The Cook County Commission on Human Rights has issued its final regulations for the Cook County Earned Sick Leave Ordinance. The final regulations, which contain substantial changes from the draft regulations, can be found on the Cook County government website. The Cook County ordinance was passed on October 5, 2016, and will take effect on July 1, 2017. A model posting can likewise be found at the link above.

The City of Chicago passed a virtually identical sick leave ordinance on June 22, 2016, and it too will take effect on July 1, 2017. The City of Chicago issued draft regulations on May 22 and is accepting public comments through June 16 at 9:00 a.m. The City has not yet made a model posting available. The City’s draft regulations may be found on the City of Chicago’s website.

There are inconsistencies between the final County regulations and draft City regulations, and it remains to be seen whether the City will resolve those disparities in its final regulations. Among the issues is how the frontloading of paid sick leave for FMLA-covered employers should be calculated as well as the rounding up of carried-over sick leave under the two ordinances.

Employers should also be aware of the growing list of municipalities in Cook County that have affirmatively opted out of the sick leave ordinance, ostensibly due to the fact that the ordinance increases the cost of companies to do business within their boundaries. As of this writing, those municipalities include: Arlington Heights, Barrington, Bartlett, Bedford Park, Berkeley, Buffalo Grove, Burr Ridge, Elk Grove, Elmwood Park, Evergreen Park, Hanover Park, Harwood Heights, Hickory Hill, Hoffman Estates, Lynwood, Mount Prospect, Niles, Norridge, Northbrook, Oak Forest, Oak Lawn, Palatine, Palos Heights, Palos Park, River Forest, Riverside, Rolling Meadows, Rosemont, Schaumburg, South Barrington, Streamwood, Summit, Tinley Park, Western Springs, and Wheeling.