Center for American Progress Issues Public Comment on Labor Department Notice

WASHINGTON, Sept. 17 -- The Center for American Progress has issued a public comment on the Department of Labor notice entitled "Request for Information: Paid Leave". The comment was written and posted on Sept. 14, 2020:

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The Center for American Progress (CAP) is writing to comment on the request for information (RFI) issued by the Women's Bureau of the U.S. Department of Labor (DOL) on July 16, 2020. As an organization dedicated to improving the lives of all Americans, through bold, progressive ideas, as well as strong leadership and concerted action, we are committed to policies that ensure workers the ability to care for themselves and their families without sacrificing their economic security.

CAP has a long history of involvement on the issue of paid leave. We originally proposed the idea for national paid family and medical leave provided through a social insurance model in our 2012 report, "Social Security Cares."/1

We have continued to push the idea of a national paid family and medical leave program through our research and advocacy because we know how critical paid leave is for the health and economic well-being of workers, families, and the economy. CAP has played a leading role in the formation and growing momentum of a national paid family and medical leave policy.

In responding to the RFI, we seek to provide DOL with compelling research and evidence on the need for national paid family and medical leave and information about key components of an effective paid leave program. In addition to CAP's research shared below, many studies have been conducted which demonstrate the effects of not having paid family and medical leave as well as the benefits of state programs that provide it. In fact, DOL itself enabled several valuable studies on paid leave program design and implementation through the innovative Paid Leave Analysis Grant Program administered by the Women's Bureau, and the Chief Evaluation Office-funded Worker Leave studies. The overwhelming weight of the research is clear: the private sector has failed to solve the paid leave crisis faced by U.S. workers, and the federal government must step in to provide publicly funded paid leave to all workers.

All workers need access to paid family and medical leave

Every worker may, at some point, need time away from work to care for or welcome a new child, deal with their own serious health condition, or provide care to a seriously ill, injured, or disabled loved one. Yet, while most workers are likely to experience one of these life events, the United States has no national guaranteed paid leave program, making it the sole outlier among advanced economies across the world to lack such a program. In 2019, only 19 percent of civilian workers had access to paid family leave through their employers, and only 40 percent had access to short-term disability insurance benefits./2

Eight states--California, New Jersey, Rhode Island, New York, Washington, Massachusetts, Connecticut, and Oregon--and the District of Columbia have passed comprehensive, statewide paid family and medical leave insurance programs. The lack of a national paid family and medical leave program creates unacceptable disparities in who has access to these employer-provided benefits, with low-wage workers, part-time workers, and workers of color among the least likely to have access.

For the millions of workers without access to paid leave, they are forced to make an impossible choice between caring for themselves or a loved one and keeping their job or their paycheck. Original analysis from CAP finds that workers lose $22.5 billion in wages each year due to the need to reduce their work hours or quit their job because they lack access to comprehensive paid family and medical leave./3

This cost of inaction is untenable for workers and their families. Women, in particular, see greater economic consequences because they perform the majority of caregiving work, losing $11.6 billion in wages from the lack of paid family and medical leave./4

This is particularly harmful for the 64.2 percent of mothers who are the primary or co-breadwinner for their families./5

Black mothers and Hispanic mothers are especially likely to be the primary or co-breadwinner for their families, at 84.4 percent and 60.3 percent respectively.

A paid family and medical leave program that ensures all workers have access to the critical benefit would advance racial, ethnic, and gender justice. Workers of color are less likely to have access to paid leave, which may be due, in part, to their over-representation in low-wage and part-time occupations, where access to paid family leave is lower./6

This contributes to disparities in access to quality health care for people of color, and compounds their job and financial insecurity./7

Women would also benefit from a paid leave program which helps them remain attached to the labor force and improve their lifetime earnings and retirement security./8

A gender-neutral paid leave program which encourages men to take paid leave may reduce gender inequality in caregiving responsibilities and may contribute to a reduction in the gender wage gap./9

