The Connecticut Paid Sick Leave Act, initially put into law in 2011, required employers with 50 or more employees to provide up to 40 hours of paid sick leave each year to eligible employees. This legislation has been recently expanded to have a wider impact on both employers and employees throughout the state.
If you’re an employer operating in Connecticut, here’s what you need to know, including a few potential pitfalls to avoid.
Key Changes to the Paid Sick Leave Law
Broader Coverage
The law will apply to a lot more employers! Currently, only businesses with 50 or more employees in specific sectors have to provide paid sick leave. Starting next year, this will start extending to more businesses based on the following schedule:
- January 1, 2025 - employers with 25 or more employees will be required to provide paid sick leave
- January 1, 2026 - employers with 11 or more employees will be required to provide paid sick leave
- January 1, 2027 - employers, regardless of size, will be required to provide paid sick leave
Another significant change is that the law now covers all private-sector employees rather than only “service workers” in certain occupations. There are some exceptions, however, like certain seasonal workers and specific construction trades.
Accrual Rates
Employees will now earn one hour of paid sick leave for every 30 hours worked, up to a maximum of 40 hours per year. This is more generous than the existing regulation, which requires one hour for every 40 hours worked. Employees can continue to carry over up to 40 hours of unused sick leave into the next year. In addition, employees will be able to use this benefit on their 120th day of employment.
Expanded Use
The reasons employees can use paid sick leave have expanded too. Employees can now use leave for mental health days, to care for a wider range of family members (including adult children, siblings, grandparents, stepparents and parent in-laws, and even those with a close, family-like bond), or during public health emergencies when workplaces or schools are closed.
More specifically, under the expanded law, employees can take paid sick leave for:
- An employee’s or employee’s family member’s illness, injury, or health condition;
- The medical diagnosis, care, or treatment of the employee or employee’s family member;
- Preventive medical care for the employee’s or employee’s family member’s mental or physical health;
- The employee’s own mental health wellness day;
- Certain purposes when an employee or employee’s family member is a victim of family violence or sexual assault, provided that the employee is not the alleged perpetrator; and
- A determination by a health authority, employer of the employee, employer of a family member, or a healthcare provider of whether an employee or employee’s family member poses a risk to the health of others due to exposure to a communicable illness, whether or not the employee or family member contracted the communicable illness.
Potential Pitfalls for Employers
Record-Keeping Requirements
The law requires employers to keep detailed records of sick leave accrual and usage for at least three years. These balances must be maintained on wage statements, which can be a big administrative task, especially for smaller businesses that might not have sophisticated payroll systems in place. Failing to maintain these records could result in fines and penalties.
Compliance and Communication
Employers need to ensure that employees are aware of their rights under the new law. All new hires after January 1, 2025, will be required to receive notice regarding this policy. Existing employees will also be required to receive a notice. Employers will also need to display posters in the workplace about employees’ paid sick leave rights.
Overlapping Leave Policies
For companies that already offer paid time off (PTO) or vacation days, it’s essential to ensure these policies align with the new requirements. While the law doesn’t require additional leave for businesses already offering 40 hours of PTO, these existing policies must meet the law's criteria.
Adapting to Phased Implementation
The phased rollout of the law’s requirements - starting with companies with 25 or more employees and eventually encompassing all employers - means businesses must stay updated and prepared for each phase. Small businesses need to be proactive in understanding when the new requirements will impact them and have a plan for compliance.
Constraints on Employee Coverage
Employers will not be able to search for a “replacement” employee while someone is out on sick leave, which can create some challenges associated with ensuring proper coverage for the business.
Restriction on Requesting Documentation
Most challenging, employers will be prohibited from requiring an employee to provide any documentation or proof that paid sick leave is being used for permitted purposes under the law.
Navigate the CT Paid Sick Leave Law Changes
Navigating the CT paid sick leave law changes will require careful planning and communication. Employers should review current leave policies, set up robust record-keeping practices, and educate their workforce to ensure smooth compliance with the new law.
Have more questions or need help? Call The Human Resource Consulting Group, LLC at 203-881-1755 or visit us at www.hr-consulting-group.com.
Author: Lisa Pollock
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Lisa Pollock is the Vice President & Chief Human Resource Officer at The Human Resource Consulting Group and oversees the HR Business Partner Group and HR Operations. She has more than 25 years of experience in human resources, with expertise in building infrastructures for growing businesses focusing on HR compliance, talent acquisition, and implementing best practices. Lisa has extensive experience in industries such as municipalities, non-profit organizations, manufacturing, professional services, and retail.
