Hawaii Employers Limited in Requiring Notice Under FMLA

The Hawaii Family Leave Law ("HFLL") regulationsHawaii employers covered by both federal and state
make clear that HFLL incorporates federal definitionslaw must understand the differences in the two sets
and interpretation of leave law under the Familyof laws, including the position taken by the federal
Medical Leave Act ("FMLA"), unless federal law is lessDOL that, "where an employer's usual and customary
favorable to the employee.notice and procedural requirements for requesting
Generally, FMLA applies to all private employers wholeave are consistent with what is practicable given
have 50 or more employees for each working day ofthe particular circumstances of the employee's need
20 or more (not necessarily consecutive) calendarfor leave, the employer's notice requirements can be
workweeks in the current or preceding calendar year.enforced." In addition, the current position of the
FMLA requires covered employers to allow eligibleDeparment is that the "flat two-day rule" under the
employees to take up to 12 weeks of unpaid leaveprevious regulations has been rescinded.
for the birth or adoption of a child, to care for a child,Thus, the determination of the adequacy of an
parent, or spouse who suffers from a "serious healthemployee's notice is driven by the individual facts and
condition," if the employee's own serious healthcircumstances, rather than an arbitrary two-day
condition makes them unable to perform one ortimeframe. The regulation itself also recognizes
more essential functions of the job, or for certainemployers' ability to enforce reasonable call-in policies.
qualifying exigencies. An eligible employee under FMLA"Where an employee does not comply with the
has been employed by the employer for 12 monthsemployer's usual notice and procedural requirements,
and has worked 1,250 hours during the preceding 12and no unusual circumstances justify the failure to
months.comply, FMLA-protected leave may be delayed or
Under HFLL, employers with more than 100denied" so long as the employer does not delay or
employees (determined in a manner similar to FMLA)deny leave where the employee provides timely
must comply with both FMLA and HFLL. Generally,notice as set by the regulation.
HFLL does not cover eligible employees that takeIn theory the employer is permitted to better plan
leave for their own serious health condition, but onlyfor staffing and operational needs by requiring an
leave taken for an employee's in-laws, grandparentsemployee eligible for protected leave to comply with
and reciprocal beneficiaries. HFLL provides only fournotice procedures. Employees will be encouraged to
weeks of leave instead of FMLA's 12 weeks. Ancomply with notice requirements knowing that the
employee eligible for leave under HFLL need only tofailure to do so could result in denial of protected
have been employed for six months for the coveredleave.
employer, regardless of the number of hours worked.