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CT Paid Leave Authority staff finalize policy language to cover noncertified school employees
Summary
Staff presented consolidated policy revisions to implement expansion to noncertified school employees, clarifying wage-averaging, DSAP classification, employer policy for nonpublic schools, and primary-role wage inclusion; staff said the board will consider adoption next week.
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At a committee meeting, CT Paid Leave Authority staff presented consolidated policy revisions intended to implement the expansion of the paid-leave program to cover noncertified school employees.
Michael (staff, CT Paid Leave Authority) told the committee that the draft changes were primarily technical but included a key substantive clarification on how employers and the authority should average wages for school employees paid on different schedules. "The biggest one is... about the averaging of wages when a school employee is able to choose between, say, a 10‑month payment schedule or 12 months, in order to make sure there's equity," Michael said.
The policy language posted in July and the public comment window closed on Aug. 22, Michael said; outreach webinars for school employers produced questions staff incorporated into the redline. He identified three substantive clarifications added after public questions: treating positions filled under a durational shortage area permit (DSAP) as positions that require certification and therefore excluded from coverage while an individual is in training; allowing a nonpublic school employer to treat a position as certified if it has an affirmative employer policy requiring certification; and using the employee's primary role with a single employer to determine whether wages from that employer are included for coverage.
Michael told the committee the DSAP clarification is intended to avoid a situation in which an individual would be covered while in a temporary training placement and then lose coverage after becoming permanently certified. He said the nonpublic-school clarification is limited to cases in which an employer’s written policy requires certification.
When asked whether the language would delay implementation, Michael said staff do not expect any delay and that the revisions fall within the framework of the notice posted for public comment. He said staff plan to present the consolidated policies to the full board next week for official adoption, assuming no material public comments.
The committee had no substantive objections during discussion. The meeting record does not include the full roll call for the earlier vote that approved the agenda minutes; the Chair stated the motion carried.

