Quick Hits

• Starting no later than January 3, 2028, the FAMLI program will provide most Maryland employees with up to twelve weeks of paid leave for certain family and medical reasons, with a possible additional twelve weeks of leave for parental bonding, per application year.
• The program is funded through employer and employee payroll contributions, which will commence on January 1, 2027, and be administered by the MDOL’s FAMLI Division.
• The final regulations address, among other things, the claims process and paid leave benefits.

Background on the Law and Final Regulations

As discussed in further detail in Part I of this series, Maryland enacted the FAMLI program in 2022, to provide most employees with up to twelve weeks of paid family and medical leave (plus up to twelve additional weeks for parental leave) within a twelve-month period. After several legislatively mandated delays, employer and employee contributions are set to begin on January 1, 2027, with benefits commencing no later than January 3, 2028.

The MDOL’s final regulations, effective March 30, 2026, are organized into five chapters—General Provisions, Contributions, Equivalent Private Insurance Plans (EPIPs), Claims, and Dispute Resolution—and largely preserve the proposed regulatory framework with certain refinements. The final regulations can be found in Title 9, Subtitle 42 of the Code of Maryland Regulations, COMAR 09.42.01-.05.

Key provisions of the regulations related to the claims process and paid leave benefits are summarized below. Part I of this series addressed important definitions, the creation of online employer accounts, and mandatory notices. Part III covers EPIPs and dispute resolution.

Applications, Supporting Documentation, and Claim Updates

Eligible employees may file an application for benefits within sixty days before the anticipated start date of leave and no later than sixty days after the start date. The sixty-day filing deadline may be waived for good cause, up to one year from the commencement of leave.

The final regulations detail the required documentation for each type of qualifying event, including certification(s) from licensed health care providers for medical conditions, proof of relationship for bonding and caregiving, and confirmation of active-duty service for qualifying exigencies. A claimant applying for uniformed services caregiving leave must also provide documentation from the United States government establishing the service member’s status. The FAMLI Division may require claimants to attest that the information in their applications is true and that there are no disqualifying criteria.

Employers have five business days to respond to notice of an employee’s submitted claim application. If no employer response is received within that period, the claim application is deemed to be complete. If the employer challenges eligibility, the Division or EPIP will investigate, after which the claim is treated as complete. The Division may also request supplemental data from the employer. If benefits are approved and issued and an employer subsequently provides disqualifying information after the five-day window, the recipient retains benefits already received, but continuation of benefits will cease, and job and anti-retaliation protections apply only for the period from approval to revocation.

Employees must update material information within ten days, or as soon as practicable with good cause, including changes to the basis, start date, duration, or end date of leave, or whether the claimant has begun to receive workers’ compensation or unemployment insurance benefits. Failure to update may result in delay, underpayment, overpayment, or denial of benefits. Claims may also be withdrawn; if leave has already begun, only the actual leave taken will count against the employee’s FAMLI balance for the application year.

Duration and Timing of Leave

Employees may receive up to twelve weeks of FAMLI benefits and leave per employer per application year, with a potential additional twelve weeks where a claimant’s initial period of their own medical leave is followed by bonding leave, or vice versa, within the same year.

Bonding leave must be taken within twelve months of the birth or placement of a child. Leave may also be used in anticipation of the placement of a child for the purposes of attending court appearances, legal and placement agency appointments, counseling and medical appointments, and travel, provided they are substantiated by required documentation.

A licensed health care provider must document the time period required for the serious health condition of the employee, their family member, or a service member. If the family member for whom the employee is caring dies, benefits continue until seven days after the death or the previously approved end date, whichever is sooner, and the covered individual must provide notice of the death to the state within seventy-two hours. In essence, the final regulations provide for a form of bereavement leave that was not explicitly contemplated in the FAMLI statute.

Leave may be taken on a continuous or intermittent basis. Claimants approved for intermittent leave must submit benefit requests within five business days of leave being taken unless good cause can be shown. Intermittent leave may not be taken in increments of fewer than four hours unless the claimant’s scheduled shift is shorter. Benefits will not be issued for requests that significantly exceed the expected duration and frequency listed on the medical certification without an updated certification. Approved intermittent leave applications expire after one year, and a new claim application is required if the employee continues to need leave for the qualifying event.

Benefit Calculations: Continuous and Intermittent Leave

The final regulations establish a two-tier wage replacement formula for continuous leave. If the claimant’s average weekly wage is 65 percent or less of the state average weekly wage, benefits equal 90 percent of the claimant’s average weekly wage. For claimants earning above that threshold, benefits are the sum of 90 percent of the claimant’s average weekly wage up to 65 percent of the state average weekly wage and 50 percent of the amount above that threshold, up to the maximum weekly benefit amount.

For intermittent leave, one “week” of benefits equals the number of hours worked during the highest-earning quarter of the previous four completed calendar quarters divided by thirteen. The hourly benefit rate is calculated by dividing the weekly benefit amount by those average hours, and benefits are paid for actual hours of intermittent leave taken. The benefit amount for intermittent leave is calculated using the state average weekly wage and maximum weekly benefit amount in effect on the anchor date. On or before January 1 of each year, every open and active intermittent leave claim will be readjusted based on the new maximum weekly benefit amount.

Coordination With Other Benefits

The final regulations allow for the reduction of FAMLI eligibility by an employee’s federal Family and Medical Leave Act (FMLA) use if the FMLA leave also qualified for FAMLI, the employer notified the employee of their potential FAMLI eligibility, and the employee did not apply.

For alternative FAMLI purpose leave or AFPL (i.e. employer-provided leave specifically designated as a separate bank of time off for medical leave, family leave, qualified exigency leave, or under a disability policy, that is not leave provided under an EPIP), an employer may require concurrent use if the leave meets all of the following criteria: it is specifically designed to fulfill a FAMLI purpose, it is paid, it is not accrued, it is not subject to repayment, it is not available for general purposes, and it is available without a requirement to exhaust another form of leave. The employer must provide advance written notice of this requirement. Similar to FMLA, if the employee is notified of required concurrent use and fails to apply for FAMLI, the employee’s FAMLI’s eligibility is reduced by the amount of APFL taken. When both FAMLI and AFPL are used concurrently, FAMLI is primary and AFPL may supplement up to 100 percent of the employee’s average weekly wage. The employer may deduct the full amount of time taken from the recipient’s AFPL balance even if the recipient received only partial wage replacement. Importantly, an employee’s decision to use AFPL concurrently does not negate job protection or anti-retaliation provisions.

