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good morning this is Russel Berger and I'm here with April ranch here we're going to get started in a minute or two to discuss paid sick leave what happens next good morning and welcome to the employment review today we will be covering paid sick leave and what happens next we'll where we'll be discussing the recently passed Maryland healthy Working Families Act during the course of today's webinar if you have any questions please feel free to submit them through the webinar software my name is russell berger and i am the chair of the Labor and Employment Group here at Offutt Kerman I work with clients of all sizes to craft pragmatic solutions to any obstacles that they encounter this month for literally all employers in the state of Maryland that challenge is sick and safely's my name is a Florence air I'm also an employment attorney here at Auto Kerman and I work to protect companies of all sizes by ensuring that their employment practices are compliant with ever-changing employment laws and that includes this new sick leave law that Maryland has recently given us all and that's why we're obviously here today to try to help you all figure out what needs to be done with respect to that law all right so as you all know we have this new sick leave law and business owners are going to need to deal with this relatively quickly so today we want to try to help you all by covering the requirements of that law the impact of the law on businesses with respect to the businesses existing leave policies and also strategies for adopting or revising any current policies that you might have in order to be compliant with the new law this is probably the simplest and most basic point in the entire law all employers in Maryland need to provide sick and safe leaves if you have 15 or more employees that sicker safely must be paid at the pay rate the employee normally receives if you have less than 15 employees believe can be unpaid now the law is not very detailed as to the definition of employee for purposes of calculating whether you have hit the 15 employees threshold or not but that being said I think the definition of employee is pretty broad and for example it doesn't exempt part-time employees or people that are working you know different schedules I think anybody that could be loosely considered an employee is going to count towards that 15 employee threshold at least until we have some more detailed regulations from the state that tell us otherwise in terms of what sort of leave is kind of covered under this law you will see some similarities to the Family Medical Leave Act for example employees can take leave under the new Maryland Pacific leave law to treat the employees mental or physical illness injury or condition as well as the care for the employees family member who may have a mental or physical illness injury or condition that needs to be treated so the employee could take leave for either themselves in that situation or for their family member the employee can also take the event of this law to obtain preventive medical care for either the employee or the employees family member and the employee may take use a sleeve for the purpose of maternity or paternity leave and one of the types of leave are cover that you maybe wouldn't typically think of in terms of why an employee might use sick leave is to allow the employee to be absent from work due to domestic violence sexual assault or socking against the employee or that employees family member and that leave also has in order for that employee to take a leave for that purpose the leaves needs to be used by the employees to either obtain for the employee or the employees family member medical or mental health attention treatment services from a victim services organization legal services or proceedings or leave for that employee to relocate due to the incident that the employee is experiencing so so far this morning we've talked about the general requirements as to what needs to be provided of what exactly sick and safe leave is uh and you know that might be background that you've gathered just from reading articles in the newspaper online and I know some people might be attending this webinar may be attended our partner Howard currents tell a brief that included a discussion of sick or safe leave yesterday but you know now we're going to get into a lot more of the detail of what this law is actually about and this is important because no matter what your existing policy is these details are going to have to be incorporated into an existing policy or replace an existing policy and this is really where the rubber meets the road so with respect to how much leave is required statutory provisions are written in somewhat of a backwards way where it talks about putting you know minimum caps that can be put into place but really was what we do know is that all employees can earn up to 40 hours of sick you're safe leave per year and if sicker safe leave is accrued throughout the course of the year and not just awarded at the beginning of the year it must be earned at a rate of at least one hour for every 30 hours worked and that's easy enough to track for hourly employees for exempt salaried employees the assumption is of a 40-hour work week so if you're using the minimum threshold and you had an exempt salaried employee they would be earning 1.3 3 hours of sick or safe leave per week based on the assumed 40-hour workweek now labor will be discussing the year-to-year carryover options in the next slide for right now it's important to know that if leave is accrue throughout the year which is how a lot of employers do structure their current PTO policies and not just awarded at the beginning of the year in a lump sum there is going to be a carryover requirement which is how you get to the next two bullet points on this slide would show 64 hours