Administering the Approved Private Plan

Compliance

Timeline

An approved private plan is valid for 3 years from the date the plan was approved by the CT Paid Leave Authority (the first date for which the obligation to remit contributions to the Authority was waived) - or until the plan changes - whichever comes first.

Each employer that has been approved for a self-insured plan shall be required to update its surety bond on a yearly basis.

Reporting obligations

The CT Paid Leave Authority is required to report data to the public reflecting the performance of the CT Paid Leave program, including private plans. As a result, the Authority must collect certain information from each private plan on an annual basis.

Reports are due on May 15th of each year and reflect the private plan coverage and utilization for the prior calendar year.

There are 2 formats for the Report Template. Private plans may utilize either template when submitting their information to the Authority.

Reports must be uploaded to My Account. Instructions to upload documents are included in the Report Template.

Audits

The Authority is required to provide oversight of private plans and may require a private plan to participate in an audit. Audits ensure that the private plans are operating in compliance with the CT Paid Leave Act and the Authority’s established policies. An audit may address 1 or more of the following categories:

- The Private Plan Application Process
- The Solvency of the Private Plan
- Paid Leave Claims Review
- Contributions Withheld from Employees

The Authority will notify employers when they have been selected for an audit and set up a meeting to discuss the process.

PRIVATE PLAN AUDIT GUIDE

In order to comply with both the reporting and audit obligations, employers must retain records of the paid leave private plan, including all claims data and all communication provided to employees related to the plan.

Recordkeeping

In order to comply with both the reporting and audit obligations, employers must retain all records relating to the private plan, including employee communications and claims data. These records must be retained for at least three years from the termination of the private plan.

Changing Your Approved Private Plan

To make material changes to an approved private plan, a new application must be submitted, which means the employer must first educate employees about the changes and hold a vote on the proposed revised plan. Filing a new application shall not terminate the approved status of the previously approved plan.

Changes made in order to comply with the law, including but not limited to changes to the Connecticut Paid Leave Act and related policies, will not require a new vote or a new application, even if material.

Material Changes vs. Non-Material Changes

The determination of whether a change is material is based on the perspective of the employees.

Examples of Material Changes

(non-exclusive list)

Changes to the plan design related to benefit amounts or durations
Changes to the insurance carrier or claims administrator
Changes to the class of covered employees, including eligibility rules and waiting period for coverage
Changes to the rate of contribution for the employee
Changes to the method of determination of the 12-month benefit period
Changes in how accruals (paid time off, sick bank, etc.) are utilized

Examples of Non-Material Changes

(non-exclusive list)

Cosmetic changes to the plan, for example, logos, fonts, branding
Changes to the legal name or legal address of the employer, assuming no changes to the actual ownership of the employer
Changes to the contact information or method for filing claims
Changes that are the result of changes in an employee’s status
Changes to correct grammatical or typographical errors.

Important

If the CT Paid Leave Authority approves the proposed new private plan, the effective date of the new plan will begin a new three-year approval period.

Administer Approved Private Plans

Compliance

Changing Your Approved Private Plan

Material Changes vs. Non-Material Changes

Examples of Material Changes

Examples of Non-Material Changes

Important

Important

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