Benefits of paid family and medical leave

The economic benefits of paid leave are substantial and well-researched. CAP's 2013 report on the economic benefits of paid leave/10 found that it increases labor force participation, particularly for mothers who take paid parental leave and caregivers,/11 and helps grow the economy; increases employee retention and correspondingly lowers turnover costs for employers; has limited or positive impacts on business operations; increases lifetime earnings and retirement saves for workers, especially women; and increase the uses of leave by working fathers. Additional research found that paid leave helped parents in California and Rhode Island arrange child care/12 and reduced the likelihood that new mothers fall into poverty and increased household incomes./13

The research also shows wide-ranging impacts on public health: When workers do not have the leave they need, they may defer or forego necessary medical treatment./14

Paid medical leave has been shown to help cancer patients manage their treatment and side effects./15

For infants and young children, paid leave provides time to establish a strong bond with parents during the first months of life, increases rates and duration of breastfeeding,/16 supports fathers' involvement in care,/17 improves rates of on-time vaccination,/18 reduces infant hospital admissions,/19 and reduces probabilities of having ADHD, hearing problems or recurrent ear infections./20

CAP's extensive research on maternal and infant health reinforces the benefits of paid family leave in contributing to fewer low birth weight infants, fewer infant deaths, improved mental health, longer parental lifespan, and long-term achievement for children./21

In California, implementing paid family leave was linked to an 11 percent relative decline in elderly nursing home usage./22

Administration of paid family and medical leave In order to ensure all workers have access to and can benefit from a national paid family and medical leave program, it must be publicly administered by the federal government. Current low access rates to paid leave prove that we can no longer rely on the private market or employers to voluntarily offer paid leave as the solution to our nation's paid leave crisis. Too few businesses are adopting paid leave policies and those that do often limit access to only their highest paid, white collar employees.

Additionally, using the private market to provide paid family and medical leave will likely create high costs while lowering the number of workers covered./23

Proposals to create private-market products, such as responses in March 2019 to the Vermont and New Hampshire request for information for their governors' Twin State Voluntary Leave Plan, express concerns over the feasibility of a voluntary program and quote costs comparable to payroll taxes for paid leave programs in other states./24

And, as CAP wrote in a 2015 report: A for-profit model could potentially create a scenario in which private insurers are incentivized to deny workers' claims, similar to problems faced in the health insurance industry. It is also likely that rates for a private-market product would be experience rated, with organizations employing many leave takers paying significantly higher premiums than those with few. This could create incentives for employers to discourage leave taking, lead to employment discrimination against those believed to be more likely to need leave, and be overly burdensome to some types of employers, which would replicate some of the same problems as self-financing leave./25

There are many alternative models that the United States can learn from when creating a paid family and medical program. The same 2015 CAP report analyzed the administration of international and domestic paid leave programs, finding that a social insurance model was the most common international structure./26

Within the United States, currently, eight states and the District of Columbia have enacted paid family and medical leave social insurance programs. Ultimately, however a federal paid leave program is administered and financed, the program must maintain necessary components, such as an earned benefit structure with eligibility criteria that ensures all workers are covered and entitled to the paid leave benefit./27

Key features of paid family and medical leave

To ensure a paid family and medical leave program meets the needs of U.S. workers it must have the following key features: 1) cover all workers, including gender neutral benefits; 2) be comprehensive by including parental, medical, and caregiving leaves with sufficient duration; 3) be affordable and cost effective for employees, employers, and the government; 4) be inclusive of diverse families and caregiving relationships; and 5) be available without adverse employment consequences./28

The need for these features has become even clearer during the coronavirus pandemic and as part of the lessons learned from the emergency paid leave provisions of the Families First Coronavirus Response Act (FFCRA)./29

The emergency paid leave laws are expansive in covering part-time and self-employed workers, allowing comprehensive reasons for paid sick leave, allowing caregiving for a broad definition of "individual," and including employment protections. However, the emergency paid leave laws fail to protect public health by preventing coverage of employees at large businesses and fail to provide sufficient wage replacement for caregivers and adequate duration of leave, especially for self-medical or caregiving of sick family members.