because you can't get the 64 hour cap without carrying over some of the 40 that could be accrued in year 1 however the bank of sicker safe leave hours can be capped at 64 hours and even though you might still be accruing to get to that 64 hour crap cap employers can also cap annual use at 64 hours some of you are sitting in questions please continue to do that we'll do the best use of them as we're going through the presentation but if we're unable to do that we will certainly try to address this at the end of the webinar our follow up with you after the webinar to answer any specific questions so please keep sending those in so that we can answer them as soon as we can so in terms of the carryover options that the law provides the law essentially allows employers to choose from two different carryover options the first option is the option that provides for a carryover which is what Russell was just speaking to so if the leave is accrued over the course of the year at that minimum rate of 1 hour for every 30 hours worked then up to 40 hours of accrued and unused time must be carried over so under that option is where you get into a circumstance to where you might hit that cap of the sixty four hours that Russell is speaking to the second option is most likely the simplest in terms of an administrative burden of tracking and keeping track of the sick leave that the employees are taking and that is that if the forty hours of sick leave are granted to the employees at the start of the year then the employer is not required to carry any unused 16 sick leave over to the following year you know another point to note about that is the law does make clear that there is no requirement that sticker safely be paid out upon termination of employment so the general rule in Maryland is that if you offer leave and you have a statement in your handbook or in your leave policy that says general leave is not going to be paid out upon termination then that's sufficient and you don't have to pay out any PTO upon termination this law does not change that at all and and whether such a either option as with most aspects of US law a really important piece of it is once you determine what is going to be a compliant policy for your particular business is to make sure that that policy is documented in a handbook or written sickly policy that's distributed to the employees and that you have a way of tracking that the employees actually receive that documentation is going to be really important here especially until we get a little bit more guidance in terms of how this law will be treated by the court the will also includes some minor limitations on when sick and safe leave can be used first leave can be prohibited for the first 106 calendar days of employment this is particularly important for seasonal workers so if you think of the shops on the boardwalk at Ocean City that might hire a college or high school kids to work for the where they wouldn't necessarily have to allow any of their employees to use sicker safely provided they didn't cross over the 106 calendar day threshold however leave would still be accruing during this time so even though an employee might not be permitted to use their sick or safe leave yet they would still be accruing or obtaining their sick or safe leave so that as soon as they cross the threshold they'd be eligible to use it also the leave even though the leave is is not permitted to be used during the first 106 calendar days if the employee were to return to work within 37 weeks the accrued leave is restored to the employee so they could earn it one summer and then be able to use it the following summer second for foreseeable absences and while that could mean a lot of things under this law the most obvious example would be planned doctor's appointments or appointments you schedule ahead of time employers can require employees to provide up to 7 days of advance notice in contrast if the leave is not foreseeable which very well may be more common under this law it's more within the typical idea of sick leave that we as employment lawyers think about employers can require notice as soon as practicable the literal word in the law is practicable I don't think that's particularly great guidance for employers and I don't think it's a very functional term but basically what that means is that as soon as is reasonable and so you would want to craft your leave policy to include that requirement so that while you know you're not going to be able to prevent an employee from taking unforeseeable leave at least you can require the employee to let you know as soon as is reasonable to do so one final point on when leave can be used is that we've can be denied if the employee fails to provide the required notice now obviously like I just mention if it's an unforeseeable absence there's not really an advanced notice requirement but for the occasions where it is a leave can be denied if the employee fails to provide that required notice and the absence will cause a disruption to the employer again the I think ultimately regulations will be issued by the DLR that will help us understand what that means but because the the term in the statute is disruption and that can mean a lot of different things to a lot of different a lot of different employers we've got a few questions about what that statutory term disruption actually means and like Russell said that's going to mean a lot of different things to a lot of different employers so if you have any specific factual questions related to your specific scenario we're happy to answer those via phone or email after the webinar but it really is just going to be you know trying to be as make a good-faith effort to be as compliant as possible and to document your efforts to do so and then once we get some regulations I think we'll have a little more guidance in terms of what that and other terms in the statute