Comment from National Center for Law and Economic Justice

Summary: The National Center for Law and Economic Justice (NCLEJ) opposes the proposed rule, arguing that it improperly narrows the joint employer standard and undermines workers' access to statutory rights under the FLSA, FMLA, and AWPA. They contend that the rule favors employers who use subcontracting to evade liability and will disproportionately harm vulnerable workers, particularly women and people of color in "fissured" industries like home care and agriculture.