Washington, D.C., November 21, 2024 – The ERISA Industry Committee (“ERIC”) this week submitted public comments on proposed regulations contained in “COMAR 09.42.01-09.42.04” (“Proposed Rules”) issued by the Maryland Department of Labor Family and Medical Leave Insurance Division (“Division”). The Proposed Rules focus on the implementation and administration of the Maryland Family and Medical Leave Insurance (FAMLI) program.
In its public comments ERIC shared alternative approaches the Division could take to improve problematic aspects of the Proposed Rules to prevent compliance burdens and to encourage employers to continue offering paid leave benefits.
“ERIC member companies across the country voluntarily offer a wide range of high quality, cost-efficient paid leave benefits for their nationwide workforces. However, as the patchwork of individual state paid leave laws and programs continue to grow, it is increasingly costly and challenging for employers to navigate the maze of multistate compliance requirements,” said Dillon Clair, Director of State Advocacy. “ERIC looks forward to working with the Division to ensure that rules governing the FAMLI program do not create unnecessary compliance complications or prevent employers from continuing to provide valuable privately-sponsored paid leave benefits.”
In its comments ERIC urged the Division to restructure and amend its Proposed Rules to:
- Provide a transparent process to explicitly notify employers about bills due for premium contributions, and permit employers to take corrective action without punitive and counterproductive penalties.
- Allow approved employer plans to maintain their status by requiring reapplication for state approval only when substantive changes are being made to the plan.
ERIC is a national advocacy organization exclusively representing the largest employers in the United States in their capacity as sponsors of employee benefit plans for their nationwide workforces. With member companies that are leaders in every economic sector, ERIC is the voice of large employer plan sponsors on federal, state, and local public policies impacting their ability to sponsor benefit plans. ERIC member companies offer benefits to tens of millions of employees and their families, located in every state and city across the country.
The full text of ERIC’s comments can be found here.