actually mean and borrowing from other employment laws where they use terms like hardship and reasonable in these all become very fact-specific and very dependent on the employer and employee and the employees role so for example in our law firm we have administrative support staff and if one administrative support person were to call out sick that would in theory be some level of disruption but that work and then be allocated across other administrative support staff so my feeling on it is that's unlikely to be the type of disruption that would satisfy this definition but again it'll ultimately be very fact-specific and hopefully we'll have some guidance on it in the near term all right so turning to what kind of verification employers can request to make sure that the employees are actually using the leave for the reason that they're requesting it for an employer can require that an employee provide verification in situations where the leave was used for two or more consecutive shifts or when the employee uses leave between days 107 and 120 of employment if that employee agreed to provide verification at the time of hire so again that piece that states that the you can request the verification if the employee agreed to provide it at the time of hire goes to the documentation and the importance of having a written policy that's compliant with this law and making sure that employees are on notice of what their requirements will be to provide these sort of verifications if an employee fails to provide verification then employers are permitted to deny future sick leave requests for that same reason so what I what this means is that if the employee is out for a knee injury and requests leave under the sick leave law to receive treatment for that knee injury and this is two or more consecutive shifts because of that injury but fails to provide documentation at the request of the employer from a medical provider of that injury then the employer can then deny that same employee's request to be out for another doctor's appointment for that same knee injury so that's how that will work in terms of the verification and the ability to deny subsequent requests for leave again the the verification requirements should be memorialized in either the handbook or the sick leave policy that's going to lay out the entire policy for your company the law this law also requires records to be kept of both the leave that has been earned and the leave that has been used in this respect I don't think this should really be a drastic change for employers they currently have some form of paid time off however I do think you should consult with your payroll providers to ensure this is properly tracked and reported on your system so for example presently I would imagine the most employers that have some form of PTO have a tracking system that's connected to their payroll this is and I think this is how sticker Safely should function as well in some instances and we will talk about this in a little bit it might just be you might just be modifying your existing leave policies not creating a brand new a bucket of leave so in any event I think it's a good idea to get with your payroll providers and ensure that you're properly tracking and recording time you have the software in the capability to do so this is also a good idea because the law requires employers to either provide a statement of sick or safe leave balance along with or as part of each pay stub or to provide an online portal where employees can access their sick or safely balance so not only if you have this tracking and record-keeping obligation you have an output an affirmative obligation as an employer to keep employees aware and up to date as to what their balance is so again I think the payroll system is a most efficient and effective way to accomplish that requirement and also it's important to note that if you do not keep accurate records the law actually has a provision that says you are presumed to have violated this law number one you're obviously violating the law because the law says keep records and you have it um but the presumption really applies to the the the question of an employee challenging uh you know the amount of leave that they have or why weren't they paid for lead that they thought they had earned if you don't have documents that you're going to be presumed to have been in violation and - oh that employee penalties and damages now as a practical matter if you came to me and said hey I'm getting sued for this what do you need to help build my defense I would ask for the documents of these records that'd be the first thing I would ask for so while it is a requirement of the law and it does carry with it the shifting presumption I also think it's important from a practical standpoint but to have this track because that's all you're going to be able to best defend yourself anyway alright so in terms of what sort of notice and information needs to be provided to the employees about this new law and the state will be providing a poster at some point in the future that will need to be posted in a similar place as to where your wage posters are so that employees can easily see that notice should also be provided and if this can be in terms of a new policy that's distributed to the employees and talked about or in a dated handbook but that notice must include how the leave is accrued whether the employer is choosing option one that we talked about earlier or option two for specific employees and the purpose for which leave is available on meaning what types what reasons the employee can use the leave for and a statement that states that the company is not permitted to retaliate against an employee for taking sick leave or for requesting sick leave and also the employees right to report a violation of this new sick leave policy again I mean like Russell and I both said several times during this