implementing an electronic filing system.  We should be proactive and take all precautions, related to employee records and record retention.

[iv]

[i] https://www.shrm.org/resourcesandtools/tools-and-samples/hr-qa/pages/includedinpersonnelfile.aspx

[ii] https://www.shrm.org/resourcesandtools/tools-and-samples/hr-qa/pages/includedinpersonnelfile.aspx

[iii] https://www.shrm.org/resourcesandtools/tools-and-samples/hr-qa/pages/includedinpersonnelfile.aspx

[iv] http://cyquesthr.com/access-personnel-files-laws-50-states/

4 Updates IRS Deadline to Supply ACA Forms to Employees

In late December 2017, the IRS announced an extension for employer’s providing Affordable Care Act forms to employee’s.  As the future of the Affordable Care Act is still undecided, employers should be proactive in distributing and communicating information to the workforce.

Below are 4 updates for the ACA:

  1. Extension: The IRS extended the date to March 2, 2018 to distribute the 2017 forms to employees.  This is a 30-day extension to the regularly scheduled date of late January 2018.
  2. Penalty: “The IRS, which announced the extension December 22 in Notice 2018-06, also said it will not impose penalties on employers that can show that they made good-faith efforts to comply with the Affordable Car Act’s (ACA’s) information reporting requirements for plan year 2017.”[1]

Notice 2018-06

Information Reporting Requirements for Plan Year 2017

  1. IRS Filing Deadline: The due dates for filing 2017 returns with the IRS is not extended.  The due dates to file information returns with the IRS remain; February 28 paper filers and April 2 electronic filers.
  2. The Future and Beyond: “Although this is the third year that the IRS has granted transition relief for reporting, the notice states significantly that the IRS does not anticipate granting transition relief for 2018 or future years,” Jost pointed out. “This statement highlights the fact that, although the individual mandate penalty is repealed as of 2019, the reporting requirements that support it, as well as the employer mandate, remain in effect.”[2]

Affordable Care Act (ACA) Tax Provisions

Form 1095-B

Form 1095-C

As leader’s, we must be proactive in approaching the Affordable Care Act’s current and future legislation.  As the individual mandate penalty is repealed, the healthcare law is still the law of the land, for now.  Continue to watch for more changes in 2018 and 2019.  The ACA is complex, seek guidance if you are unclear on a path-forward.

Below is a link to the NYS Paid Family Leave Resources:

NYS Paid Family Leave Employer Webinar

PFL Resource Page

Model Language for Employer Material

[1] https://www.shrm.org/resourcesandtools/hr-topics/benefits/pages/irs-extends-aca-form-distribution-deadline.aspx

[2] https://www.shrm.org/resourcesandtools/hr-topics/benefits/pages/irs-extends-aca-form-distribution-deadline.aspx

5 Suggestions on Work-Life Balance

Many of us have vacation and time off scheduled throughout the holiday season.  Now as we enter into the mid-point of January, we strive to continue thinking about 2018 goals and objectives.  For many, finding the balance between our professional and personal commitments is an ongoing struggle. A few weeks ago, I discussed work-life balance in a leadership development training and reinforced the importance of prioritizing the balance.

Consider these 5 thoughts on work-life balance:

  1. Keep Non-Work Commitments: This is an important piece of prioritization and self-accountability.  Continue to keep non-work commitments and take the time to enjoy the events.  It is not always easy to do so.  However, it is necessary to avoid burnout from work and not enjoying friends, family, volunteering, etc.
  2. Take Vacation Time: Vacation is a perk that most organizations offer to employees.  It is there for a reason, to ensure all of us have time off and take the necessary time to refresh and reset from the stresses of work.  As leaders, we don’t always see the value in taking vacation or time off.  Set the example for your workforce and scheduled time off and avoid working during the vacation.  If possible, leave the electronics at home or avoid answering emails.  I’m the last person to give advice on this, but shutting it down is mentally refreshing.
  3. Learn to Shut It Off: This is reflecting the advice in thought #2, shut off the electronics but also shut down the thought(s) of work.  I know this isn’t easy for any of us to do. Leave work at work and focus on having fun and relaxing while you are on vacation or taking a few days off.
  4. Use Your Calendar: We all have hectic schedules, filled with meetings and commitments. Block time on your calendar to ensure you have the necessary work-life balance.  I have found in my schedule, if it is written down or on my calendar, the more likely I will commit to the balance.  Learning to prioritize plays a major role in blocking time and committing to the balance.
  5. Mental and Physical Fitness: Stress is all around us. Ensuring we are taking care of ourselves mentally and physically is necessary.  Schedule time to go to the gym, take a walk at lunch or meditate.  I workout early in the morning, I’ve found that it’s the best way to start the day.  When I don’t workout it does have an impact on my day.  Find the formula and routine that works for best for you.  Change is hard, but necessary.

