Connecticut has passed a paid family and medical leave law that will require employers to provide paid family and medical leave (CT PFML) benefits to employees who work in the state starting January 1, 2022. Premium collection to support these benefits will begin on January 1, 2021. The regulations and processes for the administration of the CT PFML law are still being developed by the CT Paid Family Leave Authority and the CT Department of Labor. In addition, the CT Insurance Department will also be involved in the private plan approval process.
We will soon be able to quote your CT PFML self-insured private plan alongside your already existing group benefits policy with us for ease of administration. At this time, we are evaluating our potential offering for fully insured administration and we will provide more information as we get closer to a decision on our full CT PFML offerings.
This site is created for our broker and employer Clients to help them comply with employer responsibilities under the CT PFML law.
Date: November 17, 2020
Time: 2 p.m. E.T.
Marjory Robertson, AVP & Senior Counsel, Abigail O’Connell, Senior Counsel and Jonathan Kemp, Product Management discuss what you need to know about Connecticut Paid Family and Medical Leave.
Maximum benefit amounts (tied to the CT minimum wage)
Employers: All employers with one or more employees
Does not cover individuals employed by:
The benefit amounts for CT PFML are as follows:
No, there is no waiting period for benefits.
*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:
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.
Sun Life will soon be able to quote your CT PFML self-insured private plan alongside your already existing group benefits policy with us for ease of administration. At this time, we are evaluating our potential offering for fully insured administration and we will provide more information get closer to a decision on our full CT PFML offerings.
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:
This content is not to be considered legal advice. We recommend Clients speak with legal counsel specializing in labor and employment law to ensure your organization has met all of the requirements under the Connecticut Paid Family & Medical Leave (PFML) Act.
When available, Sun Life’s self-funded or administrative-services-only CT PFML solution will be administered by Sun Life Assurance Company of Canada. This service is not insurance. When available, Sun Life’s fully-insured CT PFML coverage, will be issued by Sun Life Assurance Company of Canada. This content is not to be considered legal advice.
We recommend Clients speak with legal counsel specializing in labor and employment law to ensure your organization has met all of the requirements under the CT PFML law, and other applicable leave laws including but not limited to the federal FMLA and the CT FMLA.
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SLPC 30405 10/20 (exp. 10/21)