webinar documentation is going to be important here so as far as the notice that is distributed to the employees we recommend that it's distributed in a way that employees employers can confirm that the employees received it and signed off on it seems unlikely to me that the DLR will be sending out investigators to review people's paid sick your safe lead policies and frankly that's not really contemplated by the law instead complaints into this low or originated with employees filing administrative complaints at which point the law provides a mechanism for the dllr to investigate and then ultimately if it finds any type of violation or potential violation to mediate and try to resolve the matter informally if informal attempts at resolving a dispute fail the DLR may then issue an order finding a violation and when it issues in order finding a violation it's going to include that order penalties certain penalties are mandatory and we'll certainly be included and that includes the full monetary value of any unpaid leave so if someone makes $20 an hour and they were shorted one day of leave according to the dllr twenty times eight hours for that one day $160 that would be part of the damage order it also includes actual economic damages so aside from the unpaid wage if there are other actual economic damages to the employee that would have to be included as well now the law the law also permits DLR to exercise some discretion and so in theory the DLR can include the penalty a penalty that's three times the value of the employees hourly wage for each violation so that one-sixty could be tripled and that can be included as well and in addition and this is probably the most significant penalty in most instances that could be included at this stage is a $1000 per employee penalty for employees that are counting the number of employees that for which the employer is not in compliance so if there is a problem with the math and it's only one employee not that big a deal if there's a problem with the system for example no no employee in the company is getting notice of their sick or safe leave balance and there's 50 employees in the company then in theory the dllr could issue a $50,000 penalty so you know that's why it's very important to be on top of the systemic the system or based functions of the law now if the employer does not comply with the order issued by the dllr then there's the potential for a civil action either brought by the Commissioner of the dllr or by the individual employee and if a civil action isn't pursued the risk to the employer goes up so obviously this is not going to be something that employers are going to want to have happen unless they feel as though there's a very strong defense and there's a strong reason to continue to challenge the dllr s finding because if an employee brings a private cause of action the damages can include three times the value of the employees on paid leave it can include punitive damages attorneys fees injunctive relief things that are not included so you get to that that stage so really if you can't tell it already I think the purpose of the penalty scheme being structure in this way is to stack the deck against employers and to really create a lot of leverage from an enforcement side on employers to force them to the bargaining table and encourage them to compromise as early in the process as possible all right so what should we do now what should employers what kind of action should they be taking the first is obviously to review the law and learn the requirements some of which we've talked about here today I'm trying to give a good overview of the basics of the law and what it requires the second is to review your current leave policies if you have them and determine whether the existing policies are in compliance with this new sick leave Law if they're not in compliance or even if you have a question of some of them out there in compliance then you need to figure out what the steps are that must be taken to make those policies become compliant to avoid any of the penalties that Russell was just speaking to so on that point I think one of the things that we've seen a lot of already in the last we can have is employers will have policies where they provide general leave up you know they don't really care what the employee takes it for and plenty of days 15 days 20 days something like that but you know they don't have the accrual of consistent with the law or they don't provide you know at least 40 hours upfront or they'll have a cruel but they won't have carry over so I think a lot of what we're seeing so far is the employers will need to make some changes or they'll be out of compliance in the more mechanical ways that in the big substantive way of how many hours are preceded or or you know do I allow employees to take leave for for these types of absences right and so in obviously those policies will need to be updated and if you don't have policies for very sick leaves and many employers don't right now we'll have to have those policies strap it and make sure that they are compliant with the current law as it is and as regulations come out and as this evolves as all employment laws do we will do our best to push out content to make sure that the members and other business owners are aware of the new regulations that may affect this law so one other thing we should touch on before we we get to all the questions here is that this is still a fluid situation the DLR has not issued its regulations yet and even once it issues draft regulations there's still a process by which they can be revised and have to be reviewed and it's going to take a couple of months before they can even be in effect anyway so that's kind of a best-case scenario um in terms of when this law is going into effect the state Constitution states that when a veto is overwritten as was the case here the law goes into effect