As I explained to the the leadership group I met with those weeks ago; I am the last person that should be giving advice on work-life balance.  However, I recognize the importance of work-life balance and am making the necessary changes to ensure there is a balance and time to shut it down.  Commit to making the change(s) in 2018 and make it a priority.  Goal setting is a great start.  Let’s all meet our goals in 2018-one step at a time!

5 Changes to New York City Fast-Food and Retail Scheduling Laws

On Sunday, November 26, 2017, employers in New York City were required to be compliant with the new employee-scheduling laws.  The laws impact “retail” and “fast food” employers throughout the city.  These significant changes impact; breaks between shifts, predictable hours and on-call scheduling.  These laws do not impact employers in Upstate New York, however, we should be aware of any changes impacting entire industries.

Below is a summary of the 5 legal changes to the NYC fast-food and retail industries:

  1. Voluntary paycheck deductions: This new change allows fast-food employees to designate part of their salary to a non-profit organization. Employer’s must deduct from paychecks and provide the funds to the non-profit organization.
  2. Rest between shifts: This rule establishes time between shifts and bans “clopening” shifts.  When an employee works a closing shift one night and opens the next day.  The law prohibits these consecutive shifts unless there is an 11-hour break between shifts.  However, employees can agree to clopening shifts, but must be paid $100 each time.
  3. Extra hours: Employers must now post additional hours for part-time workers before hiring new workers. The communication must be posted at the worksite and sent electronically.  “Employers would only be required to offer hours to current employees up until the point at which the employer would be required to pay overtime, or until all current employees have rejected available hours, whichever comes first.”[i]
  4. Predictable scheduling: Requires employers to provide new hires an estimate of their work schedule at the start of their employment. Employers must now communicate to their existing staff their schedules 14-days in advance.  “If employees receive schedule changes with less than 14-days of notice, they must be paid a premium between $10 and $75, depending on how little notice they receive.”[ii]
  5. On-call scheduling: Prohibits certain retail businesses from requiring workers to be on- call. The new law also states that employers cannot cancel, change or add shifts with 72-hours and they must post the schedule 72-hours in advance.  There are additional exceptions for workers covered by collective bargaining agreements.

These significant legal changes are a result of the “fight for $15” movement, that we have seen in major cities across the United States.  The fight for $15 has a goal of raising minimum wage to $15 per hour and add legal protections for many low-wage earners.  If this impacts your organization, ensure you understand your obligations as an employer under the law.  Communicate and train supervisors and managers on these changes.  These are significant changes to the work relationship and will impact many organizations throughout New York City.

[i] https://www.shrm.org/resourcesandtools/legal-and-compliance/state-and-local-updates/pages/new-scheduling-laws-for-new-york-city-fast-food-and-retail-employers.aspx?_ga=2.159635643.727342918.1511008822-1767537919.1462374782

 

[ii] https://www.shrm.org/resourcesandtools/legal-and-compliance/state-and-local-updates/pages/new-scheduling-laws-for-new-york-city-fast-food-and-retail-employers.aspx?_ga=2.159635643.727342918.1511008822-1767537919.1462374782

 

2 Updates to the 2016 Overtime Rule

As the year comes to a close, it’s important to note that on November 6, 2017 the 5th U.S. Circuit Court of Appeals granted motion to the Department of Labor (DOL), to halt litigation over the 2016 overtime rule.  This motion makes it unlikely that the 2016 overtime rule will ever take effect.  If you recall in November 2016, the minimum salary level threshold for overtime and exempt status would have been raised to $47,476 per year, impacting more that 4-million people.

