Implementation Considerations for Seattle Sick Leave

My initial thought regarding the new Seattle Sick Leave ordinance was that an employer that had a “Paid Time Off” policy for all employees would not be impacted much by the new ordinance.  As we dig deeper into the specifics of the ordinance, I am finding more complexities and administrative burdens that employers will have to implement to comply with the ordinance.

Employers that fall within the ordinance’s purview are required to accrue paid sick or safe leave time for employees who work in Seattle.   To do so, employers must have a system in place to track the number of hours their employees spend working in Seattle.   Over the years, many companies have instituted virtual office environments and flexible work arrangements that allow employees to work from home.   This ordinance will require employers to re-think some of these decisions and possibly make changes based on the cost of managing the sick/safe leave accrual requirements.

Employers that fall within the ordinance’s purview must also report the accrued time to employees every payroll cycle.  To do so, employers must have a payroll system that allows the separation of vacation time or PTO time from the accrued sick/safe time.   If the payroll system doesn’t allow for this, the employer will have to maintain the list and notification procedures manually.

Similarly, the ordinance requires that employees be able to carry-forward a certain number of hours into the next calendar year.  If the employer’s PTO policy is a “use it or lose it” policy, it does not comply.  A certain number of these hours must be allowed to be carried forward.

These are just a few of the intricacies I have discovered that will be burdensome to employers.  It’s important to understand how the ordinance applies to your business and think ahead about the necessary policy and system changes you’ll  need to implement and communicate to employees well in advance of the September 1, 2012 effective date.