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Revised DOL Regs Necessitate Job-Specific Assessment by Health Care Providers for Potential FFCRA Leave Entitlement
Nexsen Pruet 
[Guidance Overview] Sept. 22, 2020 "[A]ffected health care providers should immediately conduct a position-specific analysis of their employees ... to make a reasoned determination regarding whether their services are truly integral to the provision of patient care. Gray areas will likely include patient food service and EMR-related services.... Employers should take care to document their decision-making process in this regard before denying leave requests to such employees." |
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