Below are 2 updates from the recent ruling:

  1. No Ambiguity: “The DOL wants to preserve its right to have the 5th Circuit decide that it has the authority to set whatever salary level it ultimately selects…potentially removing a precedent that could serve as a basis for challenging the next overtime rule the department issues.”[i]
  2. New Rulemaking: When the DOL under the current administration issues a new rule, it can seek to have the current appeal dismissed and the court’s decision vacated.  The focus currently is on a new rule that incorporates a more modest increase in the salary threshold.

The rule making process is scheduled to begin in July 2018.  Remember, this is a federal law; state specific laws can vary on exempt and non-exempt status.  In New York State, we have laws that impact Executive and Administrative Classifications and overtime exemption level thresholds, based on the location throughout the state.  These rates will increase on January 1, 2018.  Remember to review state and federal guidelines, to ensure legal compliance.

NY State Administrative Exemption Rates and Questions

NY State Executive Exemption Rates and Questions

Additionally, the minimum wage rate in New York State is scheduled to increase on December 31, 2017.  This again is based on location.  In Upstate New York, the rate increases from $9.70 to $10.40/per hour.  The federal minimum wage has not been increased since 2009.

NY State Minimum Wage Rates and Information

Federal Minimum Wage Chart

If you are confused by the classifying positions and exemption changes in New York State, seek guidance and ask questions.  Classifying positions can be complex.  Do not assume when classifying positions as exempt or nonexempt.  There have been multiple court rulings lately regarding mis-classification of positions as exempt.

[i] https://www.shrm.org/resourcesandtools/legal-and-compliance/employment-law/pages/overtime-rule-stay-granted.aspx

 

7 Updates for New York State Paid Family Leave

New York State has communicated new forms that pertain to the upcoming January 1, 2018 roll-out of the Paid Family Leave, which will impact most employers throughout the state.  Below are links to the six forms that have recently been released from the state and more information on PFL tax withholding’s for employees.

Form Overview Page

  1. Employee Paid Family Leave Opt-Out: If an employee does not expect to work long enough to qualify for Paid Family Leave (a seasonal worker, for example), the employee may opt out of Paid Family Leave by completing the Waiver of Benefits Form.
  2. Bond with a Newborn, a Newly Adopted or Fostered Child: Employee is requesting Paid Family Leave to take time off to bond with a newly born, adopted or fostered child.
  3. Care for a Family Member with Serious Health Condition: Employee is requesting Paid Family Leave to take time off to care for a family member with a serious health condition.
  4. Assist Families in Connection with a Military Deployment: Employee is requesting Paid Family Leave to help relieve family pressures when someone is called to active military service abroad.
  5. Employer’s Application for Voluntary Coverage (No Employee Contribution): Employers exempt from providing mandatory Paid Family Leave may provide voluntary Paid Family Leave by completing PFL-135 (if no employee contribution is required).
  6. Employer’s Application for Voluntary Coverage (Employee Contribution Required): Employers exempt from providing mandatory Paid Family Leave may provide voluntary Paid Family Leave by completing PFL-136 (if they will be requiring an employee contribution).
  7. Tax Information: Benefits paid to employees will be taxable non-wage income that must be included in federal gross income, taxes will not automatically be withheld from benefits; employees can request tax withholding, premiums will be deducted from employees’’ after-tax wages, employers should report employee contributions on Form W-2 using Box 14 – State disability insurance taxes withheld and benefits should be reported by the State Insurance Fund on form 1099-G and by all other payers on Form 1099-MISC.

We will continue to see updates from the state on forms and potential policy changes to Paid Family Leave as the year comes to a close.  Continue to monitor for changes in policy and statewide communications.  Work with your payroll and disability providers to ensure that deductions start on or before January 1, 2018.  Be proactive in your communications with employees and ensure that policy, handbook and labor posters are up-to-date for the new year.  If you have questions regarding New York State Paid Family Leave, seek guidance on the processes and procedures.  This is a significant change at the state level, and it will impact most employers and employees in 2018.