General-purpose paid leave (i.e., employer-provided paid leave, such as general paid time off, personal leave, vacation leave, or sick leave, that is not AFPL or leave provided under an EPIP) may not be required to be substituted for FAMLI leave. It may supplement FAMLI benefits only by mutual written agreement between the employer and the employee; however, the employee may use paid sick leave before FAMLI benefits without such an agreement.

Employees generally may not receive FAMLI benefits while receiving unemployment insurance benefits or workers’ compensation wage replacement, except for permanent partial disability benefits.

Payments, Overpayments, and Fraud

The first benefit payment must be issued within five business days after approval of a complete claim application or the start of leave, whichever is later, with subsequent payments at least every two weeks. If there is an overpayment, a written notice will be sent to the claimant, and the claimant has thirty days to agree to repay or request a waiver. Repayment may be sought for erroneous payments, willful misrepresentation, or where a claim is rejected after benefits were paid. Waivers may be granted where there was no knowingly false statement, nondisclosure, or misrepresentation, or where repayment would be against equity and good conscience or would otherwise be administratively inefficient. If a waiver is denied, the claimant may file a request for reconsideration. If an EPIP seeks monetary reimbursement of an overpayment, it must notify the Division simultaneously with its notice to the claimant.

If fraud is proven after benefits were approved and issued, any benefits paid are treated as an overpayment, and job and anti-retaliation protections do not apply.

Next Steps

The final regulations took effect on March 30, 2026. Employers may wish to begin preparing for the contribution obligations beginning January 1, 2027, and for the commencement of benefits no later than January 3, 2028. This may involve reviewing available paid leave benefits under existing policies and plans and determining if adjustments may be desirable.

Ogletree Deakins’ Baltimore office will continue to monitor developments and will provide updates on the Leaves of Absence and Maryland blogs as additional information becomes available.

In addition, the Ogletree Deakins Client Portal provides subscribers with timely updates on state family and medical leave laws, including Maryland’s FAMLI program. Premium-level subscribers have access to comprehensive Law Summaries and updated policies; Snapshots and Updates are complimentary for all registered client users. For more information on the Client Portal or a Client Portal subscription, please email clientportal@ogletree.com.

Please see Part I (online account and mandatory notices) and Part III (EPIPs and dispute resolution) of this series for further information.

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Quick Hits

• The WHO and several other organizations have jointly developed “Framework Guidelines for Addressing Workplace Violence in the Health Sector,” signaling a unified global commitment to ending workplace violence in healthcare.
• Despite the absence of a federal OSHA standard, the agency is actively investigating and citing employers that fail to protect healthcare workers from workplace violence.
• Several states have also taken the initiative to provide workplace violence prevention requirements in healthcare settings.

Worldwide, up to 38 percent of healthcare workers experience physical violence during their careers, and the toll extends far beyond bruises and broken bones. The consequences are far-reaching for workers, patients, and healthcare systems. The WHO, along with several other organizations, has made this issue a priority by developing “Framework Guidelines for Addressing Workplace Violence in the Health Sector.” These guidelines support the development of violence prevention policies and data collection efforts in both nonemergency and emergency settings. In the United States, the Occupational Safety and Health Administration (OSHA) has recognized the same issue as “serious” and “longstanding.”

The number of violent incidents against healthcare workers is staggering. Not only does it have a negative impact on the psychological and physical well-being of healthcare employees, but it also compromises quality of care for patients. The WHO estimates that between 8 percent and 38 percent of healthcare workers worldwide experience physical violence at some point in their careers, with many more exposed to verbal aggression. In the United States, nearly 20 percent of healthcare workers report experiencing physical abuse in the workplace. These are not abstract statistics—they represent nurses assaulted during shifts, emergency room staff threatened at knifepoint, and behavioral health workers enduring daily hostility. Both the WHO and OSHA have taken proactive approaches to confront this crisis.

The WHO’s Call to Action

The WHO, the International Labour Organization (ILO), the International Council of Nurses (ICN), and Public Services International (PSI) jointly developed “Framework Guidelines for Addressing Workplace Violence in the Health Sector.” These guidelines support the development of workplace violence prevention policies in non-emergency settings and provide a questionnaire and study protocol to research the magnitude and consequences of violence in healthcare. For emergency settings, the WHO developed methods to systematically collect data on attacks against healthcare facilities, workers, and patients—an essential step toward understanding a problem that is too often underreported and poorly tracked.

Where OSHA Stands in 2026

In the United States, OSHA has long identified a workplace violence prevention standard for healthcare as a priority. In March 2023, OSHA convened a Small Business Advocacy Review (SBAR) panel to consider a potential standard for the prevention of workplace violence in healthcare and social assistance fields. The panel heard from a broad cross-section of stakeholders, including representatives from hospitals, residential behavioral health facilities, ambulatory treatment centers, home healthcare agencies, emergency medical services, and correctional health settings. While OSHA had originally planned to publish a notice of proposed rulemaking (NPRM) in June 2025, the spring 2025 regulatory agenda moved the proposed rule to the long-term action category, and a date for the NPRM is now “To Be Determined.”

In the meantime, OSHA continues to enforce the General Duty Clause (Section 5(a)(1)) of the Occupational Safety and Health (OSH) Act, which requires healthcare employers to maintain a workplace free from recognized hazards likely to cause death or serious physical harm. Circuit courts have indicated a willingness to uphold General Duty Clause citations involving healthcare facilities and workplace violence, making it clear that healthcare employers cannot treat the lack of a dedicated standard as a shield against accountability.

States Filling in the Gap

While the federal standard remains in limbo, several states have moved forward with their own workplace violence prevention requirements. In recent years, states including California, Kentucky, Utah, Virginia, and Washington have introduced or enacted legislation specifically addressing workplace violence in healthcare settings.

Kentucky offers a useful case study. In 2023, Kentucky passed House Bill (HB) 176, requiring health facilities to develop and execute workplace safety assessments and safety plans aimed at identifying and mitigating the risk of violence against healthcare workers. The law mandates annual training, recordkeeping, and internal reporting systems with annual compliance audits. In February 2026, a bill was introduced to strengthen the law further, proposing, among other things, that healthcare facilities display prominent notices warning of potential consequences for threatening or aggressive behavior toward healthcare workers.

