Connecticut’s updated Paid Sick Leave becomes effective January 1, 2025 and now is the time for most employers to update their policies and procedures. I’ve previously written about it here so I thought for this article, I’d focus on the key aspects of what employers need to know right now.
Here are the key points:
Changes to Connecticut Paid Sick Leave Law (Effective January 1, 2025)
- Who Needs to Comply:
- Public and private employers with at least 25 employees.
- Employers with 25-49 employees and manufacturers must comply for the first time.
- Larger employers already complying may need to update policies.
- Covered Employers:
- Previously applied to employers with 50+ employees.
- From January 1, 2025: Applies to employers with 25+ employees.
- From January 1, 2026: Applies to employers with 11+ employees.
- From January 1, 2027: Applies to all employers, even with just one employee.
- Manufacturers and certain non-profits are now included.
- Exclusions: Certain construction multiemployer health plans and self-employed individuals.
- Covered Employees:
- Previously applied only to “service workers” (certain hourly employees).
- Now covers almost all employees, exempt and non-exempt.
- BUT, seasonal employees (working fewer than 120 days/year) are excluded.
- Day or temporary workers’ coverage depends on working fewer than 120 days/year.
- Leave Accrual and Access:
- Old rate: 1 hour of paid sick leave for every 40 hours worked.
- New rate: 1 hour of paid sick leave for every 30 hours worked.
- Exempt employees presumed to work 40 hours/week unless otherwise.
- Employees can use paid sick leave starting on the 120th calendar day of employment.
- Employers can provide leave through accrual or a lump sum.
- Carryover required unless a lump sum is provided at the start of the year.
- Expanded Leave Reasons:
- Leave can be used for more than just the employee’s illness.
- Now includes leave for the employee’s spouse, sibling, child, grandparent, grandchild, parent, or close associates.
- Covers foster, adoptive, step, and in-law relations.
- Additional reasons: Public health emergency closures, exposure to communicable illnesses.
- Employee Notice and Documentation:
- Employers can no longer require advance notice or documentation for leave.
- Recordkeeping:
- Employers must post notices in English and Spanish.
- Written notice to be provided to each employee by Jan. 1, 2025, or date of hire.
- Employer to keep records of accrual and use of paid sick leave for at least three years.
- Miscellaneous Provisions:
- Sick leave can be provided through PTO programs if accessible for all purposes.
- Employees retain paid sick leave if transferred or if employment is assumed by a successor.
- Unionized employers must comply with this law, even with different collective bargaining terms.
As you can see from the above list, the changes that have been made are sneaky in their expansiveness. While some employers who have been providing PTO may not be impacted as much by this, my expectation is that most employers will have to tweak their existing policies — particularly on items such as seeking advance notice or documentation.
Consult with your HR experts or attorney to see if your policy needs an update.