Benson, Robert

I employ over 120 W-2 home care workers at $11.83 per hour. They provide dedicated, compassionate care to the disabled seniors whom we serve. I fully support the proposal to require minimum wage for these wonderful workers. However, requiring overtime pay will cause unintended negative consequences for these employees: 1) They cannot support their families working only 40 hours a week, even on our above-minimum wage pay. Virtually all our full-time employees urgently seek longer hours. However the proposed rule would force us to limit employees to 40 hours, rather than pass on additional costs to our clients, who already pay as much as $100,000 or more a year. 2) The only recourse we otherwiuse will have are to a) Reduce our base pay, so that employees net the same with overtime, or b) Transition to a registry model (commonplace in our industry) using 1099's, where protections for both employees and consumers are lacking. The proposed rule will hurt everyone and help no one.