Chosen family

CAP has conducted extensive research on the need for paid leave programs to have expansive definitions of family that cover extended relatives and chosen family, which is particularly important for LGBTQ individuals and people with disabilities./30

Data from a 2017 CAP survey showed that 32 percent of people in the United States report having taken time off work to care for a friend or chosen family member with a health-related need./31

State paid leave programs have led the way in expanding family definitions; New Jersey, for example, expanded its paid leave program's definition of family in 2019 to include chosen family, or people who "have a close association with the employee which is the equivalent of a family relationship." However, not all paid leave proposals meet these key features. While the Family and Medical Insurance Leave Act or the FAMILY Act would benefit all workers,/32 other paid leave proposals fall short of meeting workers' needs, especially by limiting leave only for parents bonding with a new child. Comprehensive paid leave is critical for workers to have time away from work to recover from a serious medical condition or care for a seriously ill loved one. Analysis of the Family and Medical Leave Act (FMLA) shows that the majority of workers who take unpaid leave do so to care for their own health./33

The need for comprehensive paid leave has become especially clear during the coronavirus pandemic as workers are struggling to manage caregiving or are recovering from COVID-19./34

Additionally, parents need paid leave beyond bonding with a new child, as original CAP analysis found that 52 percent of FMLA leaves taken by workers in 2012 occurred when they were also caring for children at home./35

Some paid leave plans also propose fiscally irresponsible ways to fund benefits, and may harm workers' retirement savings or child tax credit or may undermine the Unemployment Insurance (UI) system./36

Paid leave should not require workers to borrow from their own Social Security retirement savings to care for themselves or their loved ones. Such proposals would risk the solvency of Social Security and are essentially a loan which workers would have to pay back through reduced or delayed retirement benefits later in life./37

Similarly, a proposal to allow workers to advance funds from their child tax credit in exchange for cuts over the next 10 years is more accurately described as a loan, especially as it does not guarantee workers any time away from work./38

Another proposal to fund paid leave through state UI programs ignores the challenges and funding shortages in state UI programs, especially during the coronavirus pandemic, and risks destabilizing the entire UI system./39

Paid family and medical leave is good for business

Studies of state paid leave programs also show that employers have adapted well to the programs and that the negative effects businesses feared did not materialize./40

A study of California's paid leave program found that the vast majority of California employers reported a positive or neutral effect on employee productivity, profitability, and performance./41

In New Jersey, the majority of both small and large businesses say they have adjusted easily./42

Just one year after implementation of New York's paid family leave program, 97 percent of employers were in compliance with the new law./43

Nor do paid leave programs have negative economic impacts. In 2017, a CAP report analyzed unemployment rates in California, New Jersey, and Rhode Island before they implemented their paid leave programs compared to one year later and did not find an increase in unemployment rates./44

Paid leave boosts employee morale and reduces costly turnover. In California, virtually all employers (99 percent) report that the state's program had positive or neutral effects on employee morale, and 87 percent say that the state program had not increased costs./45

Sixty percent report coordinating their benefits with the state's paid family leave insurance system - which likely results in ongoing cost savings./46

Firm-level analysis of employers in California before and after paid family leave was implemented confirmed that for the average firm, wage costs had not increased and turnover rates had decreased./47

In multiple studies, New Jersey employers have noted that the state's paid leave program is beneficial for employees and manageable for employers./48

Small businesses support the creation of paid family and medical insurance programs at the state and federals levels, as these programs make the benefit affordable, reduce business costs, increase their competitiveness, and can allow small business owners themselves to take paid leave when the need arises./49

A 2017 poll, commissioned by CAP and Small Business Majority, found that 70 percent of small business owners support a national paid family and medical leave insurance program./50

A New Jersey survey found that, regardless of size, New Jersey businesses say they have had little trouble adjusting to the state's law./51

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The evidence is overwhelming: Paid leave is a win-win for workers and businesses, and the most equitable, sustainable model for paid leave is a national, publicly run social insurance program that builds on the innovation that states have pioneered.

We appreciate the opportunity to submit this comment and the attachments listed below. If you have any questions, please contact Shilpa Phadke at [email protected].

