As VDOLI drafts regulations for the new paid sick leave law, I urge the Department to prioritize two things:

1. A fast, low-barrier appeal process. Workers denied leave shouldn't have to hire a lawyer or lose pay while waiting. The regulations should set clear timelines for reviewing disputed denials through a simple administrative complaint process.

2. Tight, specific definitions. Terms like "reasonable documentation" or valid reasons to question a request should be clearly defined in the rule itself and not left to employer discretion. Vague language becomes a loophole, and the workers who most need this leave are least able to fight a wrongful denial.

Employers should also be required to give a written reason for any denial, so there's a record to appeal.

Thank you for the opportunity to comment.