Comment from American Hotel and Lodging Association
American Hotel and Lodging AssociationSupportTrade association
Summary: The American Hotel and Lodging Association (AHLA) supports the Department of Labor's proposed rule because it establishes a clearer, more predictable framework for determining joint-employer status based on actual control over employment terms. They specifically commend the rule's recognition that common hospitality practices—such as franchising, brand standards, and safety requirements—do not inherently establish joint-employer liability.
We submit the attached comments on behalf of the American Hotel and Lodging Association and pursuant to the U.S. Department of Labor Wage and Hour Division's notice of proposed rulemaking and request for comments regarding Joint Employer Status Under the Fair Labor Standards Act, Family and Medical Leave Act, and Migrant and Seasonal Agricultural Worker Protection Act.