Sincerely,

Center for American Progress

Attachments:

1. The Economic Benefits of Family and Medical Leave Insurance

2. Family Matters: Caregiving in America

3. Key Features of Paid Family and Medical Leave Program that Meets the Needs of Working Families

4. State Paid Leave Administration

5. Administering Paid Family and Medical Leave: Learning from International and Domestic Examples

6. The Cost of Work-Family Policy Inaction: Quantifying the Costs Families Currently Face as a Result of Lacking U.S. Work-Family Policies

7. The Missing Conversation about Work and Family: Unique Challenges Facing Women of Color

8. Paid Leave Is Good for Small Business

9. Paid Leave 101: Demystifying Paid Sick Days, Paid Family and Medical leave, and Unsatisfactory Alternatives

10. Making Paid Leave Work for Every Family

11. Paid Sick Days and Paid Family and Medical Leave Are Not Job Killers

12. New Polling Shows that Small Businesses Strongly Support Paid Family and Medical Leave

13. People Need Paid Leave Policies That Cover Chosen Family

14. Veterans and Military Families Need Comprehensive Paid Leave Solutions

15. Breadwinning Mothers Continue To Be the U.S. Norm

16. Paid Family and Medical Leave Must Be Comprehensive to Help Workers and Their Children

17. Rhetoric vs. Reality: Not All Paid Leave Proposals Are Equal

18. The Rising Cost of Inaction on Work-Family Policies

19. The Urgent Case for Permanent Paid Leave: Lessons Learned From the COVID-19 Response

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Footnotes:

1/ Ann O'Leary, Matt Chayt, and Eve Weissman, "Social Security Cares: Why America Is Ready for Paid Family and Medical Leave" (Washington: Center for American Progress, 2012), available at https://www.americanprogress.org/issues/economy/reports/2012/09/27/39331/social-security-cares/.

2/ U.S. Bureau of Labor Statistics, "Employee Benefits Survey: Table 31. Leave benefits: Access, civilian workers, March 2019," available at https://www.bls.gov/ncs/ebs/benefits/2019/ownership/civilian/table31a.pdf (last accessed September 2020); U.S. Bureau of Labor Statistics, "Employee Benefits Survey: Table 16. Leave benefits: Insurance benefits: Access, participation, and take-up rates, civilian workers, March 2019," available at https://www.bls.gov/ncs/ebs/benefits/2019/ownership/civilian/table16a.pdf (last accessed September 2020).

3/ Sarah Jane Glynn, "The Rising Cost of Inaction on Work-Family Policies," Center for American Progress, January 21, 2020, available at https://www.americanprogress.org/issues/women/news/2020/01/21/479555/rising-cost-inaction-work-family-policies/.

4/ Ibid.

5/ Sarah Jane Glynn, "Breadwinning Mothers Continue To Be the U.S. Norm" (Washington: Center for American Progress, 2019), available at https://www.americanprogress.org/issues/women/reports/2019/05/10/469739/breadwinning-mothers-continue-u-s-norm/.

6/ Jocelyn Frye, "The Missing Conversation About Work and Family: Unique Challenges Facing Women of Color" (Washington: Center for American Progress, 2016), available at https://www.americanprogress.org/issues/women/reports/2016/10/03/145208/the-missing-conversation-about-work-and-family/.

7/ National Partnership for Women and Families, "Paid Family and Medical Leave: A Racial Justice Issue - and Opportunity" (Washington: 2018), available at https://www.nationalpartnership.org/our-work/resources/economic-justice/paid-leave/paid-family-and-medical-leave-racial-justice-issue-and-opportunity.pdf.

8/ Heather Boushey, Ann O'Leary, and Alexandra Mitukiewicz, "The Economic Benefits of Family and Medical Leave Insurance" (Washington: Center for American Progress, 2013), available at https://www.americanprogress.org/issues/economy/reports/2013/12/12/81036/the-economic-benefits-of-family-and-medical-leave-insurance/.

9/ Diana Boesch, "Rhetoric vs. Reality: Not All Paid Leave Proposals Are Equal" (Washington: Center for American Progress, 2019), available at https://www.americanprogress.org/issues/women/reports/2019/10/10/475625/rhetoric-vs-reality-not-paid-leave-proposals-equal/.

