FMLA
Page Contents
- Federal
- Summary
- The Family and Medical Leave Act
- FMLA Definitions, Generally
- FMLA Definitions, Specific to Military Family Leave
- Preparing for FMLA Requests
- General Notice Posting Requirements
- Content of Notice
- Language Requirements
- Distribution and Location of General Notice
- How Often Notice Must Be Provided
- Penalties for Noncompliance
- Creating an FMLA Policy and/or Other Written Guidance
- Required Employee Notice
- Separate FMLA Policy
- Moonlighting Policies
- Inflexible Leave Policies
- FMLA Employer Coverage
- Covered Employers
- Private Employers
- Engagement in Commerce
- Number of Employees - Who Should Be Counted
- Number of Employees - Calculating Number of Calendar Workweeks
- Location of Employees
- Public Agency Employers
- Schools
- Persons Acting in Interest of Covered Employer
- Joint Employer, Integrated Employer and Successor Employer Coverage Issues
- Joint Employers
- Integrated Employers
- Successor Employers
- Receiving and Reviewing Employee Requests for FMLA Leave
- Employee Notice of Need for FMLA Leave
- What Constitutes an Employee's Notice of Need for FMLA Leave
- Employee's Duty to Cooperate
- Timing of Employee's Notice of Need for FMLA Leave
- Notice of Foreseeable FMLA Leave
- Notice of Unforeseeable FMLA Leave
- Consequences of Failure to Provide Timely Notice of Need for FMLA Leave
- Special Notice Situations of Need for FMLA Leave
- Military Leaves
- Intermittent Leave or Reduced Schedule Leave
- Determining Employee Eligibility for FMLA Leave
- First Prong: Twelve Months of Service
- Second Prong: 1,250 Hours of Service
- Hours Eligibility Rules for Flight Crews and Flight Attendants
- Third Prong: Fifty Employees Within 75 Miles
- What Constitutes a Worksite?
- How to Measure Seventy-Five Miles
- Who Is Counted for the 50 Employee Threshold?
- Qualifying Reasons for Leave
- Employee's Own Serious Health Condition
- What Qualifies As a Serious Health Condition?
- Inpatient Care
- Continuing Treatment
- FMLA Covers Broader Conditions Than ADA
- What Is Excluded From the Definition of Serious Health Condition?
- Medical Certifications in Connection With a Serious Health Condition
- Serious Health Conditions - Special Considerations
- Serious Health Condition of the Employee's Son, Daughter, Spouse or Parent
- Which Situations Qualify?
- What Family Members Are Included
- DOL's Broader Interpretation of In Loco Parentis
- What Family Members Are Excluded
- Care Due to the Birth of the Employee's Child
- Placement of a Child for Adoption or Foster Care With the Employee
- Military Exigency Leave
- Who Can Take Military Exigency Leave?
- Who Is a Military Member?
- Circumstances Where Military Exigency Leave May Be Taken
- Certification Requirements for Military Exigency Leave
- Verification of Military Exigency Leave Requests
- Military Caregiver Leave
- Who Is a Covered Servicemember?
- Who Can Take Military Caregiver Leave?
- Circumstances Where Military Caregiver Leave Can Be Taken
- Certification Requirements for Military Caregiver Leave
- FMLA's Military Leaves - Distinction from USERRA
- Requesting Certification of the Need for Leave
- Required Notice of Certification Requirement
- Time for Employee to Provide Certification
- Content of Certification of the Employee's Serious Health Condition or the Serious Health Condition of an Employee's Family Member
- Health Care Providers Who May Prepare a Certification of an Employee's or Employee's Family Member's Serious Health Condition
- Content of Certification of Leave to Care for a Covered Servicemember With a Serious Injury or Illness.
