The Race to the Finish Line on Paid Sick Leave
Judging by the rush of calls and e-mails the last few weeks, many employers are finally understanding the scope of the state’s revised Paid Sick Leave law. But before you go off and go skiing (and find yourself face to face with a dog as I did a few years back), there’s still work to be done.
The CTDOL has helped by putting out a FAQ on the subject. (Of course, you can also listen a podcast we did a few weeks ago.) And still, there are plenty of questions that remain unanswered. For example, suppose an employer offers extra pay for a shift one day a week. If an employee calls out sick for that day, how is the sick leave to be credited and paid?
For employers that haven’t been paying enough attention, there’s still time this week to make some adjustments and then play catchup later.
Here are three steps to consider taking now:
- Post a Notice: The law requires employers (with 25 or more employees) to post a notice for employees by January 1, 2025. Fortunately, the DOL has already printed a sample poster that employers can just copy and post. You can find it here.
- Consider Front-Loading Paid Time Off: The law has a lot to track — accruals, absences, etc. But in the CTDOL guidance, there’s this line: Employers will be deemed to be in compliance with this law if they offer paid time off that either meets or exceeds the requirements of the statute, meaning accrual and use rates, and reasons for the need for leave, etc. Thus, as a practical matter, if you front-load the 40 hours of paid time off each year, typically on or around January 1st and employees can take time off for any reason (including those under the PSL law), you should be deemed in compliance. Of course, there are nuances to this so be sure to talk with your legal counsel before implementing.
- Do Something: It can be easy to just feel overwhelmed by what is needed here but take simple steps to start including by learning more about the subject. The CTDOL has posted all sorts of materials on its website including a webinar. Take the time this week to get up to speed on some of the details and start work such as updating any policies you may have.
This law can amount to one of the biggest changes that HR and employers have had to worry about in years. But don’t be overwhelmed by it. Talk with your trusted advisors and get to work. There’s still time to make adjustments.