10/ Boushey, O'Leary, and Mitukiewicz, "The Economic Benefits of Family and Medical Leave Insurance."

11/ Joelle Saad-Lessler and Kate Bahn, "The Importance of Paid Leave for Caregivers: Labor Force Participation Effects of California's Comprehensive Paid Family and Medical Leave" (Washington: Center for American Progress, 2017), available at https://www.americanprogress.org/issues/women/reports/2017/09/27/439684/importance-paid-leave-caregivers/.

12/ Eileen Appelbaum and Ruth Milkman, Unfinished Business: Paid Family Leave in California and the Future of U.S. Work-Family Policy (Ithaca, NY: Cornell University Press, 2013); Barbara E. Silver, Helen Mederer, and Emilija Djurdjevic, "Launching the Rhode Island Temporary Caregiver Insurance Program (TCI): Employee Experiences Once Year Later" (Kingston, RI: The University of Rhode Island and Rhode Island Department of Labor and Training, 2016), available at https://docplayer.net/19555786-Launching-the-rhode-island-temporary-caregiver-insurance-program-tci-employee-experiences-one-year-later.html.

13/ Alexandra Boyle Stanczyk, "Does Paid Family Leave Improve Household Economic Security Following a Birth? Evidence from California," Social Service Review 93 (2): 262-304, available at https://www.journals.uchicago.edu/doi/abs/10.1086/703138?mobileUi=0&.

14/ Abt Associates Inc., "Family and Medical Leave in 2012: Technical Report" (2014), available at https://www.dol.gov/asp/evaluation/fmla/FMLA-2012-Technical-Report.pdf.

15/ Elizabeth Harrington and Bill McInturff, "Key Findings -- National Surveys of Cancer Patients, Survivors, and Caregivers," American Cancer Society Cancer Action Network, December 8, 2017, available at https://www.acscan.org/sites/default/files/ACS%20CAN%20Paid%20Leave%20Surveys%20Key%20Findings%20Press%20Memo%20FINAL.pdf. The results of this survey strongly suggest that other workers with chronic or serious illnesses will have better access to treatment and care when they are able to take paid time off from work.

16/ Rita Hamad, Sepideh Modrek, and Justin S. White, "Paid Family Leave Effects on Breastfeeding: A Quasi-Experimental Study of US Policies," American Journal of Public Health 109 (1):164-166, available at https://ajph.aphapublications.org/doi/10.2105/AJPH.2018.304693.

17/ Michael E. Lamb, The Role of the Father in Child Development, 4th ed (Hoboken, NJ: John Wiley & Sons, Inc., 2004), pp. 1-18, 309-313; Kristin Smith, "After the Great Recession, More Married Fathers Providing Child Care," University of New Hampshire Carsey School of Public Policy, Winter 2015, available at https://scholars.unh.edu/cgi/viewcontent.cgi?article=1233&context=carsey.

18/ Agnitra Roy Choudhury and Solomon W. Polachek, "The Impact of Paid Family Leave on the Timing of Infant Vaccination" (Bonn, Germany: I. Z. A. Institute of Labor Economics, 2019), available at http://ftp.iza.org/dp12483.pdf.

19/ Ariel Marek Pihl and Gaetano Basso, "Did California Paid Family Leave Impact Infant Health?" Journal of Policy Analysis and Management 38 (1) (2018): 155-180, available at https://onlinelibrary.wiley.com/doi/full/10.1002/pam.22101#:~:text=The%20impact%20of%20PFL%20on,preventative%20care%20for%20their%20child.

20/ Shirlee Lichtman-Sadot and Neryvia Pillay Bell, "Child Health in Elementary School Following California's Paid Family Leave Program," Journal of Policy Analysis and Management, 36 (4) (2017): 790-827, available at https://onlinelibrary.wiley.com/doi/abs/10.1002/pam.22012.

21/ Jamila Taylor and others, "Eliminating Racial Disparities in Maternal and Infant Mortality: A Comprehensive Policy Blueprint" (Washington: Center for American Progress, 2019) available at https://www.americanprogress.org/issues/women/reports/2019/05/02/469186/eliminating-racial-disparities-maternal-infant-mortality/.

