[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-detail-146603-en":3,"doc-seo-146603-105":30,"detail-sidebar-cat-0-en-105":91},{"code":4,"msg":5,"data":6},0,"success",{"doc_id":7,"user_id":8,"nickname":9,"user_avatar":10,"doc_module":4,"category_id":11,"category_name":12,"doc_title":13,"doc_description":14,"doc_content":15,"file_id":16,"file_url":17,"file_type":18,"file_size":19,"view_count":4,"is_deleted":4,"is_public":20,"is_downloadable":20,"audit_status":20,"page_count":21,"language":22,"language_code":23,"site_id":24,"html_lang":23,"table_of_contents":25,"faqs":26,"seo_title":27,"seo_description":14,"update_tm":28,"read_time":29},146603,687207024643,"Rhys","https://ap-avatar.wpscdn.com/davatar_3d24733baf745e90a7e4bdd5f77d97b2",7,"Healthcare","Maine Hospital Association Paid Family and Medical Leave Program Comments - FMLA/MHA","Comments from the Maine Hospital Association on the Paid Family and Medical Leave Program rule, emphasizing how the drafted provisions would create unnecessary financial and operational burdens for employers. The submission argues that delayed application/approval timelines for private-plan substitution require employers to pay state taxes for an extended period. It also requests improved notice to employers regarding administrator decisions and appeals, and proposes narrowing employee job-protection protections in a specific absence-and-no-notice scenario.","June 10, 2024  \nLuke Monahan, Director  \nPaid Family and Medical Leave Program  \n50 State House Station Augusta, ME 04333-0050  \nDirector Monahan,  \nPlease accept these comments on behalf of the Maine Hospital Association.  \nThe Maine Hospital Association (MHA) represents all 36 community-governed hospitals including 33 nonprofit, general acute care hospitals, 2 private psychiatric hospitals, and 1 acute rehabilitation hospital. In addition to acute-care hospital facilities, we also represent 11 home health agencies, 18 skilled nursing facilities, 19 nursing facilities, 12 residential care facilities, and more than 300 physician practices.  \nOur members employ approximately 30,000 workers in Maine and each of our members will qualify as a large employer under the statue; as such, they are directly impacted by the law and the rule.  \nHere are our comments.  \n1. The rule as drafted needlessly harms employers who wish to provide paid FMLA benefits pursuant to a private plan.  \nSection XIII of the rule (page 16) outlines the process and criteria for employers’ to provide the paid FMLA benefit pursuant to a private plan. In fact, it appears to be the most extensive part of the draft rule.  \nSubsection A(2) bars employers from submitting applications until January 1, 2026, 18 months from now. It further artificially delays any approval until April 1, 2026.  \nThe clear effect of this delay is to obligate employers who are going to use the private option to pay into the state program for 18 months even though they are not going to use the state program.  \nAt a rate of 1% of employee wages, hospitals statewide will be paying $3 million per month in taxes into the state. Many of these hospitals will want to utilize the private option. Forcing hospitals to pay approximately $50 million into a state program they won’t use is incredibly unfair and senseless. There is no justification for the delay in reviewing applications except for the purpose of grabbing money from these employers.  \nMHA Request(s):  \n• Our first request is that you open the application process within 30 days of the adoption of this rule.  \n• Our second request is that for any employer who has submitted an application, there is no obligation to remit tax payments pending a decision. (Obviously, any employer whose application is ultimately rejected should be obligated to remit payments, including any back payments to January 1, 2025. )  \n• Our third request is that if the state can not accept applications prior to November 1, 2024, employers should be allowed to file a Letter of Intent to substitute a private plan and that upon submission of such a Letter of Intent, there is no obligation to remit payments until the application period opens. (Again, any employer whose application is ultimately rejected should be obligated to remit payments, including any back payments to January 1, 2025. )  \nMany hospitals currently utilize private plans for the state unemployment insurance program and workers compensation program. They have track records of responsible stewardship of these state benefit programs and will undoubtedly be able to do so for the paid FMLA benefit.  \nThe state is going to collect payments for 16 months prior to benefits being paid in order to allow the state to build a reserve fund. This makes sense. Employers who are intending to substitute a private plan should be given the same option. Forcing them to pay this tax denies them that opportunity.  \n2. The rule as drafted neglects to provide notice to employers of decisions by the FMLA Administrator regarding applications for benefits.  \nSection VI (H) of the rule (page 8) provides employers with notice than an employee has filed an application for benefits.  \nSection VII details the various notices provided to the applicant regarding the decision of the Administrator to approve or deny the application.  \nHowever, it provides no copies of these decision notices to the employer. It should be obvious why employe","cbCaipIktaUjoAA2","https://ap.wps.com/l/cbCaipIktaUjoAA2","pdf",223889,1,5,"English","en",105,"# General Background\n## Stakeholder Coverage and Workforce Impact\n# Key Comments and Requests\n## Private Plan Application Timing and Tax Remittance\n## Employer Notice of Administrator Decisions and Appeals\n## Narrowing Job Protections in Unique Absence Circumstances","[{\"question\":\"Why does the Maine Hospital Association object to the private plan application timing in the drafted rule?\",\"answer\":\"The rule delays employer ability to submit applications and delays approvals, effectively requiring private-plan employers to pay into the state program for months even when they will not use the state option.\"},{\"question\":\"What notice-related change does the MHA request regarding decisions on benefit applications?\",\"answer\":\"The MHA requests that employers receive copies of decision notices provided to employees, including notice of any appeal of a denial and any subsequent decision.\"},{\"question\":\"How does the MHA propose limiting employment protections for employees in certain circumstances?\",\"answer\":\"The MHA proposes amending Section XIV to remove job protection for employees absent 30 days or longer without any notice explaining the absence, where the employer has refilled the position.\"}]","Maine Hospital Association Paid Family and Medical Leave Program Comments - FMLA/MHA | PDF",1787746388,13,{"code":4,"msg":31,"data":32},"ok",{"site_id":24,"language":23,"slug":33,"title":13,"keywords":34,"description":14,"schema_data":35,"social_meta":86,"head_meta":88,"extra_data":90,"updated_unix":28},"maine-hospital-association-paid-family-and-medical-leave-program-comments-fmlamha","",{"@graph":36,"@context":85},[37,54,68],{"@type":38,"itemListElement":39},"BreadcrumbList",[40,44,48,51],{"item":41,"name":42,"@type":43,"position":20},"https://docshare.wps.com","Home","ListItem",{"item":45,"name":46,"@type":43,"position":47},"https://docshare.wps.com/document/","Document",2,{"item":49,"name":12,"@type":43,"position":50},"https://docshare.wps.com/document/healthcare/",3,{"item":52,"name":13,"@type":43,"position":53},"https://docshare.wps.com/document/maine-hospital-association-paid-family-and-medical-leave-program-comments-fmlamha/146603/",4,{"url":52,"name":13,"@type":55,"author":56,"headline":13,"publisher":58,"fileFormat":61,"inLanguage":23,"description":14,"dateModified":62,"datePublished":62,"encodingFormat":61,"isAccessibleForFree":63,"interactionStatistic":64},"DigitalDocument",{"name":9,"@type":57},"Person",{"url":41,"name":59,"@type":60},"DocShare","Organization","application/pdf","2026-08-26",true,{"@type":65,"interactionType":66,"userInteractionCount":4},"InteractionCounter",{"@type":67},"ViewAction",{"@type":69,"mainEntity":70},"FAQPage",[71,77,81],{"name":72,"@type":73,"acceptedAnswer":74},"Why does the Maine Hospital Association object to the private plan application timing in the drafted rule?","Question",{"text":75,"@type":76},"The rule delays employer ability to submit applications and delays approvals, effectively requiring private-plan employers to pay into the state program for months even when they will not use the state option.","Answer",{"name":78,"@type":73,"acceptedAnswer":79},"What notice-related change does the MHA request regarding decisions on benefit applications?",{"text":80,"@type":76},"The MHA requests that employers receive copies of decision notices provided to employees, including notice of any appeal of a denial and any subsequent decision.",{"name":82,"@type":73,"acceptedAnswer":83},"How does the MHA propose limiting employment protections for employees in certain circumstances?",{"text":84,"@type":76},"The MHA proposes amending Section XIV to remove job protection for employees absent 30 days or longer without any notice explaining the absence, where the employer has refilled the position.","https://schema.org",{"og:url":52,"og:type":87,"og:title":13,"og:site_name":59,"og:description":14},"article",{"robots":89,"canonical":52},"index,follow",{"doc_id":7,"site_id":24},{"code":4,"msg":5,"data":92},[93,97,101,105,109,114,117,122,127,130,134],{"id":20,"doc_module":4,"doc_module_name":46,"category_name":94,"show_sort_weight":95,"slug":96},"Story & Novel",90,"story-novel",{"id":47,"doc_module":4,"doc_module_name":46,"category_name":98,"show_sort_weight":99,"slug":100},"Literature",80,"literature",{"id":53,"doc_module":4,"doc_module_name":46,"category_name":102,"show_sort_weight":103,"slug":104},"Exam",70,"exam",{"id":21,"doc_module":4,"doc_module_name":46,"category_name":106,"show_sort_weight":107,"slug":108},"Comic",60,"comic",{"id":110,"doc_module":4,"doc_module_name":46,"category_name":111,"show_sort_weight":112,"slug":113},6,"Technology",50,"technology",{"id":11,"doc_module":4,"doc_module_name":46,"category_name":12,"show_sort_weight":115,"slug":116},40,"healthcare",{"id":118,"doc_module":4,"doc_module_name":46,"category_name":119,"show_sort_weight":120,"slug":121},8,"Research & Report",30,"research-report",{"id":123,"doc_module":4,"doc_module_name":46,"category_name":124,"show_sort_weight":125,"slug":126},9,"Religion & Spirituality",20,"religion-spirituality",{"id":125,"doc_module":4,"doc_module_name":46,"category_name":128,"show_sort_weight":125,"slug":129},"World Cup","world-cup",{"id":131,"doc_module":4,"doc_module_name":46,"category_name":132,"show_sort_weight":131,"slug":133},10,"Lifestyle","lifestyle",{"id":135,"doc_module":4,"doc_module_name":46,"category_name":136,"show_sort_weight":21,"slug":137},19,"General","general"]