Public Comment Opportunities on Overtime, Census 2020, and Title X

Man writing on paper (Unsplash)Our action items often focus on calling or contacting your legislators, but that's not the only way your voice can be heard. Another way to share your opinion and make a difference is through public comment.

Public comment periods give people the chance to articulate their opinions on proposed rules or laws and to offer advice on how they could be changed. You may speak up at a local town council meeting to discuss a proposed park in your neighborhood, or you might submit an electronic comment to show how a proposed rule would affect your life.

Taking part in a public comment period is an effective way to ensure legislation is implemented in a way that helps everyone affected. Your thoughts go directly to people making the rules, and those thoughts shape the final version of the law.

We have three ways to take action through public comment this week - on Overtime, Census 2020, Title X. Take a look and see what is interesting to you!


The Pennsylvania Department of Labor and Industry (DLI) proposed a new regulation requiring public comment. The proposed regulation would greatly expand eligibility for overtime pay in Pennsylvania. This regulation mirrors much of the overtime proposal under President Obama's Administration that was put on hold in the courts. It would do three things:
  1. Clarify the definitions of executive, administrative, and professional workers to make it much easier to figure out what kinds of job duties qualify under the exemption. 
  2. Raise the minimum salary threshold for the exemption from $23,660/year to $47,892/year within two years and then institute a formula to update the minimum threshold every three years going forward. 
  3. Allow employers to count nondiscretionary bonuses for up to 10% of the salary threshold (i.e. up to $4,789/year could be paid in bonuses).
Take Action:
  • Keystone Research Center and CLS put together sample comments you can use. 
    • If you submit comments, please send them by August 22 to Bryan M. Smolock, Director, Bureau of Labor Law Compliance, 651 Boas Street, Room 1301, Harrisburg, PA 17121 ( Comments can be sent by mail or email. 
    • Individuals can also submit shorter comments through a service set up by We the People available here
  • You can read a report from NELP on overtime in Pennsylvania here.

Census 2020

In March 2018, the Census Bureau was directed to add a question to the 2020 Census regarding citizenship status. This is a new question that may decrease responses to the Census, which in turn could affect funding and Congressional representation for the next ten years.

Take Action:
  • Write and submit public comment. The Leadership Conference on Civil and Human Rights has a toolkit including a comments template and talking points. The toolkit also includes a sample media alert and social media you can share.
  • Submit your comments through by August 7, 2018.

Title X

In June, new rules for the Title X Family Planning Program were released. These rules would expand requirements for grantees and could interfere with the patient/provider relationship, including the ability to make the legal referrals needed by a client. A number of health provider organizations, including AMA, ANA, ACOG, AAP, ACNM, ACP, APAOG, NPWH, NSRH, and SAHM, oppose the rule.

Take Action:
  • Comments can be submitted by July 31, 2018, on the Federal Register's website.
  • The National Partnership for Women and Families, ACOG, the American Academy of Nursing, and Doctors for America have partnered to create a public provider pledge at If you agree with their stance, please share it with healthcare providers in your network.


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