"Weeks after the Windsor decision, the few federal agencies that have issued guidance have taken wildly disparate approaches.... There is a clear need for prompt guidance, coordinated among the various agencies. Moreover, unless the guidance takes the OPM approach (treating a marriage as valid if it was recognized by the state performed, regardless of the laws of the state of residence), employers can expect to have to undertake determinations of marital status far more complex than just determining whether the employee's current state of residence permits same-sex marriage."  MORE >>