It is apparently the deadline that never is, but the January 14 deadline for new public comments on the joint employer rule was extended again last Friday by the National Labor Relations Board (NLRB). Under the terms of this latest extension, new public comments must be received by January 28, 2019 and responses to new comments have a deadline of February 11, 2019. The comment period on joint employer has been extended no fewer than 3 times thus far as the NLRB grapples with restoring the historic definition of joint employer. This latest extension results from a muddled decision by the US Circuit Court of Appeals for DC validating the process used by the NLRB in the Browning-Ferris decision, but striking down the result declaring Browning-Ferris a joint employer. In response, 48 members of the Congressional Progressive Caucus signed a letter to the NLRB asking that the agency reverse course on joint employer and re-establish the Obama era expansion of the definition. The initial NLRB decision in Browning-Ferris will impose significant costs over the long run on small businesses in general and franchise businesses in particular. This Wall Street Journal Op-Ed, authored by IFA President Robert Cresanti and US Chamber executive Neil Bradley, lays out the cost for franchise owners with undeniable clarity!