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Draft Regs Issued for Massachusetts Paid Family and Medical Leave Law; Questions Remain
Constangy, Brooks, Smith & Prophete, LLP Link to more items from this source
[Guidance Overview]
Feb. 13, 2019
"[T]he draft regulations omit any meaningful explanation of the interactions between employers' existing paid leave policies and the receipt of benefits under the law. The draft regulations are also silent about how private plans should operate. For example, is the employer allowed to make employee wage deductions at the rates promulgated by the Department? Are employers allowed to invest the funds, as in an ERISA-governed retirement plan? What if there is a shortfall in the employer's private leave benefit fund? What if there is a windfall?"

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