The U.S. Department of Labor announced that it issued three new opinion letters that address compliance issues related to the Fair Labor Standards Act (FLSA) the Family and Medical Leave Act (FMLA), and the Consumer Credit Protection Act (CCPA). An opinion letter is an official, written opinion by the Department’s Wage and Hour Division on how a particular law applies in specific circumstances presented by the individual or entity that requested the letter.
The opinion letters issued are:
FMLA2019-3-A: Addressing whether an employer may delay designating paid leave as FMLA leave due to a collective bargaining agreement;
FLSA2019-13: Addressing the ordinary meaning of the phrase “not less than one month” for purposes of FLSA section 7(i)’s representative period requirement; and
CCPA2019-1: Addressing whether employers’ contributions to employees’ health savings accounts are earnings under the CCPA.
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