Excerpt: It is anticipated that regulations will be issued to provide guidance on the new requirements (e.g., on calculating the average number of employees, the average number of hours worked, etc.). Clarification will also be needed on how the 'look back' determination is administered in connection with the initial implementation of the law. For example, will January 19 be the date counting hours must commence in order to determine which persons are 'covered employees' entitled to benefits on February 1 – or, will December be the 'look back' month for counting hours in order to determine which persons are 'covered employees' entitled to benefits no later than January 19?

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