Center for American Progress Issues Public Comment on Labor Department Notice
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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
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,
Eight states--
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
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
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
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
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
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
Within
Key features of paid family and medical leave
To ensure a paid family and medical leave program meets the needs of
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
State paid leave programs have led the way in expanding family definitions;
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
Paid leave should not require workers to borrow from their own
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
In
Just one year after implementation of
Nor do paid leave programs have negative economic impacts. In 2017, a CAP report analyzed unemployment rates in
Paid leave boosts employee morale and reduces costly turnover. In
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
In multiple studies,
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
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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
Sincerely,
Attachments:
1. The Economic Benefits of
2. Family Matters: Caregiving in America
3. Key Features of Paid Family and Medical Leave Program that Meets the Needs of Working Families
4.
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
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
16. Paid Family and Medical Leave Must Be Comprehensive to
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
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Footnotes:
1/
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3/
4/ Ibid.
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10/ Boushey, O'Leary, and Mitukiewicz, "The Economic Benefits of
11/
12/
13/
14/
15/
16/
17/
18/ Agnitra Roy Choudhury and
19/
20/
21/
22/
23/
24/
25/ Glynn, "Administering Paid Family and Medical Leave: Learning from International and Domestic Examples."
26/ Ibid.
27/
28/
29/
30/
31/
32/
33/
34/
35/
36/ Boesch, "Rhetoric vs. Reality: Not All Paid Leave Proposals Are Equal."
37/ Ibid.
38/ Ibid.
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40/
41/
42/
43/
44/
45/
46/ Ibid.
47/
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49/
50/
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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