Meanwhile, in Washington, a recent amendment to RCW 49.19.020 added a new section establishing investigation requirements for workplace violence incidents in healthcare settings.

Next Steps

Even in the absence of a federal standard, the importance of workplace violence prevention in healthcare settings is clear. The WHO’s framework, OSHA enforcement actions, and state-level mandates all point in the same direction—healthcare facilities and employers must take proactive measures to address workplace violence and protect employees.

At a minimum, employers may want to review OSHA’s guidance on preventing workplace violence in healthcare settings. OSHA states in the guidance: “One of the best protections healthcare employers can offer their workers is to establish a zero-tolerance policy toward workplace violence.” Such workplace violence prevention policies should cover all employees, patients, and visitors, according to the guidance.

Ogletree Deakins’ Healthcare Industry Group and Workplace Violence Prevention Practice Group will continue to monitor developments and will post updates on the firm’s Healthcare, Workplace Safety, and Workplace Violence Prevention blogs as additional information becomes available.

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Quick Hits

• USCIS will accept employment-based adjustment of status filings based on the Final Action in May 2026.
• Most EB-1, EB-2, and EB-3 final action dates remain unchanged from the April 2026 Visa Bulletin.
• EB-3 Other Workers advances for all countries except India, China, and the Philippines.
• EB-5 Unreserved category for China advances by three weeks.

As a consequence, adjustment of status eligible for filing based on the April 2026 Visa Bulletin’s Dates for Filing Chart may not be eligible for filing in May.

The U.S. Department of State’s May 2026 Visa Bulletin shows no movement for most employment-based preference categories, except for limited movement in EB-3 Other Workers and EB-5 Unreserved preference categories.

The May 2026 Visa Bulletin Final Action Dates chart shows the following movement in the:

• EB-1: All countries remain current except China and India (which both remain at April 1, 2023).
• EB-2: All countries are current except China (which remains at September 1, 2021) and India (which remains at July 15, 2014).
• EB-3: No movement. China remains at June 15, 2021, India remains at November 15, 2013, and the Philippines remains at August 1, 2023. All other countries remain at June 1, 2024.
• EB-3 Other Workers: All countries (except India, China, and the Philippines) advance to February 1, 2022. China remains at February 1, 2021, India remains at November 15, 2013, and the Philippines remains at November 1, 2021.
• EB-4: All countries remain at July 15, 2022.
• Certain Religious Workers: All countries remain at July 15, 2022.
• EB-5 Unreserved: China advances to September 22, 2016. India remains at May 1, 2022. All other countries remain current.
• EB-5 Set-asides (Rural, High Unemployment, and Infrastructure): All countries remain current.

Source: U.S. Department of State, May 2026 Visa Bulletin, Final Action Dates Chart

Key Takeaways

The most significant development in the May 2026 Visa Bulletin is the shift by USCIS to require the use of final action dates for employment-based adjustment of status filings, rather than the more favorable Dates for Filing chart that had been in use in prior months. This means that applicants who were eligible to file under the Dates for Filing chart but are not yet current under the Final Action Dates chart will lose their ability to file employment-based adjustment of status applications beginning in May 2026.

The State Department notes that recent forward movement in cutoff dates is partly attributable to decreased consular immigrant visa issuance rates resulting from the immigrant visa processing pause on certain nationalities and notes that as additional immigrant visa demand materializes, or the administration lifts the pause on immigrant visa processing on certain nationalities, retrogression may be necessary later in the fiscal year which ends September 30, 2026, to keep issuances within annual limits.

Ogletree Deakins’ Immigration Practice Group will continue to monitor developments and will post updates on the Immigration blog as additional information becomes available.

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Quick Hits

• The U.S. Department of Education’s Office of Civil Rights has rescinded agreements protecting transgender and LGBTQ+ students across several school districts and one community college, reflecting a policy shift under the Trump administration.
• The office explained these agreements incorrectly interpreted Title IX, stating that protections apply only to sex and not gender identity.
• Such changes to Title IX enforcement and antidiscrimination obligations have significant implications for educational institutions receiving federal financial assistance.

On April 6, 2026, OCR announced that it had rescinded provisions of resolution agreements reached under the Biden administration to resolve alleged violations of Title IX of the Education Amendments of 1972.

The resolution agreements reportedly had imposed obligations on the schools, including providing faculty training on pronoun use and maintaining access to bathrooms consistent with students’ gender identities. At least one of the affected school districts has already voted to rescind the policies adopted under pressure from ED, after receiving prior confirmation that the resolution agreement would no longer be enforced.

The rescission applies to resolution agreements with five school districts: Cape Henlopen School District, Delaware Valley School District, Fife School District, La Mesa-Spring Valley School District, and Sacramento City Unified. Additionally, the agency said it would no longer enforce an agreement with Taft College, a community college in California.

Title IX Sex-Based Harassment

Title IX prohibits educational institutions receiving federal financial assistance from discriminating on the basis of sex in educational programs. The law and its regulations require schools to promptly and effectively respond to and investigate allegations of sex-based harassment.

However, OCR said the rescinded resolution agreements were based on the Biden administration’s “distorted” interpretation that federal antidiscrimination law applies to discrimination on the “basis of ‘gender identity,’ not sex.”

“Title IX protections are based on sex, therefore, these districts are not in violation of the law and are freed from these terms of the resolution agreements,” OCR stated in a news release.

According to the 2023 findings in the Taft College case, OCR found the community college “failed to respond promptly and effectively” to allegations that employees harassed a transgender student based on sex, including allegations that faculty and staff repeatedly misnamed and misgendered the student. OCR further found that the college failed to adequately notify students that they could report allegations of harassment based on sex, gender, gender identity, or gender expression.

The Taft College resolution agreement required the college to take certain steps, including updating its notices and policies “to clarify that harassment based on sex includes harassment based on sex stereotyping and that refusing to use (or repeatedly misusing) a student’s preferred names and pronouns may constitute harassment based on sex that could create a hostile academic environment under Title IX.” The college was further required to report information on sex-harassment allegations to the OCR.

Shifting Federal Policy

OCR’s rescission of the resolution agreements reflects how ED and OCR are shifting Title IX enforcement in line with the Trump administration’s policy of enforcing federal laws prohibiting sex-based discrimination and harassment under an interpretation of “sex” as being binary and immutable.