thirty days later that would mean that this law was set to go into effect on February 11 there supposed to be a hearing this afternoon which was bumped up to yesterday regarding a bill by one of the I believe the chief sponsor of the sticker safe leave law to create some sort of breathing room and an extension my understanding of that bill is that it was going to provide for an extension as to the date that the Commissioner would begin enforcing but it wasn't going to change the actual effective date of the law and therefore it was not going to change you know when employers in theory would have to be in compliance with it I think there's you know we're talking about a political process here so there's people that want to pass through an amendment that's very narrow there's people that would like to push back on some of the substance of the law so we don't know exactly going to happen uh in fact I I know there's someone one of the senators yesterday or at least one of the witnesses during the hearings yesterday was pushing for July one effective date because most of the municipal and county governments operate on a annual budget that begins on July 1 and it would be hard to shift gears mid-year also along those lines as I mentioned it's going to take a few months for us to have regulations and we'll do our best to answer a lot of the questions we've gotten but you know not surprisingly a lot of the questions are geared on definitions and what does this mean and you know how do you resolve this ambiguity in the law and we can tell you our best guess uh and our more than a guess because you know we were interpreting and analyzing you know using our legal know-how but ultimately there could be regulations that and we would expect there would be regulations that address some of these ambiguities all right turning to some of the questions um Russell it's an important company chooses option to for the carry over for if the company chooses that to front-load ours and give the employees the 40 hours of sick leave up front at the beginning of the year so then they don't have to carry over any hours into the following year then what would they do for new hires that come on board after the start of the year so so that's enough that's exactly one of those questions and I think the regulation uh will likely provide some guidance on but here's my thought as of right now I don't think the law is entirely clear that you can prorate that so that would be the option is if someone comes on board on July 1 they would get 20 hours because they're there for exactly half the year and they wouldn't earn the first 20 hours I'm not sure that that's so clear in the law and that's necessarily permitted and given you know the relatively low risk of providing a couple extra days of paid sick leave I tend to take the conservative approach for now that being said I think this is going to be a short-lived problem because if you take the approach we take that approach now and you hire someone in March and you give them the 40 hours right up front by the time we get to June or July I would expect that we would have regulations that give us guidance on and if the regulations make clear that Pro rating is okay then we change the policy and we start prorating then if the regulations don't give us guidance we take the conservative approach to avoid the thousand dollar per employee penalties somebody had asked about the ability for the employers to require a verification that the leave was being used appropriately and the the law states that that can be done when the lead was used for more than two consecutive scheduled shifts so you can't require that verification its employees only out for two days or two consecutive shifts but once they reach that third consecutive shift that's when you can request that verification from the employee um Russell how would you recommend employers handle situations where they may have a lot of different categories of employees to where they might have part-time seasonal employees and full-time exempt employees would it be a good idea to or a bad idea for that employer to maybe apply option one to some of the employees for the carryover and option two for the other employees you see a problem with that not really so I see the issue being the the statute doesn't talk about whether you can mix or match which seems to me to be uh you know tacit permission to do so as long as you're compliant with the minimum requirements of the statute and I think for certain employees it would make sense to do things differently um and as long as you're compliant with the minimum thresholds or law the only thing that you really have to be conscious about when you start treating employees differently from one another is running into discrimination claims and generally speaking if you're classifying uh if you're providing different benefits which is what believe would be based on different job titles and job classifications you're probably going to have nothing to worry about with respect to a discrimination claim it's where you start providing certain benefits to one group of people or another where you should run into discrimination problem we just don't want to accidentally back into that when we treat employees differently we're receiving questions about what does the term family member mean and the statute has specifically defined how family member means but as an overview it's a biological child adopt a child foster child or stepchild of the employee a biological parent or adoptive parent stepparents of the employee or the employees spouse the employees spouse or employed spouse is a family member for the purposes of the statute and as is grandparents grandchildren siblings and so those are essentially what the how family member is being defined by the statute um Russell do are overtime hours required to be counted for the purposes of the accrual method yes