Connecticut Paid Family and Medical Leave (CT PFML)

Yes. Sun Life offers both fully insured and self-insured private plan administration for employers.

Employers: All employers with one or more employees

Does not cover individuals employed by:

• The federal government
• The state, municipalities, or local or regional boards of education, except to the extent their employees are covered employees
• Non-public elementary or secondary schools

Employees:

• Must have earned at least $2,325 during the employee’s highest earning quarter within the first four of the last five most recent quarters and must be one of the following:
  • Must be currently employed or
  • Have been employed within the prior 12 weeks, or
  • Is a self-employed individual or sole proprietor and Connecticut resident who has enrolled in the program

The benefit amounts for CT PFML are as follows:

• 95% of weekly earnings up to 40 times the minimum wage; plus 60% of earnings above 40 times the minimum wage. The total weekly compensation will be capped at 60 times the minimum wage.
• 60 times the minimum wage is equal to $900 weekly, increasing to $941.40 on January 1, 2024.
• Base weekly earnings is an amount equal to 1/26th of a covered employee’s total wages earned during the two quarters of the covered employee’s base period in which such earnings were highest. The base period is the first four of the five most recently completed quarters.

No, there is no waiting period for benefits.

• Bonding (birth, adoption or foster-care placement)
• Care for a family member with a serious health condition
• Employees own serious health condition*
• If an employee is a victim of family violence
• Care for an injured service member
• Serving as an organ or bone marrow donor
• Military exigency as defined by the federal FMLA

*The definition of serious health condition aligns with that used under the federal FMLA. Namely, a serious health condition is an illness, injury, impairment or physical or mental condition involving inpatient care or continuing treatment.

Covered family members include spouse, sibling, son or daughter, grandparent, grandchild or parent, or an individual related to the employee by blood or affinity whose close association the employee shows to be the equivalent of those family relationships.

Leave under the CT PFML law itself does not provide job protection. However, leave under the CT PFML law may run concurrently with unpaid job-protected leave under either the federal Family and Medical Leave Act (FMLA) or the CT unpaid FMLA, both of which provide job protection. It is important for employers to understand that this new CT PFML statutory requirements also amends the unpaid CT FMLA law and the requirements of both must examined together to fully understand the amount of leave that is available to employees and whether job protection attaches.

CT PFML is funded through employee payroll contributions (initial rate will be 0.5% up to the Social Security maximum). Employers may cover employee contributions though there are tax implications for employees at least if the employer participates in the state plan.

Yes. Employers may seek approval to meet their obligations of the CT PFML law through a private plan. If approved, premium contributions do not need to be made to the state’s Family and Medical Leave Trust Fund. In a private plan, employers may choose to supplement the employee-premium in order to offer enhanced benefits, a better employee experience, and greater access to reporting and data for the employer.

According to the Connecticut Paid Leave Authority, in order to qualify for a private plan you must:

• Offer at least the same number of weeks of benefits
• Offer at least the same level of wage replacement for each week of benefits
• Include no additional requirements or conditions
• Deduct the same amount from employee paychecks as the state plan
• Cover all employees through the duration of their employment
• Apply to all current and future employees at your business
• Be approved by a majority of your employees who work in CT, and also provide coverage for former employees for up to 12 weeks after termination of employment.
• Remain compliant with any additional requirements established by the CT Paid Leave Authority and the Department of Labor

Note: Private plans cannot present substantial risk to the solvency of the CT Paid Leave Authority trust fund.

The CT Paid Leave Authority is in the process of adopting processes and requirements related to private plans. We will update this FAQ as these are published. Visit the CT Paid Leave Authority Apply for an Exemption page for more information.

Yes, if employers choose to offer CT PFML through a private plan administrator and it is a self-insured plan then a bond may be required by the state. The amount of the bond is to be determined.

Yes. While the CT PFML law creates certain paid benefits for leave because of an employee’s own health condition or for covered caregiving reasons, the CT PFML law is not intended to replace benefits provided by employers through Short Term Disability (STD) plans and programs. It is important to know that cancelling STD benefits could leave your employees unprotected if they become disabled for these reasons:

1. Benefit amount for higher-income employees. The CT PFML max weekly benefit may be insufficient for high-income earners who require greater income replacement.
2. Consequences of combined 12 weeks of family and medical leave. If an employee takes 12 weeks of family leave in a 12-month period, the employee may be left without income replacement for their own serious health condition in the same timeframe.
3. Impact of intermittent leave. CT PFML can be taken intermittently so an employee may substantially reduce and/or exhaust their benefits be left without income replacement protection if they become seriously and continuously disabled thereafter.
4. Short-term disability may offer additional features and benefits. STD policies may include employee-facing features that improve their experience: first-day hospitalization, survivor benefits, and, most important, return-to-work and vocational rehabilitation programs. Employees can still access these features even if they are approved for both CT PFML and STD.