 

4 Updates on the New York Time Off to Vote Law & NYC Pay History Inquiries Ban

As leaders, the list of laws and regulations to remember continues to grow and evolve.  As a reminder, in the State of New York, employers must post in a conspicuous place at least 10 working days prior to every election day, a notice setting forth the provisions in the NY Time off to Vote Law, for compliance with New York’s voting leave law.  These communications/notices shall be kept posted until the close of polls on election day.  A conspicuous place could be considered a break room or cafeteria.

Below are 4 summaries of the New York Time Off to Vote Law:

  1. “If a registered voter does not have sufficient time outside of his working hours, within which to vote at any election, he may, without loss of pay for up to two hours, take off so much working time as will, when added to his voting time outside his working hours, enable him to vote.
  2. If an employee has four consecutive hours either between the opening of the polls and the beginning of his working shift, or between the end of his working shift and the closing of the polls, he shall be deemed to have sufficient time outside his working hours within which to vote. If he has less than four consecutive hours he may take off so much working time as will when added to his voting time outside his working hours enable him to vote, but not more than two hours of which shall be without loss of pay, provided that he shall be allowed time off for voting only at the beginning or end of his working shift, as the employer may designate, unless otherwise mutually agreed.
  3. If the employee requires working time off to vote he shall notify his employer not more than ten nor less than two working days before the day of the election that he requires time off to vote in accordance with the provisions of this section.
  4. Not less than ten working days before every election, every employer shall post conspicuously in the place of work where it can be seen as employees come or go to their place of work, a notice setting forth the provisions of this section. Such notice shall be kept posted until the close of the polls on election day.”[i]

NY State Sample Posting: Time Off to Vote

New York Time Off to Vote Law

The New York City pay history inquiry has been banned effective October 31, 2017.  Happy Belated Halloween!  This follows a growing trend across the country, employers in NYC will no longer be allowed to ask job applicants about salary history.  If you have locations in NYC or recruit there, make the necessary changes to your recruiting process.  This includes; online applications, paper applications, interview questions, etc.  “Employers are still free to make statements about the anticipated or job applicants’ expected salary, salary range, bonus and benefits…if the job applicant makes a voluntary and unprompted disclosure of his or her salary history to the prospective employer, the employer may consider salary history in determining the prospective employee’s salary, benefits and other compensation and may verify the applicants salary history…employers are prohibited from asking job applicants about objective indicators of work productivity, such as revenue, sales, production reports, profits generated or books of business.”[ii]

Salary History Law: Frequently Asked Questions

NYC Employer Fact Sheet

[i] SHRM.org Express Request Legal Updates

[ii] https://www.shrm.org/resourcesandtools/legal-and-compliance/state-and-local-updates/pages/nyc-issues-guidance-salary-inquiry-prohibitions.aspx?_ga=2.199105455.1852699784.1509187308-1767537919.1462374782

 

5 Steps for a Successful Open Enrollment Period

During the months of October and November, employers annually conduct open enrollment sessions for employees and family members. These informational sessions, communicate upcoming benefit changes, new costs and any other relevant information that will impact the employee or employees family. The open enrollment sessions also provide an opportunity for the employee and/or significant other to ask questions regarding benefits and costs. SHRM published, “6 Simple Ways to Improve Open Enrollment,” in August 2017. Additional information or resource material, will be helpful to us as leaders and to our employees who need the information to make the best decision for themselves and their families, related to benefits.
Below are 5 steps for a successful open enrollment period:

1. Prepare, Prepare, Prepare: Generate and disseminate information prior to open enrollment meetings. This will provide employees with the opportunity to review the information prior to the open enrollment sessions. Ensure that the information is communicated through the proper organizational channels and it is easy to understand. Do not make benefit information over complex or complicated. Develop a frequently asked questions sheet that will provide assistance to employees when thinking about questions and possible solutions. We cannot cover every questions, this format will help generate thought and answers.

2. Focus on the Employees: This step encompasses step #1, in that we need to prepare information for the workforce that is relevant and timely. Knowing your employees will add value to focusing on specific tools and resources for the open enrollment process.