yeah so for non-exempt employees that you would be tracking their hours the hours are earned per you know it's one hour for every thirty hours worked there's not a per week tap as so you can only earn up to one hour for every thirty hours up to a total of forty hours work it would just be based on the pure number of hours worked of course if you do the math this and you were in one hour for every 30 and you had a cap of 40 hours earned in the year that and someone's working full-time that's going to get them into like June or July so at some point you know you stopped earning more hours because you've already earned them for the year and if you worked overtime you would just get there faster and we're being asked if an employee is denied sick leave and they still take our out of the office and not working is the employer required to pay that employee anyhow and the answer to that like a lot of questions would be it depends on the situation but generally speaking as long as you have a compliant sick leave policy that's compliant with this new law and you are correctly applying that policy and the employee is then appropriately denied sick leave for whatever reason then they don't have that sick leave to take so if there's no other leaves that you have available for them to take pursuant to your policies and they're out of work you can take provided their third at-will employee disciplinary actions up to an including termination for that employee missing their scheduled work however I say it depends because depending on the situation you may be exposing yourself to some sort of discrimination claim or retaliation claim if there have been particular circumstances with respect to that employee so without knowing any of those details generally speaking as long as you're correctly applying the policy and they don't have that leave accrued and available to take then no you shouldn't have to pay them for that if they are out of out of the office and not working in violation of the policies so April there we're getting a number of questions about how sick or safely interacts with existing state federal law such as the fmi what are your thoughts on that well my thoughts are that if the existing federal FMLA applies to your business then the that you would need to have a leave policy that is compliant with both the federal law and also the Maryland law I don't see anything in the new Maryland sick leave law that would be counter to the FMLA at this time and along those lines I think it's perfectly reasonable for these to run concurrently so I don't think it's 12 weeks of FMLA leave plus one week of paid sick leave I think and I think you would want to address this in a policy to make it clear that they would run concurrently just like no other form for example short-term disability or requiring employees to take a PTO and burn off their PTO as as part of their FMLA leave I think you would want to incorporate this in much the same way well what if FMLA doesn't apply your business but you have a eally generous PTO policy and you don't require employees to specify whether they're taking that PTO for sick leave or for just vacation purposes would you still recommend that employers do the things that we've mentioned today in terms of tracking sick leave and and making sure that they're affording those employees see sick leave hours that are required yeah so there's in my opinion etic there's two schools of thought they're starting to form on this one is moderately conservative and the other is ultra conservative and so the ultra conservative approach would be let's say you've you have a policy where you have general leave use it for the employee can use it for whatever the employee would like of up to 15 days arm the ultra-conservative approach would be much not touch that let's leave it exactly how it is and let's just add in an extra five days or sick or safe leave we'll take the state's supposed to craft a model policy we'll just adopt that or something like that we'll just have the separate bucket of pay of paid sticker safely for unpaid sick receives leave that will count separate from the general PTO that we've always awarded that's ultra conservative and that requires providing the employees with an additional 40 hours a year of leave the alternative would be to take the existing policy which is the 15 days or the 120 hours worth a general leave that employees can use for whatever purposes they would like and revise that and edit that to make it compliant with the law and as I alluded to earlier that might be as simple as tinkering with a cruel or carry over arm or it might be something basic like well typically we have employees accrue their time over the course of the year and we don't have carryover and now I have to pick one of the other because the law says I have to and taking maybe minimum 40 hours as required by the law awarding that on the first day of the year and then accruing the rest over the course of the year so that you can be compliant with the law still have employees accrue most of their leave but not the minimum 40 required by the law and then not have carry over at the end of the year so some of these solutions are going to really require you the the pop the hood and look under look at the engine and figure out exactly what tweaks can be made to make this change and make your policies compliant with the law in the least disruptive way possible to your ongoing business okay um we are getting a lot of questions about whether or not we will have the PowerPoint and also the recording of this webinar available we will and we'll be happy to send that out to the attendees of today's webinar so we'll make sure that you all have that and then that way you'll also have an email from us so you can feel free to respond with any specific questions that you may have and this is an interesting question if an employee carries over forty or