22/ Kanika Arora and Douglas A. Wolf, "Does Paid Family Leave Reduce Nursing Home Use? The California Experience," Journal of Policy Analysis and Management 37 (1) (2017): 38-62, available at https://onlinelibrary.wiley.com/doi/full/10.1002/pam.22038.

23/ Sarah Jane Glynn, "Administering Paid Family and Medical Leave: Learning from International and Domestic Examples" (Washington: Center for American Progress, 2015), available at https://www.americanprogress.org/issues/economy/reports/2015/11/19/125769/administering-paid-family-and-medical-leave/.

24/ Vasu Reddy, "Why the governor should support real paid leave: SB 1 is a commonsense, sustainable solution; Sununu's is not," NH Business Review, April 24, 2019, available at https://www.nhbr.com/the-governor-should-support-real-paid-leave/; Sara Persechino, "Senate Majority Leader Responds to Governor Sununu Blocking Paid Leave in NH," New Hampshire Senate Democratic Caucus, Press Release, May 9, 2019, available at https://www.nhsenatedemocrats.org/single-post/2019/05/13/Senate-Majority-Leader-Responds-to-Governor-Sununu-Blocking-Paid-Leave-in-NH.

25/ Glynn, "Administering Paid Family and Medical Leave: Learning from International and Domestic Examples."

26/ Ibid.

27/ Sarah Jane Glynn, "State Paid Leave Administration" (Washington: Center for American Progress, 2015), available at https://www.americanprogress.org/issues/economy/reports/2015/09/30/122354/state-paid-leave-administration/.

28/ Center for American Progress and the National Partnership for Women & Families, "Key Features of a Paid Family and Medical Leave Program that Meets the Needs of Working Families" (Washington: 2014), available at https://www.americanprogress.org/issues/economy/reports/2014/12/01/102244/key-features-of-a-paid-family-and-medical-leave-program-that-meets-the-needs-of-working-families/.

29/ Diana Boesch, "The Urgent Case for Permanent Paid Leave: Lessons Learned From the COVID-19 Response" (Washington: Center for American Progress, 2020), available at https://www.americanprogress.org/issues/women/reports/2020/09/01/489914/urgent-case-permanent-paid-leave/.

30/ Moira Bowman and others, "Making Paid Leave Work for Every Family" (Washington: Center for American Progress, Family Values @ Work, Forward Together, and A Better Balance, 2016), available at https://www.americanprogress.org/issues/lgbtq-rights/reports/2016/12/01/292886/making-paid-leave-work-for-every-family/.

31/ Katherine Gallagher Robbins and others, "People Need Paid Leave Policies That Cover Chosen Family" (Washington: Center for American Progress, 2017), available at https://www.americanprogress.org/issues/poverty/reports/2017/10/30/441392/people-need-paid-leave-policies-that-cover-chosen-family/.

32/ Sarah Jane Glynn and Jane Farrell, "What the FAMILY Act Means for All Americans," Center for American Progress, December 12, 2013, available at https://www.americanprogress.org/issues/economy/news/2013/12/12/80945/what-the-family-act-means-for-all-americans/.

33/ Sunny Frothingham and Sarah Jane Glynn, "Rhetoric vs. Reality: 4 Myths About Paid Parental Leave" (Washington: Center for American Progress, 2017), available at https://www.americanprogress.org/issues/women/reports/2017/08/14/437285/rhetoric-vs-reality-4-myths-paid-parental-leave/.

34/ Diana Boesch and Katie Hamm, "Valuing Women's Caregiving During and After the Coronavirus Crisis" (Washington: Center for American Progress, 2020), available at https://www.americanprogress.org/issues/women/reports/2020/06/03/485855/valuing-womens-caregiving-coronavirus-crisis/.

35/ Diana Boesch, "Paid Family and Medical Leave Must Be Comprehensive to Help Workers and Their Children" (Washington: Center for American Progress, 2019), available at https://www.americanprogress.org/issues/women/reports/2019/07/16/472026/paid-family-medical-leave-must-comprehensive-help-workers-children/.