Previously, OCR found that San José State University’s policies allowing transgender student-athletes to compete in women’s sports and access the corresponding facilities violated Title IX. Further, the U.S. Department of Justice (DOJ) filed a lawsuit against Minnesota over the state’s policy allowing transgender students to participate in interscholastic sports and use locker rooms consistent with their gender identity.

However, the Trump administration’s interpretation of Title IX as applying to only a binary and immutable view of “sex” is not dispositive, particularly when it comes to participation in interscholastic athletics. In a recent decision rejecting an organization’s claims over Minnesota’s sports participation policy, the Eighth Circuit noted that there is “no dispute that whether Title IX requires, permits, or prohibits the participation of transgender athletes in female athletics remains an open question of law.”

The Supreme Court of the United States is currently considering two cases—Little v. Hecox and West Virginia v. B.P.J.—involving transgender students challenging state laws restricting participation in girls’ and women’s sports to athletes assigned female at birth. A decision in that case is anticipated this summer.

Next Steps

The Trump administration’s policy shift has significant implications for Title IX and antidiscrimination obligations for educational institutions that receive federal financial assistance, particularly those in states with conflicting laws. As such, educational institutions may want to review and consider their applicable policies.

Ogletree Deakins’ Diversity, Equity, and Inclusion Practice Group and Higher Education Practice Group will continue to monitor developments and will provide updates on the Diversity, Equity, and Inclusion Compliance and Higher Education blogs as additional information becomes available.

This article and more information on how the Trump administration’s actions impact employers can be found on Ogletree Deakins’ Administration Resource Hub.

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President Trump Nominates Two for NLRB. President Donald Trump has nominated James Macy to fill the remaining Republican seat on the National Labor Relations Board (NLRB). In addition, David Prouty, whose term is set to expire in August 2026, has been renominated for another five-year term on the Board. The remaining Democratic seat will remain unfilled for now.

A management-side attorney, Macy currently serves as director of the U.S. Department of Labor’s Office of Workers’ Compensation Programs. Assuming he is confirmed, Macy will join Republican members Scott Mayer and James Murphy (the chairman of the NLRB) to give Republicans a majority through at least December 2027, when Murphy’s term expires. Members of the business community are hopeful that this will give the Board sufficient time to revisit some of its Biden-era decisions on issues such as ambush union elections, employer speech restrictions, employer handbook policies, whether a worker is an employee or independent contractor, and whether offensive or abusive employee conduct can be considered protected concerted activity under the National Labor Relations Act, to name a few.

OSHA Renews National Emphasis Program Focused on Heat Hazards. The Occupational Safety and Health Administration (OSHA) has updated its National Emphasis Program (NEP) focused on protecting workers from heat-related hazards. According to an agency press release, “[h]eat illness remains a serious hazard for indoor and outdoor workers,” and the revised NEP “allows OSHA to better focus on outreach, compliance assistance, and enforcement efforts in high-risk industries and promote effective prevention practices.” OSHA is updating the NEP on heat while continuing to move forward on a heat–injury and illness prevention standard that was initially proposed during the Biden administration. Dee Anna D. Hays and Leah J. Shepherd have the details.

Senator Seeks Elimination of OPT Program. Senator Rick Scott (R-FL) has sent a letter to President Trump criticizing the Optional Practical Training (OPT) work-permit program. Senator Scott characterizes the OPT program as a national security risk, claiming that it provides “recipients from Communist China … access to sensitive technological information and intellectual property.” Senator Scott’s letter concludes, “The OPT program should not exist; it is a purely regulatory creation with no statutory basis.”

The OPT program provides one year of post-graduation work authorization to F-1 student visa holders, as well as an additional two years if they graduate with a STEM degree. According to the most recent Unified Agenda of Regulatory and Deregulatory Actions (issued in September 2025), Immigration and Customs Enforcement planned to issue a proposal to amend the existing OPT regulations as early as September 2025. While multiple government shutdowns and partial shutdowns have likely contributed to the delayed issuance of this proposal, Senator Scott’s letter is evidence that lawmakers and regulators remain interested in examining the OPT program.

House Lawmakers Continue Examination of AI in the Workplace. On April 15, 2026, the Workforce Protections Subcommittee of the House Committee on Education and Workforce held a hearing titled “Building an AI-Ready America: Understanding AI’s Economic Impact on Workers and Employers.” This was the sixth in a series of hearings that the committee has held on artificial intelligence (AI) in the workplace. Matthew P. Gizzo, shareholder in Ogletree Deakins’ New York and Dallas offices and co-chair of the firm’s Technology Practice Group, provided testimony at the hearing. Regarding the benefits that AI provides to both employers and employees, Gizzo wrote:

AI offers employers powerful tools to meet their wage and hour compliance obligations under federal, state, and local laws more accurately, more efficiently, and more consistently than has ever been possible before. Rather than viewing AI primarily through the lens of risk, AI-driven solutions can be maximized to close the compliance gap, particularly for small- and medium-sized businesses, in a manner that benefits employers and employees on a broad scale.

Republican members have not yet released any proposed legislation as a result of these hearings. However, should they choose to introduce legislation governing the use of AI in the workplace, Gizzo asked lawmakers to avoid “prescriptive mandates that would stifle the development and use of beneficial AI applications” and to establish “a uniform federal standard that preempts the growing patchwork of inconsistent state regulations.”

The Slaughter-House Cases. This week in 1873, the Supreme Court of the United States issued its decision in the Slaughter-House Cases. It was the first case in which the Supreme Court interpreted the Fourteenth Amendment, which had only been ratified in 1868. The Slaughter-House Cases involved a Louisiana law that granted a butchering monopoly to the Crescent City Live-Stock Landing and Slaughter-House Company. Louisiana reasoned that centralizing butchering activity in one location would limit pollution in the Mississippi River. The Butchers’ Benevolent Association of New Orleans challenged the law as a violation of the Fourteenth Amendment’s Privileges or Immunities Clause (“No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States …”). Justice Samuel Miller rejected the argument, writing that the privileges or immunities clause applied only to federal citizenship, such as the right to peaceably assemble or the right to protection of the federal government while “on the high seas or within the jurisdiction of a foreign government.” The Slaughter-House Cases, and its narrow interpretation of the Privileges or Immunities Clause, blunted the impact of the Fourteenth Amendment and allowed post-Civil War state and local civil rights abuses to persist. Although subsequent Supreme Court jurisprudence has relied on other clauses of the Fourteenth Amendment to protect individual rights and freedoms, the Slaughter-House Cases has not been reversed.