close to 40 hours into the following year can the company then stop the accrual until the balance falls below 664 hours again I believe they can so the way I see it working is let's presume someone earned 40 hours in year one and they didn't take any of it so on December 31st they have 40 hours that would carry over into the next year so they're starting January 1 with 40 hours in the bank and then they start to accrue and they get about three or four months into the year and they hit the 64 hour cap I think you can cap it at that point because the law says you can put a limit on the amount of hours in the bank um however if they then use a day of sick leave and they go back down to 56 for example they would then start accruing again and they could accrue up to 40 hours over the course of the year to be frank about it I think the law is poorly drafted in this respect because it talks about these caps it doesn't really talk about the interplay between them um so I'm basing that answer on the fact the law says you can have a hard seal and you have to have a policy that says this you can't just do this but assuming either the right you know written policy in place I think you can shut people down from accruing more sick leave at 64 hours total in the bank even though the law says an employee has to be permitted to accrue up to 40 hours in a year I think the limit on the hours in the bank would take precedence over the accrual requirement because otherwise the limited the bank wouldn't make any sense you wouldn't need that I I agree and I also agree that again all this would need to be in your policy so figuring out what how you want to implement this policy in a way that will be compliant with the law is important and making sure that it's clearly communicated to the employees and the supervisors and HR folks who are going to be tracking this is also equally as important so I we try to answer as many of the questions that we could that I think would apply more generally across the board and we do have some more tailored and fact-specific questions and we will follow up with those of you who we haven't been able to answer those questions individually so that we can make sure to get you those answers and like I said we will also be distributing the PowerPoint and the recording of this webinar to everyone so please feel free to follow up with us if you have any questions we know that this is a bit of a frustrating process for business owners because it's a change and it's new and it's not as clearly drafted as I think that we would all like and it's obviously creating a burden on employers that didn't exist before so we just want to make sure that we avail ourselves to all of you to make sure that we can help you through this and get everybody on track with a policy and an inflammation of it to try to make this new law be as smooth as possible for everyone and as a kind of a general takeaway for where we are right now obviously there's some more detail and nuance in the statute itself that we didn't cover today and certain industries like the restaurant industry and some extent construction and employers with CBA's our collective bargaining agreements are going to have some slight deviations from this there my or some some nuance to it but the the general point I want to make may today is that you're all doing their thing by getting up to speed and learning as much as you can about what we know about the law right now it's a fluid situation so we have to be somewhat flexible I think the right things to do right now are to understand the law understand in general terms what you might have to change and how you would go about changing it to get into compliance with the law and you know what I would have told clients thus far is that I don't know that we want to make a change and we want to change your policy today when the effective data the law could change or uh you know some of the or something more substantive can change in the law we want to be prepared we want to go right up to the doorstep of implementing a new policy but we don't necessarily want to roll it out any earlier that we have to and for those of you who dealt with the change the potential change to the salary basis test and the Fair Labor Standards Act a couple years ago no people made changes people gave employees raises to bring them into compliance with what everyone expected to be a change in the FLSA and then that change didn't happen at the very last minute so thousand you know across the country really millions of dollars of raises were awarded to bring employers and the compliance with the law that then did not come into effect so while I don't think that's going to be the case here and we are going to have sick or safe leave some of the details might change some of the effective dates might change so I think we're at a point where you know our counsel is be prepared be ready to go and but let's wait and see what happens and in you know the week or so leading up to February 11th that would be the time to roll out policies that would be the time to officially make these changes but as April said as you go through the process you are going to need to change your policies because even if you had everything compliant I still think it's going to be important that you include references to to this law and you're currently policy these and make clear that these is permitted for these requirements and you might want to incorporate some of the notice the verification requirements into your written policy so I think there's going to be work for literally all employers in the state of Maryland to do on this and as you're going through that process feel free to reach out to us if you have any questions or you need any guidance or assistance thank you all for joining us this morning and good luck to you as you try to remain there become compliant with this law thank you have a good day