Background
Beginning January 1, 2021, all Connecticut employers, unless excluded by exception, were required to participate in the statewide Paid Family and Medical Leave insurance program, which we covered here and here. Employees were able to begin using these benefits effective January 1, 2022. The Connecticut Paid Leave (CTPL) program covers all employers with one or more employees and is accessible to all employees who have met certain earned-wage thresholds. Those who are self-employed or are sole proprietors are also eligible to opt-in to the program.
Summary
The state issued final proposed amendments which made changes to expand the existing Connecticut Family and Medical Leave Act (CTFMLA) beginning January 1, 2022. CTFMLA provides unpaid job-protected leave to qualified employees. One of the significant changes to the CTFMLA is that a covered employer is now defined as having one or more employees working in Connecticut; formerly, it was 75 or more employees. To be eligible to take leave under CTFMLA, employees must be employed for at least three consecutive months (previously it was 12 months) preceding the date of leave.
In addition, there were new changes implemented to the CTPL program that require action from employers. Pursuant to these proposed regulations, beginning July 1, 2022, employers must provide employees written notice of their rights and terms to use leave under the CTFMLA, their opportunity to file for wage benefits under the CTPL, as well as retaliation and complaint procedures. Employees must receive this notice upon hire and annually thereafter.
The state has published a model notice of employee rights under the CTFMLA and CTPL found here. Employers may use this notice or may create their own so long as all the components are outlined in any employer-created materials. Subject to the approval of these proposed regulations, it appears that employers may fulfill the notice requirement by including information in their employee handbook or other policy. At this time, there does not appear to be a requirement that this notice be acknowledged in writing or electronically by employees.
Employer Next Steps
- Employers who have not updated their leave policies, employee handbooks or new hire materials should take steps to do so promptly to satisfy these requirements.
- If you are a Full-Service or Virtual HR client and would like our assistance with updating your policy, please email us.
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This content is provided with the understanding that HR Knowledge is not rendering legal advice. While every effort is made to provide current information, the law changes regularly and laws may vary depending on the state or municipality. The material is made available for informational purposes only and is not a substitute for legal advice or your professional judgment. You should review applicable laws in your jurisdiction and consult experienced counsel for legal advice. If you have any questions regarding this content, please contact HR Knowledge at 508.339.1300 or email us.
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