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CT Paid Leave outlines rule for averaging school pay schedules to determine benefit wages
Summary
CT Paid Leave Authority officials said the proposed rule averages annual wages across four quarters for employees with multiple payment schedules (10-month, 12-month, or 10-month plus a year-end payment) so similar employees receive comparable benefit calculations; comment instructions were provided.
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During the webinar, Amber Forrest and Michael Caesar explained how the Authority intends to handle benefit-wage calculations for school employees who are paid on different calendars.
Caesar described the core calculation rule used by the program: benefits are typically calculated using the two highest-earning quarters out of the four of the past five quarters as of the leave start date. To avoid different benefit outcomes for employees who receive the same annual pay but on different schedules, the Authority's proposed approach will average annual wages across four quarters when an employee has the option among multiple payment schedules (for example, 10 months, 12 months, or 10 months plus a large year-end payment). Forrest said this is intended to ensure employees receiving the same total annual compensation have comparable eligibility and benefit results.
Forrest noted the Authority has updated guidance and invited written comments on the revised consolidated policies; attendees were told to send comments to michael.caesar@ct.gov. The proposed rule language and the public comment period will determine the procedure and timeline for implementation.
Payroll and HR staff for schools should review the proposed guidance and the school-specific employer verification form the Authority will use, which asks whether a position requires certification and whether multiple payment schedules are available. That form will also ask about holidays, shutdowns and school breaks so the Authority can determine which days an employee would have been scheduled to work when calculating benefit payments.