3. Identify Needs: “Review the results of previous years’ open enrollment efforts to make sure the process and the perks remain relevant and useful to workers.” Do you send out a survey asking for feedback from last year’s open enrollment? What are the demographics of the workforce? Do you have metrics associated with benefit usage?

4. All Available Resources: Are we utilizing all the available resources inside and outside of the organization? Is the marketing department to develop material and communications? Are we partnering with brokers, insurance carrier and vendors to provide sufficient resources during the open enrollment process? Are we communicating all information? Remember NYS Paid Family Leave. Be creative. If you were in the employee’s shoes, what resources would add value and engagement throughout the enrollment process? Don’t assume that the carrier will say no, if you never ask, you will not know the answer.

5. Spouses Involvement: Many organizations provide the opportunity for spouses and domestic partners to be involved in the open enrollment process. Meeting times might need to be changed from day to night or weekend sessions. Other options could be webinars or one-on-one meetings. Involving the spouse will generate more questions and continued engagement.

Open enrollment can be a complex and confusing process for any employee. As leadership, we need to be aware of the needs of our workforce and find proactive solutions to manage and communicate these complexities. “Benefits enrollment strategies are always evolving. What worked last year may not be relevant this year. But you can’t go wrong putting employee’s needs first.” If it was you, what questions would you have during open enrollment?

– Matthew Burr, HR Consultant

Matthew@Burrconultingllc.com

Burr Consulting, LLC

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Burr Consulting, LLC, P.O. Box 197, Spencer, New York, 14883 (607)227-4386, https://burrconsultingllc.com/ Matthew@Burrconsultingllc.com

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Personnel Records Request in New York State & Paid Family Leave Letter Correction

Occasionally, an employee will request access to their personnel file during the employment relationship or after departing from the organization.  What are our legal obligations in providing this information to current or former employees?  There is currently, “no federal law that requires private employers to provide employees access to their personnel files, but there are many state laws that do grant access.”[i]  The answer varies, based on state specific laws and regulations.  What does that mean for employers in New York State?  Currently there is no law in New York State which permits an employee to examine his or her personnel file.  There is currently an amendment in the New York State Senate to provide public and private employees the right to review personnel files, the bill is in Committee and was proposed initially 2013-2014 and is now being proposed again in 2017-2018.  However, Pennsylvania allows an employee to inspect certain information from their own personnel files maintained by an employer.  Below are websites for New York State, Pennsylvania and the Society of Human Resources Management:

NY State Worker’s Rights Frequently Asked Questions

Senate Bill S2191: NYS Right to Review Personnel File

PA Inspection of Employment Records Law

SHRM Article: Personnel Records Access Legal Obligation Federal Laws & Policies

Again, laws vary state by state.  If you are a multi-state employer, research the specific laws and regulations and be consistent with employees.  Remember to look for (.Gov) or credible website sources, when searching for current state laws and regulations.  If you are required to provide access to employees on all or certain personnel file information, ensure you have a policy in place that is fair and consistent to all employees.

Below is a correction to the draft communication letter, when communicating NYSPFL information throughout the organization.  Correction underlined as regulation has changed, from $1.65 weekly maximum contribution to $85.56 annually:

The cost of Paid Family Leave benefits is paid for by the employee via payroll deductions.  The Company will be deducting a percentage of your average weekly wages (determined by New York State) to fund Paid Family Leave benefits.  The deduction rate, which is set by New York State and is the same for everyone, is 0.126% of each employee’s weekly wage with a weekly wage cap of $1,305.92.  The maximum contribution is currently $85.56 annually.  For example, if the employee’s weekly wage amounts to $1,000.00, the maximum payroll deduction for Paid Family Leave would be $1.26 for that week.  For employees who make more than the state’s average weekly wage of $1,305.92, the Paid Family Leave deduction will be capped at $1.65 per week (0.126% of $1,305.92).  We will be designing and communicating a more detailed Paid Family Leave policy in the future to be effective in 2018.  If you have any questions please contact ____.”

 

– Matthew Burr, HR Consultant

Burr Consulting, LLC

 

[i] https://www.shrm.org/resourcesandtools/tools-and-samples/hr-qa/pages/copypersonnelfiles.aspx