Thursday, September 5, 2019

The Public Comment Period for Paid Family and Medical Leave is Open!

The Public Comment Period for paid family and medical leave has officially opened! Between now and September 25, the Colorado Department of Labor and Employment (CDLE) will collect comments from workers, business owners, organizations and community members to share with the FAMLI Taskforce to help inform their decision about the best paid leave program for the state of Colorado. (Please see the official CDLE announcement below). http://www.cofamli.org/

CDLE needs to hear your story about how the lack of access to paid leave, or how having paid leave has impacted your life and/or the lives of those you care about, and what you think should be done to ensure no Coloradan has to choose between taking care of themselves or a loved one in a time of need and keeping their livelihood.
Public Comment request:
1. What feedback/comments would you like to provide to the Task Force for consideration
when making its initial recommendation regarding the establishment, implementation, and administration of a paid family and medical leave program in the state of Colorado?

CDLE has created three avenues to submit comments:
  1. via the FAMLI Task Force website at famlitaskforce.com
  2. emailed directly to Admira Makas at admira.makas@state.co.us
  3. mailed to 251 E. 12th Avenue, Denver, CO 80203, Attn: Admira Makas

The deadline to submit written comments is Wednesday, September 25, 2019. All written comments will be made publicly available at famlitaskforce.com.

Official CDLE announcement:
Colorado Department of Labor and Employment Seeks Public Comments on the Administration of a Paid Family and Medical Leave Program in Colorado

As directed by Senate Bill 19-188 , the Colorado Department of Labor and Employment is assisting the newly created Family and Medical Leave Task Force (the Task Force) in studying the possible implementation of a paid family and medical leave program in the state. The Task Force is studying a program or policy that allows workers to take a specified amount of time off work for the birth or adoption of a new baby, to treat their own serious mental or physical medical illness, to care for a loved one with a serious mental or physical illness, to address certain needs arising from a family member’s active duty service, or because the worker is unable to work because the worker or a family member is the victim of abuse such as domestic violence, stalking, or sexual assault; to receive some compensation while on leave; and return to their job after leave. In studying the parameters of a paid family and medical leave program in the state, the Task
Force shall consider the following factors:
  • Affordability for the lowest wage workers;
  • Equitability across workers of all incomes and classifications;
  • Accessibility to workers least likely to have access to paid leave today;
  • Adequacy of the program;
  • The minimum duration of leave that meets evidence-based standards and wage replacement that is sufficient to allow the lowest wage workers to participate;
  • The purposes of the leave, including serious illness, caring for a loved one with a serious illness, bonding with a new child, and needs arising from military deployment and the effects of domestic violence, stalking, and sexual assault;
  • Self-employed workers’ access to paid family and medical leave and a mechanism to allow self-employed workers to participate;
  • Eligibility requirements for workers to collect paid family and medical leave insurance;
  • The definition of family or family member for whom an individual may take leave for purposes of providing care;
  • Job protection and other employment protections, including their effect on an individual’s ability to take leave;
  • Duration of leave;
  • Amount of the wage replacement;
  • Maximum weekly wage replacement amount;
  • Program funding structure;
  • The estimated degree to which an option for employers to provide their own paid family and medical leave benefits that meet the minimum statutory requirements of the state plan, may influence overall employer participation in the statewide plan;
  • Program implementation;
  • The role of third-party vendors on program sustainability;
  • The solvency of a paid family and medical leave fund under various models;
  • The portability of paid family and medical leave benefits;
  • The sustainability of a paid family and medical leave program;
  • How a paid family and medical leave program would interact with other benefits;
  • The likelihood and estimated degree to which paid family and medical leave benefits may broadly impact other existing leave benefits provided by employers (ex. vacation leave, sick leave, paid time off, etc.); and,
  • A timeline that presumes a paid family and medical leave program that is established by July 1, 2020; begins education and outreach on January 1, 2022; establishes the funding stream on January 1, 2023; and starts paying benefits on January 1, 2024.
The completed study will include a thorough analysis of paid family and medical leave programs by experts in the field, actuarial and third-party studies on the feasibility of such a program for the state of Colorado, and comments collected from the public about the administration of the program in the state. All information collected through those efforts will shape an initial recommendation by the task force on a family and medical leave program for employees in the state.