36/ Boesch, "Rhetoric vs. Reality: Not All Paid Leave Proposals Are Equal."

37/ Ibid.

38/ Ibid.

39/ Sunny Frothingham and Rachel West, "Trump's Paid Parental Leave Plan Won't Work for Women and Families: Expanding Parental Leave Through Unemployment Insurance Is Unworkable and Under-Inclusive" (Washington: Center for American Progress, 2017), available at https://www.americanprogress.org/issues/women/reports/2017/06/08/433895/trumps-paid-parental-leave-plan-wont-work-women-families/.

40/ Danielle Corley, "Paid Leave Is Good for Small Business," Center for American Progress, October 19, 2016, available at https://www.americanprogress.org/issues/women/reports/2016/10/19/146465/paid-leave-is-good-for-small-business/.

41/ Eileen Appelbaum and Ruth Milkman, Unfinished Business: Paid Family Leave in California and the Future of U.S. Work-Family Policy; Ann Bartel and others, "California's Paid Family Leave Law: Lessons from the First Decade" (Washington: U.S. Department of Labor, 2014), available at http://www.dol.gov/asp/evaluation/reports/PaidLeaveDeliverable.pdf.

42/ Miriam Ramirez, "The Impact of Paid Family Leave on New Jersey Businesses" (New Brunswick, NJ: New Jersey Business and Industry Association and Bloustein School of Planning and Public Policy at Rutgers University, 2012), available at https://bloustein.rutgers.edu/wp-content/uploads/2012/03/Ramirez.pdf.

43/ Office of Governor Andrew C. Cuomo, "New York State Paid Family Leave: 2018 Year in Review" (Albany, NY: 2019), available at https://www.governor.ny.gov/sites/governor.ny.gov/files/atoms/files/PFL_EOYReport_2018_FINAL.pdf.

44/ Danielle Corley, Sunny Frothingham, and Kate Bahn, "Paid Sick Days and Paid Family and Medical Leave Are Not Job Killers" (Washington: Center for American Progress, 2017), available at https://www.americanprogress.org/issues/women/reports/2017/01/05/295908/paid-sick-days-and-paid-family-and-medical-leave-are-not-job-killers/.

45/ Eileen Appelbaum and Ruth Milkman, Unfinished Business: Paid Family Leave in California and the Future of U.S. Work-Family Policy.

46/ Ibid.

47/ Kelly Bedard and Maya Rossin-Slater, "The Economic and Social Impacts of Paid Family Leave in California: Report for the California Employment Development Department" (Santa Barbara, CA: University of California at Santa Barbara, 2016), available at https://www.edd.ca.gov/disability/pdf/PFL_Economic_and_Social_Impact_Study.pdf.

48/ Sharon Lerner and Eileen Appelbaum, "Business As Usual: New Jersey Employers' Experiences with Family Leave Insurance" (Washington: Center for Economic and Policy Research, 2014), available at http://www.cepr.net/documents/nj-fli-2014-06.pdf; Jessica Mason and others, "Meeting the Promise of Paid Leave: Best Practices in State Paid Leave Implementation" (Washington: National Partnership for Women & Families, 2019), available at https://www.nationalpartnership.org/our-work/resources/economic-justice/paid-leave/meeting-the-promise-of-paid-leave.pdf.

49/ Stephen Rouzer, "New Report: Small Business Owners Support Paid Family Leave, FAMILY Act," Main Street Alliance, February 7, 2017, available at https://www.mainstreetalliance.org/small_business_owners_support_family_act; Mason, "Meeting the Promise of Paid Leave: Best Practices in State Paid Leave Implementation."

50/ Shilpa Phadke and Danielle Corley, "New Polling Shows that Small Businesses Strongly Support Paid Family and Medical Leave," Center for American Progress, March 30, 2017, available at https://www.americanprogress.org/issues/economy/news/2017/03/30/429527/new-polling-shows-small-businesses-strongly-support-paid-family-medical-leave/.

51/ Ramirez, "The Impact of Paid Family Leave on New Jersey Businesses."

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The notice can be viewed at: https://beta.regulations.gov/document/DOL-2020-0004-0001

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