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Mary Ziegler, Director
Division of Regulations, Legislation, and Interpretation
Wage and Hour Division
U.S. Department of Labor, Room S-3502
200 Constitution Avenue NW.
Washington, DC 20210
RE: (RIN) 1235-AA05
DATE (no later than February 27, 2012)
Dear Ms. Ziegler:
I/We am/are writing in support of the Department of Labor’s proposed rule (RIN) 1235-AA05 that would
narrow the current exemption of home care workers from the minimum wage and overtime protections under
the Fair Labor Standards Act. I manage/own a non-profit/for-profit home care agency with ### employees
serving approximately ### clients.
At our agency, we have always treated our home care aides with respect—and that includes fair
compensation. Our workers receive $/hour. We also pay/would pay for travel between clients and overtime at
time and a half if our competition did the same. We believe strongly that these workers deserve the same
federal minimum wage and overtime protections that are granted to other American workers, including
nursing assistants who do similar work in different settings. Of our caseload, ## percent of our clients have
high-hour needs, and as a business we can manage those cases without excessive overtime
Our workers provide a wide range of services, including [personal care/housekeeping/medical-related tasks—
please be specific]. This work requires skill and compassion. It is by no means equivalent to Friday-night
babysitting. It is a career that allows our employees to give back to their communities while helping to provide
for their families.
One of the challenges we face as a business is recruiting and retaining a qualified workforce. We believe that
providing a compensation floor will help to attract more workers to the field and reduce turnover, which adds
unnecessary costs to our business ledger and undermines continuity of care.
The proposed rule shows that home care is a “real” job, deserving of respect and fair pay. Without this action,
we will struggle to provide quality care to an exploding population of seniors.
I/We urge you to implement this proposed rule to extend minimum wage and overtime protections to home
care workers.
Sincerely,
NAME
ORGANIZATION
ADDRESS