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CT Paid Leave Authority staff outline policy changes to implement Public Act 25-174, propose alternate earnings calculation for school employees
Summary
Staff recommended revisions to implement Public Act 25-174, extending mandatory participation to certain non‑certified school employees and proposing an alternate method that evens annual pay across four quarters to avoid disparate paid‑leave outcomes caused by pay schedules; the board will be asked to post the rules for public comment ahead of an October 1st implementation window.
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The CT Paid Leave Authority heard a staff presentation recommending revisions to its consolidated policies to implement Public Act 25‑174 and to add an alternate earnings calculation for certain school employees.
Michael presented the changes and urged a faster-than-usual timeline so the authority could finalize rules before October 1st. “If we want to get this all said and done by October 1st, we kind of have to move a little bit faster than we normally would,” Michael said. He told the committee the legislation makes certain employees of public school operators and non‑public elementary and secondary schools mandatory participants as of that date, while employees in positions that require certification remain exempt unless covered through collective bargaining.
The most significant operational change staff proposed is an alternate calculation for employees who work only during the school year and are paid on differing schedules. Michael explained the method as taking an employee’s annual earnings across the four quarters and evenly dividing that total across the quarters so a worker paid over 12 months and one paid over 10 months would generate the same quarterly figures for benefit calculation. “Take their annual earnings across the four quarters and evenly divide them across the four quarters,” Michael said. He showed examples in which three employees earning the same annual salary could receive markedly different weekly paid‑leave benefit amounts under the current formula — a gap approaching $150 per week in the scenarios presented.
Committee members asked about fiscal impact and scope. Holly Williams said aligning similarly situated employees is logical and unlikely to materially affect the fund’s projections: “I just kind of want to say that out loud… it’s likely not to have a material effect on the fund,” she said. Staff cautioned that, absent an alternate calculation, employees with the same annual pay but different pay schedules could generate higher benefits that are not matched by higher contributions, which could harm fund stability.
Staff also proposed a new employer employment‑verification form so employers can confirm whether individual employees are in certified roles (and therefore exempt) or non‑certified roles (and therefore newly covered), and to collect payroll cadence information needed for the alternate calculation. The draft policy allows private-plan employers to adopt a similar smoothing calculation but does not require it.
Michael said the authority will post the redlined policy for public comment if the board approves posting at its next meeting and will include an explanatory notice describing the calculation and its rationale. The committee received general support for forwarding the revisions to the board for notice and comment.
The authority did not take a final vote on the policy changes at this meeting; staff said the goal is to have rules in place prior to the law’s October 1st effective date so employers and newly covered employees understand the verification and calculation process.

