Action Needed: Submit Comments on NJ DOL Proposed DWBR Regulations

​The New Jersey Department of Labor has released proposed regulations for the Domestic Workers Bill of Rights (DWBR), and the comment period is now open. We strongly urge all NJ members to review these proposed rules carefully and submit comments before the deadline.

Of particular concern is the requirement that employers obtain a signed written contract at the start of each workweek, which is impractical and burdensome for Health Care Service Firms. Another main point to highlight in your comments may be that our employees are Certified Home Health Aides (CHHAs), employed and supervised under the NJ Board of Nursing and Division of Consumer Affairs, and therefore are not domestic workers. The intent of this law was to protect individual household employees, not regulated health care workers employed by licensed Health Care Service Firms. Health Care Service Firms are already required to comply with extensive state and federal regulations, including those governing wage and hour laws, worker protections, and employment practices. These rules ensure that CHHAs receive all rights and protections afforded to employees, making many of the DWBR provisions duplicative and unnecessary for our industry.
 
We recommend that each agency:

1. Review the proposed regulations in full (linked here).
2. Consult your legal counsel for guidance on how these rules could impact your operations.
3. Submit formal comments to the NJ Department of Labor emphasizing that HCSFs are already governed by extensive licensing, accreditation, and wage/hour requirements that ensure worker protections.

Submit comments here: [email protected]
Deadline: November 1, 2025
 
For questions about this information, contact Dennis Marco, HCAOA New Jersey Lobbyist at [email protected]. Although this law has already passed in the NJ Legislature, this is an important opportunity to ensure our industry’s voice is heard. The more responses received from legitimate licensed providers, the stronger our collective message will be. Thank you for taking action and helping to protect the integrity of professional home care in New Jersey.
 
Warm regards,
Andrea Sussman
Chair, HCAOA New Jersey Chapter