- Health Care Providers Who May Prepare a Certification for the Serious Injury or Illness of a Covered Servicemember
- Invitational Travel Orders and Invitational Travel Authorizations
- Content of Certification of Military Exigency Leave
- Other Forms of Certification
- Recertification
- New Certifications
- Fitness-for-Duty Certifications
- Types of Certification Forms
- The DOL's Forms
- Employer Challenges to Certifications
- No Certification Returned
- Untimely Return of Certification
- Foreseeable Leave
- Unforeseeable Leave
- Incomplete or Insufficient Certification
- Notice of Why Incomplete/What Is Missing
- Written Notice
- Incomplete and Insufficient - Defined
- Time to Cure
- Failure to Cure
- Authentication/Clarification of Certification
- Authentication - Defined
- Clarification - Defined
- Contact With Health Care Provider to Authenticate or Clarify
- Failure to Authorize Authentication or Clarification
- Validity of Certification
- Process for Seeking Second and Third Opinions
- Selection of Health Care Provider for Second/Third Opinions
- Third Opinion Is Binding
- Provisional FMLA Benefits
- Second or Third Opinion Exclusions
- When Employee Fails to Cooperate With Process
- Role of Social Media
- New Certifications and Medical Recertification During FMLA Leave
- How Often Can Employer Request Recertification
- Exceptions to the General Timing Rule
- Time Frame for Employee to Provide Recertification
- Failure to Provide a Recertification
- Who Pays for Recertification
- Second and Third Opinions on Recertification
- What to Provide a Health Care Provider When Seeking Recertification
- Exclusions for Recertification of Military Leaves
- Communicating With Health Care Provider
- Employee Written Consent and What It Must Include
- Who Can Contact the Health Care Provider?
- What Can Be Discussed With the Health Care Provider?
- What to Provide a Health Care Provider?
- GINA's Safe Harbor Statement
- Maintaining Certifications
- Designating, Calculating and Tracking Leave Requests
- Eligibility Notice to Employee
- Content of Eligibility Notice
- Optional DOL Form (WH-381, Part A)
- Method of Delivering Eligibility Notice
- Language Requirements for Eligibility Notice
- Timing of Eligibility Notice (5 Business Day Rule)
- Change in Eligibility Status
- Recordkeeping Requirements Relating to Eligibility Notices
- Rights and Responsibilities Notice
- Content of Rights and Responsibilities Notice
- Optional DOL Form (WH-381, Part B)
- Method of Delivering Rights and Responsibilities Notice
- Language Requirements for Rights and Responsibilities Notice
- Timing of Rights and Responsibilities Notice
- Notice of Changes to Information in Rights and Responsibilities Notice
- Obligation to Respond to Employee's Questions
- Inclusion of Other Documents With Rights and Responsibilities Notice
- Recordkeeping Requirements Relating to Rights and Responsibilities Notices
- Employer Notices Relating to Key Employee Status
- Initial Notice to Key Employee
- Notice of Determination of Substantial and Grievous Economic Injury
- Method and Timing of Initial Key Employee Notice Regarding Reinstatement
- Method and Timing of Final Key Employee Notice Regarding Reinstatement
- Responding to Key Employee's Request for Reinstatement
- Designation Notice
- Employer's Designation Decision
- Content of Designation Notice
- Optional DOL Form (WH-382)
- Special Circumstances - Unscheduled Intermittent Leave Designations
- Special Circumstances - Designations for Care of a Covered Servicemember Leave
- Method of Delivering Designation Notice
- Timing of Designation Notice
- Changes in Designation Status
- Disputed Designations
- Recordkeeping Requirements Relating to Designation Notices
- Failure to Designate FMLA Leave
- Permissible Retroactive Designations
- Impermissible Retroactive Designations
- Consequences of Employer's Failure to Provide Proper Notices
- Calculating and Tracking Leave
- Calculating the Leave Year
- Measuring the 12-Month Period
- Calendar Year Method
- Other Fixed Year Method
