LETTERS PAID LEAVE MANDATES MAY FAIL TO REACH PART-TIME WORKERS Paid sick leave supports individual and public health through eliminating the financial penalty for missing work when an employee or an employee’s family member is ill or needs medical care. In America, access to paid sick leave mirrors other economic inequalities, as part-time and low-wage workers are far less likely to have paid leave than full-time or higher-income workers.1 In the absence of a federal policy, local mandates passed by cities, counties, and states expand the right to paid leave to workers who would not otherwise have it.2 Colla et al. report on a vanguard effort in their analysis of how employers implemented the 2007 San Francisco Paid Sick Leave Ordinance in California.3 More San Francisco employers offered leave and covered more employees after the Ordinance went into effect, findings echoed by the more recent evaluation of the Seattle Paid Sick and Safe Time Ordinance in Washington.3,4 In both Seattle and San Francisco, more than 90% of firms offered paid sick leave to at least some employees after the respective mandates took place.3,4 However these high rates of leave offering mask within-employer inequalities whereby some employees at an establishment may have

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access to leave but others do not. The Colla et al. analysis rests on a survey question askingwhether an employer provides paid vacation or sick time to any of its employees; a follow-up question asks about the percentage of workers covered.5 Relying on responses to the former will overestimate the availability of leave to all employees. Indeed Colla et al. found that the largest employers report covering only 86% of their employees; and the smallest employers cover fewer than 8 in 10.3 The Seattle Ordinance evaluation, which tracked leave offering separately for full- and part-time employees, found that almost all employers (96%) offer leave to their full-time employees. Not all employers have part-time employees, but among those who do, only 62% cover their parttimers.4 Neither study tracked leave by earnings level, but the audit-based National Compensation Survey collected by the Bureau of Labor Statistics reports that only 30% of private industry employees in the bottom quarter of the wage distribution have access to paid sick leave1; many of these employees presumably work in enterprises where higher-earners do have this benefit. As other localities implement and examine paid sick leave mandates, detailed tracking of which classes of employees gain access can more accurately track the likely health impact of these measures. j

Jennifer L. Romich, PhD

About the Author Jennifer L. Romich is with the School of Social Work, University of Washington, Seattle. Correspondence should be sent to Jennifer L. Romich, Associate Professor, University of Washington, School of Social Work, Box 354900, Seattle, WA 98105 (e-mail: [email protected]). Reprints can be ordered by visiting http://www.ajph.org and clicking on the “Reprints” link. This letter was accepted January 2, 2015. doi: 10.2105/AJPH.2015.302550

References 1. Bureau of Labor Statistics. Table 6. Selected Paid Leave Benefits: Access. 2014. Available at: http://www. bls.gov/news.release/ebs2.t06.htm. Accessed April 8, 2014.

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2. Dell’Antonia K. Paid sick leave: on four ballots and undefeated. New York Times. November 5, 2014. Available at: http://parenting.blogs.nytimes.com/2014/11/ 05/paid-sick-leave-on-four-ballots-and-undefeated. Accessed December 30, 2014. 3. Colla CH, Dow WH, Dube A, Lovell V. Early effects of the San Francisco paid sick leave policy. Am J Public Health. 2014;104(12):2453---2460. 4. Romich JL, Bignell W, Brazg T, et al. Implementation and Early Outcomes of the City of Seattle Paid Sick and Safe Time Ordinance Final Report. Seattle, WA: University of Washington; 2014. 5. Dow WH, Dube A, Colla CH. Bay Area Employer Health Benefits Survey. Berkeley, CA. Berkeley, CA: University of California; 2009.

COLLA ET AL. RESPOND We agree with Romich that detailed tracking of which classes of employees gain access to sick leave can more accurately track the likely health impact of sick leave policies. We have a few additional data points from The Bay Area Health Benefits Survey that are worth mentioning to confirm that firms with high rates of part-time workers are also expanding access to paid sick leave. First, and most importantly, given the way that the San Francisco, California, policy works, accrual is not limited to full-time workers. As a result, almost by definition, it is reaching part-time workers unless employers are noncompliant. The San Francisco Paid Sick Leave Ordinance requires employers to provide paid sick leave to all employees (including part-time and temporary) at the same rate: one hour for every 30 hours worked after the first 90 calendar days of employment. The way the calculation is completed means they will earn fewer hours of sick leave, but it will be in proportion to work hours. Romich’s comment also highlights the importance of how the details of leave policies are implemented. Second, Table 1 in our article reports firms with a large fraction of part-timers did see a sizable increase in coverage. We cannot say that such an increase occurred equally for fulland part-time workers; however, if coverage rates rose similarly in firms with few and many

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part-timers, it strikes us as unlikely that parttimers did not benefit from the mandate. In firms with a high proportion of part-time workers (> 33% of employees work fewer than 30 hours per week, or the 75th percentile), 53.5% of firms offered paid sick leave prior to the mandate. In 2009, after implementation of the paid sick leave policy, 78.6% of these firms reported offering coverage, to 49.9% of employees. Similarly, in firms with more than 50% part-time workers, only 40.9% of firms offered paid sick leave in 2006, compared with 71.1% in 2009. The eligibility rate within these firms in 2009 was 38.9%. By contrast, the eligibility rate in 2009 in firms with no part-time workers was 85.6%. If you apply this eligibility rate (85.6%) to the full-time workers in the firms with a majority of part-time workers described above, it is very likely that part-time workers in San Francisco saw increased access to leave after the mandate. High rates of leave offering are masking withinemployer inequalities, whereby some employees at an establishment have access to leave but others do not, but part-time workers are very likely gaining some access to paid sick leave. We agree that there is substantial inequality in leave allowances in the labor market, and that paid leave mandates will not address this fully. However, this mandate appears to have reduced such inequalities as it is most binding for firms hiring low-wage workers. At the same time, as the San Francisco experience shows, the design of the mandate is very important in ensuring that it applies to broad classes of workers—including part-time employees. j

Reprints can be ordered at http://www.ajph.org by clicking the “Reprints” link. This letter was accepted February 24, 2015. doi:10.2105/AJPH.2015.302651

Contributors All authors contributed equally to this letter.

Carrie H. Colla, PhD William H. Dow, PhD Arindrajit Dube, PhD

About the Authors Carrie H. Colla is with the Geisel School of Medicine at Dartmouth, The Dartmouth Institute for Health Policy and Clinical Practice, Lebanon, NH. William H. Dow is with the Division of Health Policy and Management, School of Public Health, University of California, Berkeley. Arindrajit Dube is with the Department of Economics, University of Massachusetts, Amherst. Correspondence should be sent to Carrie H. Colla, Geisel School of Medicine at Dartmouth, The Dartmouth Institute for Health Policy and Clinical Practice, 35 Centerra Parkway, Lebanon, NH 03766 (e-mail: [email protected]).

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Colla et al. respond.

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