While the new contractual obligation is plainly written, the contours of what is “reasonably knowable” are less certain. For primes, the key question now is how far their due diligence and oversight responsibilities should extend into the operations of their subs, particularly in sensitive internal areas such as employment practices (e.g., hiring and promotions), employee program participation, contracting, or allocation or deployment of company resources. The clause’s focus on conduct “[i]n connection with” the contract and traditional industry practice in the prime–sub relationship can provide a compliance guide for primes grappling with understanding the new contractual dynamic with their subs.

Quick Hits

• The “reasonably knowable” standard in EO 14398 likely should not require prime contractors to affirmatively investigate all aspects of a subcontractor’s business, but it could require attention to information that arises through normal contract administration.
• The EO contract clause’s applicability to conduct “[i]n connection with the performance of work” likely limits a prime’s oversight obligation to issues tied to contract performance, not a sub’s internal employment practices generally.
• Analogous standards, including the False Claims Act framework, suggest that liability may attach where a prime contractor ignores clear red flags, not where it fails to uncover information outside its ordinary visibility.
• Agencies have not yet defined the contours of this standard, creating uncertainty and reinforcing the need for a measured, risk-based approach to subcontractor oversight.

A Standard Rooted in Knowledge, Not Surveillance

The phrase “reasonably knowable” may appear to impose an affirmative duty on prime contractors to investigate or actively monitor subcontractors’ compliance with the EO clause. A closer reading suggests a more measured standard. The clause likely ties the reporting obligation to what the prime knows or should know under the circumstances, not what could be discovered through exhaustive inquiry or audit.

This distinction matters. Federal procurement has operated on the principle that prime contractors manage subcontract performance, not the entirety of a subcontractor’s internal business operations. In practice, primes assess whether subs are delivering the required goods or services, meeting schedule and quality expectations, and complying with flow-down contract terms that impact delivery. Primes typically do not audit subs’ hiring practices, promotion decisions, or internal corporate policies unrelated to contract performance. The “reasonably knowable” standard should be read against that industry practice backdrop. By doing so, the standard does not appear to transform primes into general regulators of their subs’ enterprise operations.

The Limiting Effect of “In Connection With the Performance of Work”

The clause’s reference to conduct “in connection with the performance of work under this contract” is likely to be a key limiting principle. That language suggests the clause’s compliance focus is not on all aspects of a subcontractor’s business, but rather on conduct that has a nexus to contract performance.

For example, information that comes to light through ordinary contract administration activities such as performance reviews, deliverable assessments, site visits, or communications with subcontractor personnel may fall within the scope of what is reasonably knowable. By contrast, internal employment practices that have no discernible connection to contract performance may fall outside that scope, particularly where the prime lacks visibility into those practices through its normal oversight functions.

This interpretation aligns with long-standing procurement norms. Prime contractors are not typically expected to “police” subcontractors beyond what is necessary to ensure contract compliance. Extending the obligation further could create significant practical and legal challenges, including tensions with corporate separateness and potential exposure to unrelated employment law issues.

Lessons From the False Claims Act and From Common Law Standards

Although EO 14398 does not define “reasonably knowable,” analogous standards in federal law provide useful context. The scienter standard under the False Claims Act, for example, includes not only actual knowledge but also “deliberate ignorance” and “reckless disregard” of the truth or falsity of information. Courts interpreting that standard have generally declined to impose liability for mere negligence or for failing to uncover information that was not reasonably accessible.

Similarly, common law doctrines often frame “reasonably knowable” information as that which would be discovered through the exercise of ordinary diligence under the circumstances. This is not a duty of exhaustive investigation, but rather a duty not to ignore red flags that are apparent within the scope of one’s responsibilities.

Applied to the EO contract clause, these analogues suggest that a prime contractor may have an obligation to act where there are clear indicators of problematic conduct tied to contract performance that arise in the course of normal oversight. On the other hand, the standard likely does not require proactive audits of subcontractor policies or affirmative efforts to uncover information that is not otherwise visible.

Practical Implications for Prime Contractors

Even with these guideposts, there remains meaningful uncertainty regarding how contracting officers and agencies will interpret and enforce the “reasonably knowable” standard. Early implementation may vary across agencies, particularly as this requirement intersects with evolving policy positions on DEI-related activities.

In this environment, prime contractors may want to consider calibrating their compliance approaches without overcorrecting. Practical steps could include the following:

• Ensuring that subcontract management personnel are trained to recognize and escalate potential compliance issues that arise during routine oversight activities
• Reviewing subcontract terms to confirm that appropriate representations, certifications, and flow-down clauses are included
• Documenting ordinary course contract administration activities to establish what information was and was not reasonably available
• Avoiding unnecessary expansion of oversight into areas that are unrelated to contract performance and outside the prime’s traditional role

Based on the information currently available, the goal would appear to be to demonstrate reasonable diligence within the scope of the prime’s contractual responsibilities, but not to assume a generalized duty to investigate.

A Developing Standard Worth Watching

EO 14398 introduces a concept that is familiar in legal theory but new in this specific procurement context. The “reasonably knowable” standard sits somewhere between actual knowledge and strict liability, and its application will likely be shaped through agency guidance, contracting officer practice, and potentially enforcement actions.

For now, prime contractors may want to resist the instinct to either ignore the requirement or overextend their oversight functions. The more defensible position likely lies in grounding compliance efforts in established procurement practices, focusing on information obtained through normal contract administration, and remaining attentive to how agencies begin to interpret this standard in practice.

As with many recent developments in federal procurement policy, this is an area where thoughtful, measured implementation will be more effective than sweeping changes made in the absence of clear guidance.

Next Steps

Ogletree Deakins’ Diversity, Equity, and Inclusion Compliance Practice Group, Government Contracting and Reporting Practice Group, and Workforce Analytics and Compliance Practice Group will continue to monitor developments and provide updates on the Diversity, Equity, and Inclusion Compliance, Government Contracting and Reporting, and Workforce Analytics and Compliance blogs as additional information becomes available.

This article and more information on how the Trump administration’s actions impact employers can be found on Ogletree Deakins’ Administration Resource Hub.

