11.05.26
Paid Parental Leave Requirements
Under the amended Article XXIV of the Allegheny County Health Department’s Rules and Regulations, the paid parental leave mandate applies to employers situated or doing business within Allegheny County with 15 or more employees. The regulation defines a covered employee as an individual who performs work within Allegheny County for at least 80 hours during a regular and consecutive 12-month period, as determined by the employer.
The regulation excludes independent contractors, state and federal employees, temporary employees, seasonal employees, and members of specified construction labor unions covered by collective bargaining agreements.
To qualify, an employee generally must have been continuously employed for at least 180 days. Part-time employees must also have worked at least 625 hours during that period.
Eligible employees may receive up to 12 weeks of paid parental leave at their same base rate and with the same benefits the employee would have received while working, subject to a $4,200 weekly cap. Part-time employees are compensated based on their current rate of pay and their average weekly hours worked during the six-month period immediately preceding their request for benefits.
Leave is available following the birth or stillbirth of a child, adoption, or legal permanent placement of a child for adoption or foster care.
Following one year after the Effective Date, employers that fail to comply may be subject to penalties of up to $100 per day for each violation.
Coverage Questions for Remote and Traveling Employees
Although the regulation establishes an 80-hour threshold for work performed within the County, it does not expressly address how it applies to certain remote, hybrid, or traveling-work arrangements. Absent further guidance, employers should monitor developments and consult counsel, as appropriate, when evaluating employee coverage.
Interaction with Existing Leave
Employers that already offer paid parental leave through a private plan should ensure that the plan satisfies their obligations under Article XXIV. Article XXIV expressly prohibits individuals from waiving their rights under the amendment.
When an employee’s leave also qualifies under the federal Family and Medical Leave Act (“FMLA”), the leaves run concurrently when applicable, rather than automatically providing an additional 12 weeks following FMLA leave.
Sick Leave
The amendments also expands the County’s paid sick leave requirements by increasing the accrual rate from one hour for every 35 hours worked to one hour for every 30 hours worked, unless the employer provides a faster accrual rate, and increasing the annual cap for covered employers from 40 to 72 hours in a calendar year. The amendment also lowers the applicable employer-size threshold from 26 to 15 employees.
Next Steps
Employers with operations or employees working in Allegheny County should evaluate their coverage and determine whether their existing leave policies satisfy the new requirements. The amendment takes effect on April 20, 2027 (the “Effective Date”), and employers must comply within 180 days thereafter.
Employers should:
The County intends to provide additional guidance on coverage, eligibility, documentation, compliance, and enforcement before implementation.