CT Paid Leave Authority staff review private-plan policy edits and list 2025 priorities

Staff for the CT Paid Leave Authority’s Policy & Personnel Committee reviewed proposed, non‑substantive edits to the authority’s private‑plan policies and presented a set of policy priorities the authority plans to work on in 2025.

The discussion focused on clarifying language in private‑plan materials that staff say do not change policy intent. Staff reported adding the word “date” to clarify that an employer moving from a private plan back to the public program must notify employees that they can file paid‑leave requests with the authority only after the plan’s termination date. Staff also added the phrase “of the earnings” to clarify a sentence describing the employee contribution limit as “one‑half of 1% of the earnings.” Michael, a staff member, said the two edits were “just sort of clarifying” and that no substantive comments were received during the notice‑and‑comment period.

The nut of the presentation was forward‑looking: staff told the committee they expect to bring the revised private‑plan policy language to the full board for adoption at the upcoming board meeting. Michael said the edits were intended to address technical clarity only and that “there were no other comments or questions for the policy.” An insurance carrier did ask a clarifying question during public comment but did not submit formal comment.

Staff also presented a preliminary list of policies they plan to address in 2025. Items identified for work this year included:

- Completing adoption of the private‑plan policy edits and finalizing changes to the employee handbook (staff said the employee handbook was in notice‑and‑comment and expected to be considered in February); - A statutorily prompted review of the authority’s bylaws (the last bylaws update was November 2022) and a parallel review of the plan of operations; - Enhancing the authority’s conflict‑of‑interest guidance to address non‑financial conflicts and to identify backup decision‑makers where staff discretion is exercised; - Revising the private‑plan audit guide, drawing on roughly two years of audit experience; - Developing rules for when a third party may file or manage paid‑leave claims on behalf of someone who is incapacitated or deceased (staff noted the existing third‑party authorization form but said they want guidance for unexpected situations where power of attorney paperwork is not available); and - Creating objective criteria that define when approval of private plans would “substantially select risks” or otherwise threaten the solvency of the family medical leave insurance trust, and what actions the authority would take if that scenario occurred.

On the solvency item, Michael emphasized the authority is not currently near any solvency threshold but said the authority should draft rules now “before we actually run into this issue” so the board has criteria if private plans ever present systemic risk. He told the committee the goal is to identify where discretion exists and ensure there are backups for decision points such as waiving penalties or handling appeals.

Staff described the procedural next steps: the board will consider formal adoption of the private‑plan policy edits at the next full board meeting, after which the authority will publish required notices for public comment. Michael explained that publication in the Connecticut Law Journal and the associated 30‑day comment period can create scheduling gaps that staff try to manage when returning revised policies to the committee for further edits.

Ending: Staff asked committee members to raise additional policy topics as they occur; no committee action was required in the meeting on the private‑plan edits, and staff indicated they will continue to shepherd the listed priorities through the notice and board adoption process.