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Quick Hits

• Seasonal allergies may qualify as a disability under the ADA when they substantially limit major life activities such as breathing or concentrating, and employers must engage in a good-faith interactive process whenever an employee raises allergy-related limitations.
• While mild seasonal allergies are unlikely to meet the ADA’s definition of disability, severe allergies may be covered, and the ADA requires that the determination be made without considering the ameliorative effects of medication.
• Employers may want to consider low-cost measures such as improved air filtration or schedule adjustments, and ensure frontline managers are trained to recognize and properly route such requests to maintain ADA compliance.

When Do Seasonal Allergies Become a ‘Disability’?

Spring is in the air in the United States—and so are pollen, ragweed, grass, and a host of other springtime allergens. For most employees, seasonal allergies are a minor nuisance managed with an over-the-counter antihistamine. But for some, allergic reactions may be severe enough to significantly impair breathing, concentration, or other daily functions, prompting affected employees to seek accommodations under the ADA. For those employees, employers may want to think carefully about accommodation requests related to seasonal allergies.

The ADA defines disability as a “physical or mental impairment that substantially limits one or more major life activities.” An impairment substantially limits a major life activity when a person “is either unable to perform a major life activity or is significantly restricted as to the condition, manner or duration under which the individual can perform the major life activity as compared to the average person in the general population.” Major life activities include breathing, concentrating, and working, all of which can be affected by severe allergic conditions.

That said, not every case of seasonal allergies will qualify. Mild or ordinary seasonal allergies easily controlled with routine medication are unlikely to rise to the level of an ADA-qualified disability. But an employee who experiences chronic sinusitis, severe asthma triggered by allergens, or allergic reactions that substantially impair breathing or other major life activities may well be covered under the ADA. Importantly, the ADA requires that this determination be made without regard to the ameliorative effects of mitigating measures such as medication, meaning even an employee whose symptoms are well-controlled by prescription allergy drugs may still be considered disabled under the ADA.

While a serious health condition under the Family and Medical Leave Act (FMLA) and a disability under the ADA are defined differently, it is possible that seasonal allergies qualify as either or both in some instances. Accordingly, when managing an employee with seasonal allergies, employers may want to consider whether the FMLA’s rights for unpaid leave for a serious health condition are implicated in addition to the ADA analysis discussed here.

The Interactive Process

When an employee raises allergy-related limitations that interfere with or relate to performance of the employee’s job—even informally, without ever mentioning the ADA—the employer’s obligation to engage in a good-faith interactive process is triggered. Courts have held that failing to engage can create liability on its own, regardless of whether the condition ultimately meets the statutory definition of disability. The bottom line: employers may wish to take every request seriously, respond promptly, and document the conversation, including the limitations discussed, the accommodations considered, and the reasons for any decisions made.

Employers are entitled to request medical documentation to support an accommodation request when the disability or need for accommodation is not obvious. In the context of seasonal allergies, it is generally reasonable to ask the employee to provide documentation from a healthcare provider confirming that the employee has an impairment, the specific limitations the employee experiences as a result, and how the requested accommodation would help the employee perform the essential functions of the job.

Employers may want to be careful, however, not to request overly broad medical records or conduct inquiries that go beyond what is necessary to evaluate the accommodation request. The goal is to obtain enough information to understand the employee’s functional limitations and assess potential accommodations.

Reasonable Accommodations to Consider

An employer has the discretion to choose a reasonable accommodation that enables the employee to effectively perform the essential functions of their job. An employer does not have to provide the employee’s preferred or requested accommodation if there is an alternative reasonable accommodation that enables the employee to effectively perform the essential functions of his or her job.

Remember that an employer is not required to provide an accommodation that would impose an undue hardship, which means significant difficulty or expense relative to the employer’s resources and operations. Whether a particular reasonable accommodation is an undue hardship is determined on a case-by-case basis. But because most allergy accommodations are temporary and modest, that defense may be tough to establish in this context.

The good news is that many allergy-related accommodations are generally straightforward and can be low-cost. Reasonable accommodations related to seasonal allergies generally include measures to remove the allergen or reduce the employee’s exposure to the allergen. This can include, but is not limited to, keeping windows and doors closed to keep pollen out, improving HVAC filtration or changing HVAC filters frequently, relocating an employee’s workstation away from frequently opened windows and doors, allowing leave for visits to allergists or other medical providers, and considering schedule adjustments during allergy season to allow for later start times to avoid exposure during peak allergy times or temporarily allowing remote work to avoid exposure to allergens.

Key Takeaways

Engaging in the interactive process in good faith is a core component of ADA compliance, regardless of an employee’s medical condition. What feels like “just allergies” to one person may be a genuinely debilitating condition for another and possibly trigger ADA obligations. As allergy season continues, it is a good time to review existing accommodation policies and confirm that frontline managers know how to address and route requests appropriately.

Ogletree Deakins’ Employment Law Practice Group and Leaves of Absence/Reasonable Accommodation Practice Group will continue to monitor developments and will post updates on the Employment Law and Leaves of Absence blogs as additional information becomes available.

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Quick Hits

• New DOL guidance indicates that state laws relating to ESG investments would avoid ERISA preemption, creating additional legal risk to plans that offer ESG investments.
• The guidance sets forth the DOL’s position that proxy advisors can be fiduciaries subject to ERISA.
• Management of shareholder rights exercises discretion over plan assets and meets ERISA’s definition of a fiduciary.
• The DOL is following the DOL’s 1975 five-part test for determining whether providing investment advice for a fee renders a person a fiduciary. The existence of a contract between a plan and a proxy advisory firm for investment advice services may be a relevant factor in determining whether this test is met.

This guidance represents the latest chapter in the Trump administration’s movements against environmental, social, and governance (ESG) investments, and it could increase employers’ legal exposure under state laws relating to plan investments.

Risk for ESG Investments

The guidance, released by the DOL’s Employee Benefits Security Administration (EBSA), follows a December 2025 executive order from President Donald Trump, which directed federal agencies to strengthen fiduciary standards and increase transparency around proxy advisory firms. That order called out practices that considered diversity, equity, and inclusion (DEI) and ESG factors. Most recently, the DOL also issued guidance addressing the extent to which ERISA-covered retirement plans may consider nonpecuniary factors in investment decisions.