- Rolling Forward Method
- Rolling Backward Method
- Required Uniformity of Leave Year Method
- Employer Notice Requirements Regarding Leave Year Method
- Designating or Changing Leave Year Method
- FMLA Leave to Care for a Covered Servicemember - Single 12-Month Period
- Calculating the Single 12-Month Period
- Per Service Member, Per Injury or Illness
- Determining Leave Entitlement
- FMLA Leave Generally - 12 Workweeks
- Exception to 12 Workweeks of Leave - Spouses Working for Same Covered Employer
- Exception to 12 workweeks of Leave - Airline Flight Crew Employees
- Exception to 12 workweeks of Leave - State Law Requirements
- Leave to Care for a Covered Servicemember - 26 Workweeks
- Exception to 26 Workweeks of Leave - Spouses Working for Same Covered Employer
- Exception to 26 Workweeks of Leave - Airline Flight Crew Employees
- Combination of Leave to Care for a Covered Servicemember and Other FMLA Leaves
- Stacking of FMLA Leave Time
- Holidays and Temporary Cessations of Business
- Administering and Processing Intermittent and Reduced Schedule Leave Requests
- Intermittent Leave and Reduced Schedule Leave - Defined
- Employee Notice of Intermittent or Reduced Schedule Leave
- Notice of Foreseeable Intermittent or Reduced Schedule Leave
- Notice of Unforeseeable Intermittent or Reduced Schedule Leave
- Required Intermittent and Reduced Schedule Leave
- Optional Intermittent and Reduced Schedule Leave
- Child Bonding
- Certification for Intermittent or Reduced Schedule Leave
- Recertification of Intermittent or Reduced Schedule Leave
- Designating Intermittent or Reduced Schedule Leave
- Increments of Intermittent Leave
- The Minimum Increment Rule and Test
- Special Rule for Airline Flight Employees
- The Physical Impossibility Exception
- Tracking Intermittent and Reduced Schedule Leave
- Special Rules for Elementary and Secondary Schools
- Fair Labor Standards Act (FLSA) - Considerations for Intermittent Leave
- Overtime
- Pay Docking for Intermittent Leave
- Fluctuating Workweek Method for Paying Overtime
- Holidays and Temporary Cessations of Business
- Temporary Transfer of an Employee on Intermittent or Reduced Schedule Leave
- Returning from Intermittent Leave
- Challenges of Intermittent or Reduced Schedule Leave
- Methods to Prevent Abuse
- Employer Obligations When Employee Is Out on Leave
- Maintenance of Employee Health Benefits
- Group Health Plans
- Maintenance of Coverage
- Payment of Health Care Premiums While on FMLA Leave
- Payment Options
- Notice Requirements Regarding Payment of Health Care Premiums
- Failure to Pay Health Plan Premiums
- Failure to Return from Leave - Effects on Health Care Coverage
- Costs of COBRA
- Recovering Premiums
- Changes in Employer's Health Plans or Benefits
- Termination of Health Care Coverage
- Maintenance of Multi-Employer Health Plan Benefits
- Non-Health Benefits During FMLA Leave
- Equivalent Leave Status
- Payment of Costs to Maintain Non-Health Benefits While on FMLA Leave
- Changes in Non-Health Benefits During FMLA Leave
- Pension/Retirement Benefits
- Seniority Benefits/Promotion
- Holiday Pay
- Vacation/Sick Day Accruals
- Continuation of Life Insurance, Disability Insurance, AD&D and Similar Insurance
- Effect on Exercising and Vesting Stock Options
- Bonus Programs
- Compensation While on FMLA Leave
- Required Substitution of Paid Time Off Benefits
- Option to Use Paid Time Off Benefits
- Enforcing Paid Time Off Policy
- Other Paid Benefits
- Paid Disability Benefits
- Workers' Compensation Benefits
- Interplay of Other Disability Leaves and State Laws
- The Americans with Disabilities Act (ADA)
- Workers' Compensation Laws
- Treatment of Holidays and Company Closures
- Public Employers: Compensatory Time
- Pay Docking
- Deductions for Partial Days of Absence
- Public Employees
- Terminating or Taking Otherwise Negative Action Against Employees on Leave
- Considerations Prior to Taking Adverse Actions
- Employer Burden to Show Negative Action Is Not Based on Exercise of FMLA Rights
