September 2, 2025

WorkLife Law is proud to have submitted comments opposing the U.S. Department of Labor’s proposed rule, “Application of the Fair Labor Standards Act to Domestic Service.” This rule proposes stripping basic minimum wage and overtime protections from homecare workers – a critical segment of the workforce whose labor is already undercompensated yet is critical for the well-being of our children, people with disabilities, and older adults. The proposed rule perpetuates a long and troubling legacy of undervaluing care work necessary for our economy and communities to thrive.

WorkLife Law’s comment expressed our experts’ concern that the proposed rule will have a disastrous effect on care infrastructure– harming paid care workers, unpaid family caregivers, and care recipients alike. By lowering wages and protections for care workers, the proposed rule will cause fewer people to enter that profession at a time when our nation faces a critical shortage. This will result in increased struggle for unpaid family caregivers who will be unable to find care workers whom they can rely upon to provide high quality care for their loved ones at home.

“It’s deeply disturbing—though sadly not surprising—to see the current administration move to roll back essential protections for caregivers, whose critical work underpins our entire economy. The systemic devaluation of caregiving is deeply rooted in racism and sexism. This Proposed Rule threatens not only the livelihoods of paid caregivers but also risks a cascading impact on millions of unpaid family caregivers and care recipients who depend on them.”

-Leah Kennedy, Staff Attorney at WorkLife Law

The care workers who will be harmed by the proposed rule are disproportionately women, people of color, and immigrants. Unsurprisingly, unpaid family caregivers reflect similar demographics. Historically, caregiving has been devalued rather than compensated at a level that reflects that care is an essential part of our economy that allows it to function. Depriving paid care workers of federal minimum wage and overtime protections would effectively turn back the clock. 

WorkLife Law urges the Department of Labor to preserve the status quo under the current regulations that have been in effect for over 13 years. 

Our comment is available here.