| As an employee working in the State of New Jersey, | | | | eligible employees for the birth or adoption of a child |
| no doubt you have heard co-workers, friends or | | | | and to care for the serious medical condition of a |
| family mention "family leave" or the "family medical | | | | close family member (generally a parent, spouse or |
| leave act." These phrases reference two separate | | | | child). Unlike NJFLA, the FMLA expands leave to |
| laws that benefit many people working in this State - | | | | cover an employee's own serious medical condition. A |
| the Family Medical Leave Act ("FMLA"), which is a | | | | serious medical condition is generally defined as an |
| federal law, and the New Jersey Family Leave Act | | | | illness, injury, impairment or physical or medical |
| ("NJFLA"), which you likely guessed is a state law. | | | | condition, which requires in-patient care or continuing |
| Fundamentally, these laws provide unpaid leave | | | | treatment from a health care provider. Issues |
| periods during which a qualifying employee's job as | | | | triggered by the definition of serious medical condition |
| well as certain benefits are protected. For non-military | | | | include overlap with an employee's privacy protection |
| employees, an employee may be entitled to a | | | | in his or her medical records and permissible |
| benefit of 12 weeks unpaid leave in a 12 month | | | | communications an employer may have with an |
| period under the FMLA and 12 weeks of unpaid leave | | | | employee's medical professionals. Moreover, in certain |
| in a 24 month period under the NJFLA. The concept | | | | circumstances, cosmetic or elective surgery may |
| under both laws is to place an employee in the same | | | | qualify as a serious medical condition as well as the |
| job position after family leave expires. | | | | treatment for alcohol or substance abuse as opposed |
| On the surface, these laws seem relatively | | | | to absences caused by the use of alcohol or drugs. |
| straightforward regarding the benefits provided. In | | | | Given that the leave provided for under FMLA and |
| practice, however, issues such as whether a | | | | NJFLA may cover the same event, simultaneous |
| particular employee is entitled to leave, calculation of | | | | running of leave under both acts must frequently be |
| the leave period and simultaneous running of leave | | | | determined. For example, an individual injured at work |
| periods under both FMLA and NJFLA frequently arise. | | | | whom is unable to work for 12 weeks due to his or |
| Given the not so obvious pitfalls that surround | | | | her own disability, would exhaust the 12 weeks of |
| application of these laws, employers often simply do | | | | unpaid leave under FMLA. If, on the final day of the |
| not know the law or worse, believe, incorrectly, that | | | | employee's own disability, his or her spouse is |
| they fully comprehend the intricacies of the leave | | | | seriously injured in a motor vehicle accident, the |
| acts, both of which lead to misapplication of the law. | | | | employee is then entitled to 12 weeks unpaid leave |
| In general, the FMLA and NJFLA apply to all private | | | | under NJFLA. Contrast, however, a situation where |
| employers with 50 or more employees and all public | | | | an employee must provide care to a child for a |
| and governmental agencies regardless of the number | | | | serious medical condition and the 12 weeks of unpaid |
| of employees. Nevertheless, even the basic task of | | | | leave under both FMLA and NJFLA would run at the |
| tallying the number of employees working for a | | | | same time.ther issue that often occurs is whether an |
| private employer is complicated by provisions of the | | | | employer may force an employee to use paid leave |
| leave laws that increase the number of employees | | | | time concurrent with the unpaid leave provided for |
| attributed to an employer if it is shown that there is | | | | by FMLA and NJFLA. The short answer is yes - an |
| common management, ownership and control of a | | | | employer may require you to take your paid time |
| subsidiary, division or entity related to the particular | | | | off, i.e., sick and vacation time during your unpaid |
| employer. | | | | leave period. The principle here is that an employer |
| To be eligible for leave under the FMLA, an employee | | | | must follow its past practice concerning exhaustion |
| must have worked for a specific employer for a | | | | of all accrued paid leave during a leave of absence. In |
| minimum of 12 months and worked 1,250 base hours | | | | other words, the employer's practice must be |
| in the 12 months preceding the leave. Compare the | | | | consistent for leave act purposes with its policy |
| NJFLA, which requires the same 12 month | | | | about using paid time off during other unpaid leave |
| employment period, but reduces the base hour | | | | periods. |
| requirement to 1000 hours in the preceding 12 | | | | For employees and employers alike, the FMLA and |
| months for leave eligibility. Calculating eligibility is | | | | NJFLA pose difficult legal and factual questions. At |
| likewise not always what it seems - the minimum 12 | | | | risk for employers that mistakenly deny leave to an |
| month period of working for an employer does not | | | | employee is litigation and potentially significant |
| have to be consecutive months of employment and | | | | monetary penalties. At risk for employees that do |
| includes partial weeks worked, sick leave, vacation | | | | not properly follow the leave act guidelines is loss of |
| time and other paid time off. Contrast the base hour | | | | much needed time off and termination from |
| requirement, which does not include vacation, sick | | | | employment. For these reasons, it is imperative |
| leave or other personal leave toward this | | | | employers and employees consult with a legal |
| requirement. | | | | professional concerning the FMLA and NJFLA. |
| Under both FMLA and NJFLA, leave is available to | | | | |