- Reinstating Employees Returning from FMLA Leave
- Adequately Preparing for Reinstatement
- Communicating with Employees While on Leave
- Employee Periodic Reporting
- Employee Notice of Intent to Return
- Return to Work or Fitness-for-Duty Certification
- Notice Requirement for Fitness for Duty Certification
- Fitness-For-Duty Certification's Relationship to Condition Causing FMLA Leave
- Fitness-For-Duty Certifications for Intermittent/Reduced Leave Schedule
- Cost of Fitness-For-Duty Certification
- No Second or Third Opinions for Fitness-For-Duty Certification
- GINA Safe Harbor Statement When Fitness-For-Duty Certification is Requested
- Consequences of Failure to Provide Fitness-For-Duty Certification
- Key Employee Notice Relating to Reinstatement
- Job Restoration Rights
- Same or Equivalent Position
- Equivalent Pay
- Pay Increases
- Shift Differentials/Overtime
- Bonuses
- Equivalent Benefits
- Changes to Benefit Plans Made During the FMLA Leave
- Re-Qualification for Benefits Prohibited
- Accrual of Benefits During FMLA Leave
- Pension/Retirement Plans - Breaks in Service and Vesting Requirements
- Equivalent Terms and Conditions of Employment
- Joint Employers
- Conditions to Qualify For Reinstatement
- Light Duty and the Right to Job Restoration
- Circumstances Affecting Restoration Rights
- Key Employee Distinctions
- Grievous Economic Harm Standard
- Notices to Key Employee
- Reasonable Opportunity to Return to Work
- RIFs/Restructuring
- FMLA Fraud
- Failure to Provide Fitness-for-Duty Certification
- Hired for Discrete Term or Project
- Documentation Pertaining to FMLA
- Leave-Related Accommodations Under the ADA and Returning Employees to Work
- Interaction With Workers' Compensation, State and/or Local Law and Collective Bargaining Agreements
- Curbing FMLA Fraud and Abuse
- What Is FMLA Fraud?
- What Is FMLA Abuse?
- Moonlighting While on FMLA Leave
- Strategies to Combat FMLA Fraud and Abuse
- Surveillance
- Effective Use of Certifications
- Periodic Updates on Status
- Strategies to Control Intermittent Leave Abuse
- Training Supervisors to Spot Fraud and Abuse
- Scheduling Foreseeable Leave
- Alternatives to Intermittent Leave
- Track Patterns of Intermittent Leave Usage
- Communicating With Health Care Provider Regarding Intermittent Leave Usage
- Enforcement of Call-In Procedures
- FMLA Interplay
- FMLA Recordkeeping Requirements
- Types of Records to Keep
- Time Period Required to Maintain Certain Records
- Method of Retention
- Maintenance of Personnel Files
- Confidentiality - Employee Privacy Concerns
- ADA
- HIPAA
- HIPAA Privacy Rules Do Not Apply to an Employer's Retention of Health Information Received in the FMLA Process
- HIPAA Privacy Rules Do Apply To the Health Care Provider Who May Be Asked to Provide Protected Health Information to the Employer During the FMLA Process
- GINA
- Confidential Files
- Who Can See the Records?
- Employer's Records Retention Policy
- Actions Prohibited By the FMLA
- Interference
- Elements of a FMLA Interference Claim
- Individual Liability
- Waiver and Release of FMLA Rights
- Enforcement Rights
- Filing a FMLA Complaint With the Secretary of Labor
- Private Lawsuit Under the FMLA
- Relief Available for Prevailing FMLA Litigants
- Monetary Relief
- Liquidated Damages and an Employer's Good Faith Defense
- Equitable Relief
- Violations of Posting Requirements
- Additional Resources
Federal
Authors: Sofija Anderson, Michelle R. Barrett, Jane Ann Himsel, Diane L. Kimberlin, Alexis C. Knapp, Casey Kurtz, Deborah D. Cannavino; Lisa Lichterman Leach, Sarah E. Moss, Judith A. Paulson, Mark T. Phillis, Barbara Rittinger Rigo, Terri M. Solomon and Susan A. P. Woodhouse, Littler Mendelson, PC
Summary
- The Family and Medical Leave Act (FMLA) became effective in 1993. The statute's stated purpose is to help employees balance their work and family responsibilities by taking reasonable unpaid leave for certain family and medical reasons, and to promote equal employment opportunity for men and women. See The Family and Medical Leave Act.
