"[T]he guidance does not clearly address key questions left open by the [New York Sick Leave Law (NYSLL)], including: [1] If an employer provides a lump sum of paid sick leave at the beginning of each year (also known as front-loading), whether the employer must still allow employees to carry over accrued, unused leave at the end of the year. [2] In determining the amount of sick leave the employer is required to provide, whether to count only employees within New York or employees nationwide.... [3] Whether employers can require reasonable documentation to support an employee's request to use New York Sick Leave."

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