For employers, perhaps more significant than the headline focus on proxy advisory firms is the language addressing the risk of regulatory fragmentation, particularly as a direct response to state-level actions that seek to limit consideration of ESG or DEI factors and impose additional disclosure requirements on such investments. Historically, the impact of these state laws on ERISA-covered benefit plans has been relatively limited due to the expectation that they would be preempted by ERISA.

The new guidance clarifies that a state law is not preempted by ERISA when the state law requires proxy advisory firms to disclose to plan investors when they make recommendations for any purpose other than maximizing risk-adjusted return. In a notable departure from prior assumptions, and against the backdrop of gradual judicial narrowing of ERISA preemption, the guidance expressly states that these types of state laws would generally not be preempted. This position places retirement plans in a precarious position, increasing potential exposure to claims and other liability to the extent their investment lineups include ESG investments.

ERISA Fiduciaries Subject to High Standards

ERISA imposes fiduciary duties of prudence and loyalty on fiduciaries of retirement, health, and welfare plans. Under a five-part test established in 1975, a person is a fiduciary when he or she provides individualized investment advice on a regular basis under a mutual understanding that the plan will rely on that advice as a primary basis for investment decisions.

The fiduciary status has two key practical consequences for employers and plan sponsors. First, all actions taken on behalf of the plan must satisfy ERISA’s prudence and loyalty standards. Second, fiduciaries face potential liability for engaging in prohibited transactions with respect to plan assets. The new guidance specifies that shareholder rights, including proxy voting for shares held by ERISA-governed plans, are plan assets. Accordingly, the exercise of those rights is subject to fiduciary standards, meaning fiduciaries must manage proxy voting decisions with the same care and loyalty required for any other plan asset.

Limited Role of Proxy Advisors

Proxy advisory firms are third-party entities that provide research, data, and voting recommendations to institutional investors, often addressing corporate governance issues like director elections, executive compensation, and mergers.

The DOL has indicated that, depending on the facts and circumstances, a proxy advisory firm could satisfy the five-part fiduciary test. Proxy advisory firms may be ERISA fiduciaries when they exercise control over proxy voting for plan-held shares or provide fee-based proxy voting advice to ERISA plans.

However, this part of the guidance is likely to have minimal practical impact on most plan sponsors.

In practice, this issue is most relevant to defined benefit pension plans. Large corporate and union pension funds hold diversified equity portfolios, spanning hundreds or thousands of companies, making it impractical to independently analyze every proxy ballot. It is common to hire proxy advisors responsible for overseeing their votes to protect participants’ interests. However, the Supreme Court of the United States’ decision in Thole v. U.S. Bank, N.A., limits exposure for these plans, as plan participants likely lack standing to sue over proxy voting decisions.

Defined contribution plans, such as 401(k)s, more often invest in mutual funds or trusts, where fund managers, not the plans, hold shares and vote proxies. Consequently, most 401(k) plans don’t vote proxies directly and rarely need proxy advisory firms.

There is a risk, however, that the DOL will scrutinize proxy advisory services to employer plans to attack whether the voting recommendations violate the DOL’s view that ERISA fiduciaries’ duty of loyalty requires a singular focus on maximizing risk-adjusted financial returns for the plan and not on ESG or DEI interests.

Next Steps

In light of this guidance, to the extent a plan offers ESG or similar investments, it may wish to consider reviewing compliance with applicable state proxy-voting or investment-related rules to assess potential legal exposure. Plans also might consider reviewing their investment policy statements, particularly the sections addressing proxy voting, to ensure the language does not create fiduciary exposure under the new guidance.

Additionally, plans that hire proxy advisors may want to review their service agreements to assess fiduciary status under the five-part test and, assuming the test is met, ensure the agreements appropriately address fiduciary status and related responsibilities, such as fee disclosures.

Ogletree Deakins’ Employee Benefits and Executive Compensation Practice Group and the Environmental, Social and Governance Practice Group will continue to monitor developments and will post updates on the Employee Benefits and Executive Compensation blog as additional information becomes available.

This article and more information on how the Trump administration’s actions impact employers can be found on Ogletree Deakins’ Administration Resource Hub.

Karen N. Brandon is a shareholder in Ogletree Deakins’ Morristown office.

Carly E. Grey is a shareholder in Ogletree Deakins’ Washington, D.C., office.

This article was co-authored by Leah J. Shepherd, who is a writer in Ogletree Deakins’ Washington, D.C., office.

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Quick Hits

• Washington State Governor Ferguson recently signed a wide range of labor and employment legislation into law, including bills that address reductions in force, pregnancy accommodations, noncompete agreements, traditional labor relations, behavioral health in the construction industry, and wage and hour claims.
• HB 1155, which bans noncompetition agreements with employees and independent contractors, will take effect on June 30, 2026; the other laws will take effect on June 11, 2026.

These bills were signed by the governor in recent weeks:

Separation of employment

• SB 6106 amends the Washington WARN law (called the STABLE Act) to remove “any Indian tribe” from the definition of “employer.” It also limits the disclosure of the names and addresses of employees holding affected jobs.
• HB 1155 bans noncompetition agreements with employees and independent contractors, while expanding what qualifies as such.
• SB 5874 modifies penalties for reporting errors regarding unemployment compensation. It also amends requirements for reporting employee information, including Social Security numbers and standard occupational classifications.
• HB 2264 allows a person to receive unemployment benefits after voluntarily being part of an employer’s reduction in force.

Accommodations and general employee rights

• SB 6014 confirms that employers may not require a certification from a pregnant employee’s healthcare provider for the accommodation of a limit on lifting over seventeen pounds. It also protects records relating to pregnancy accommodations from disclosure through public records requests.
• HB 2303 prohibits employers from requiring, coercing, or requesting employees to implant a microchip and from using subdermal technology for management or surveillance. Employees alleging violations of the law may bring a civil lawsuit for injunctive relief, actual damages, punitive damages, and attorneys’ fees.
• SB 5847 requires employers to notify workers injured on the job that they have the right to choose a medical provider of their choice when seeking workers’ compensation.
• HB 2105 stipulates that employers have five business days to notify employees if a federal agency seeks an inspection of an employee’s I-9 authorization form and related work records.