- The FMLA requires covered employers to provide 12 workweeks of leave during an applicable leave year to an eligible employee for the following reasons: the employee's inability to work due to a serious health condition; to care for an immediate family member with a serious health condition; the birth, adoption or foster care of the employee's child; and to address a military exigency arising from a family member's military duty or call to military duty. See Qualifying Reasons for Leave; Designating, Calculating and Tracking Leave Requests.
- The FMLA requires covered employers to provide 26 workweeks of leave during an applicable leave year for an eligible employee to care for a military servicemember with a serious injury or illness. See Qualifying Reasons for Leave; Designating, Calculating and Tracking Leave Requests.
- The FMLA and its regulations use many terms of art that are defined by the Department of Labor, including serious health condition, qualifying exigency, health care provider and key employee, among others. See FMLA Definitions, Generally.
- FMLA leave may be taken in a single block of consecutive days or on an intermittent or reduced-schedule basis. See Administering and Processing Intermittent and Reduced Schedule Leave Requests.
- Employers covered by the FMLA include private employers with more than 50 employees, public agencies, public school boards, and public and private elementary and secondary schools. A covered employer's managers also may be considered employers under the Act. See FMLA Employer Coverage.
- There are specific rules for how employees are to be counted for purposes of determining whether a private employer meets the 50-employee threshold. See FMLA Employer Coverage.
- There are unique rules under the FMLA for elementary and secondary schools, which affect the use of certain types of FMLA leave and employees' entitlement to be restored to an equivalent position at the end of leave. See FMLA Employer Coverage.
- An employer may be covered by the FMLA as a result of a relationship it has with another employer (or former employer). These situations include joint employer, integrated employer and successor employer relationships. See FMLA Employer Coverage.
- The FMLA imposes various notice obligations on employees, including the requirement that they provide their employer with enough information for the employer to determine that their absence may be for an FMLA-qualifying reason. Employees also have an obligation to cooperate with their employer when the employer makes reasonable inquiries aimed at determining whether or not the FMLA applies. See Receiving and Reviewing Employee Requests for FMLA Leave.
- Employees' notice obligations vary depending on the FMLA-qualifying reason for the leave and whether or not the need for leave is foreseeable or unforeseeable. If an employee's request for leave is late, the employer may be able to delay or deny the leave. See Receiving and Reviewing Employee Requests for FMLA Leave.
- An employer can impose other notice obligations on its employees, including requiring them to follow the employer's normal procedures for requesting leave and to update the employer when the employee's leave needs change. Employee notice requirements may not be more rigorous than those imposed by the FMLA, and many such notice requirements must be excused if there are extenuating circumstances. See Receiving and Reviewing Employee Requests for FMLA Leave.
- The FMLA includes a three-prong test for determining whether an employee is eligible for leave. The three prongs involve how long the employee has been employed by the employer, how many hours the employee has worked during the 12 months preceding the requested leave, and how many employees are employed at the relevant worksite. See Determining Employee Eligibility for FMLA Leave.
- When calculating an employee's length of service for purposes of determining FMLA eligibility, there are specific rules for what time may and may not be counted. See Determining Employee Eligibility for FMLA Leave.
- When calculating an employee's amount of recent service for purposes of determining FMLA eligibility, the only hours counted are those that are considered compensable under the Fair Labor Standards Act, and there are special rules relating to exempt employees and employees returning from uniformed service. See Determining Employee Eligibility for FMLA Leave.
State Requirements
The following states have additional requirements for this topic under applicable state law.
- Alabama
- Alaska
- Arizona
- Arkansas
- California
- Colorado
- Connecticut
- Delaware
- District of Columbia
- Florida
- Georgia
- Hawaii
- Idaho
- Illinois
- Indiana
- Iowa
- Kansas
- Kentucky
- Louisiana
- Maine
- Maryland
- Massachusetts
- Michigan
- Minnesota
- Mississippi
- Missouri
- Montana
- Nebraska
- Nevada
- New Hampshire
- New Jersey
- New Mexico
- New York
- North Carolina
- North Dakota
- Ohio
- Oklahoma
- Oregon
- Pennsylvania
- Rhode Island
- South Carolina
- South Dakota
- Tennessee
- Texas
- Utah
- Vermont
- Virginia
- Washington
- West Virginia
- Wisconsin
- Wyoming