Wages

• HB 2479 creates the Wage Recovery Program and Wage Recovery Account to allow unpaid, low-wage workers to receive disbursements if certain conditions are met. It gives the Washington Department of Labor and Industries (L&I) discretion to investigate complaints under the Wage Payment Act. It also increases the minimum civil penalty amount and removes the maximum cap for willful violations. Penalties may be assessed for repeat willful violators and willful violators that have previously settled or resolved prior wage complaints.
• SB 6058 grants the L&I more discretion in how it investigates wage complaints. It permits civil penalties for willful violations.
• SB 6039 clarifies that required notices, orders, citations, determinations, and similar communications from the L&I may be provided using electronic means. In certain contexts, the method must allow delivery to be tracked or confirmed.

Labor rules

• HB 2471 authorizes the state to regulate private-sector labor disputes if the National Labor Relations Act ceases to preempt state regulation or if the National Labor Relations Board does not assert jurisdiction over private-sector employment. The Public Employment Relations Commission may oversee union elections, mediate disputes, and address unfair labor practices.
• HB 1128 establishes a childcare workforce standards board.
• HB 2355 establishes labor protections for domestic workers, including mandating minimum wage and overtime, advanced termination notice, and protections against harassment, discrimination, and personal document confiscation.

Construction

• HB 2107 requires the L&I to make a good-faith effort to notify an employer within ten working days if an onsite inspection identifies a hazard at any construction worksite.
• HB 2492 requires state-registered apprenticeship programs in the building and construction trades to provide apprentices with two hours of behavioral health and wellness training. It allows electricians and plumbers to count up to four hours of behavioral health and wellness training toward continuing education requirements for certification renewals.

Income tax

• SB 6346 provides various forms of tax relief paid for through a new 9.9 percent state tax on an individual or household’s Washington taxable income over $1 million, beginning in 2028, with the first payments being due in April 2029, unless litigation, referendum, or repeal initiatives are successful in challenging the law.

Next Steps

These laws will take effect on June 11, 2026, except for the law on noncompete agreements, which will take effect on June 30, 2026.

The state agencies do not release their interpretations or explanatory comments on every new law, and any such administrative guidance is often not released until after new laws take effect.

Ogletree Deakins’ Seattle office will continue to monitor developments and will post updates on the Construction, Employment Law, Healthcare, Reductions in Force, Traditional Labor Relations, Unfair Competition and Trade Secrets, Wage and Hour, Washington, and Workplace Safety and Health blogs as additional information becomes available.

Information on Terminations and RIFs and Pregnancy, Childbirth, and Lactation is available on the Ogletree Deakins Client Portal. These recent updates are referenced on the Washington jurisdiction page and in the Washington WARN and Washington Pregnancy, Childbirth, and Lactation law summaries. Snapshots and updates are available for all registered client users. Detailed information and relevant documents (including updated Washington WARN notices) are available for Premium and Advanced subscribers. For more information on the Client Portal or a Client Portal subscription, please reach out to clientportal@ogletree.com.

Sherry L. Talton is a shareholder in Ogletree Deakins’ Seattle office.

This article was co-authored by Leah J. Shepherd, who is a writer in Ogletree Deakins’ Washington, D.C., office.

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Quick Hits

• Slovakia remains further ahead than the Czech Republic with transposing the EU Pay Transparency Directive into national law, with a dedicated draft law already in the legislative process.
• The Czech Republic published a draft Labour Code amendment and has explicitly opted for a “minimalist transposition” mirroring the directive’s minimum requirements.
• In both countries, employers may want to begin reviewing pay structures, transparency practices, and internal governance now.

Slovakia published its draft implementing law in September 2025 and submitted it to Parliament on 7 January 2026. On 26 March 2026, the Czech Ministry of Labour and Social Affairs released its draft proposal, which has now entered the public consultation phase.

Where the Two Countries Stand

Slovakia and the Czech Republic are both moving towards implementation, but they are doing so in different ways and at different speeds.

Slovakia

Slovakia is further along in the transposition process than its neighbour. Its transposition effort is built around a dedicated draft law on equal remuneration for men and women for the same work or work of equal value, which is already in the legislative process.

The Slovak draft is particularly detailed on recruitment. Employers would have to provide applicants with timely and transparent information on the starting remuneration or remuneration range for a role. This requirement would be considered fulfilled if the salary information included in the job advertisement is more prescriptive than the directive requires. While Slovak law has required salary disclosure in job advertisements since 2018, the new proposal would go further by requiring the remuneration offered to be linked to objective, gender-neutral criteria established before the position is advertised. Employers would also be prohibited from asking candidates about their current or previous remuneration.

The proposal also would strengthen transparency during employment. Employers would not be allowed to prevent employees from disclosing information about their remuneration, and any contractual provisions imposing confidentiality in this area would be invalid. Because the Slovak draft uses the broader concept of remuneration, this transparency would not be confined to wages or salary in the narrow sense, but could also cover other benefits linked to employment.

The Slovak reporting model largely follows the directive. Employers with fewer than one hundred employees would not be required to report unless they chose to do so voluntarily. A failure to comply could ultimately lead to a fine of up to EUR 4,000.

The Czech Republic

The Czech Republic has also moved beyond the preparatory stage. The Ministry of Labour and Social Affairs has prepared a draft amendment to the Labour Code to transpose the Pay Transparency Directive into Czech law and has made clear that it is pursuing a “minimalist transposition”. The stated aim is to meet EU requirements while limiting the burden on employers as far as possible.

The legislation is expected to take effect from 1 January 2027, although some requirements will be phased in later, with reporting implementation dates extending to 2028 (for employers with 150 or more employees) and 2031 (for employers with 100-149 employees). This timeline confirms that the Czech Republic does not intend to meet the European Union’s transposition deadline of 7 June 2026.

Employers are encouraged to stay informed about the implementation process in their respective jurisdictions. Information and updates on the progress of the directive’s implementation across the European Union can be found using Ogletree Deakins’ Member State Implementation Tracker.

Further information can also be found by listening to our podcast, “Understanding the EU Pay Transparency Directive: What Employers Need to Know.”

Ogletree Deakins’ London office, Pay Equity Practice Group, and Workforce Analytics and Compliance Practice Group will continue to monitor developments and will provide updates on the Cross-Border, Pay Equity, and Workforce Analytics and Compliance blogs as additional information becomes available.

Daniella McGuigan is a partner in the London office of Ogletree Deakins and co-chair of the firm’s Pay Equity Practice Group.

Lorraine Matthews, a practice assistant in the London office of Ogletree Deakins, contributed to this article.

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