Effective October 1, 2025, the Connecticut Family and Medical Leave Act (CT FMLA) and the Connecticut Paid Family & Medical Leave Insurance Program (CTPL) will expand to cover non-certified employees of nonpublic elementary and secondary schools. Prior to this expansion, eligible private school employees were only covered under the federal Family and Medical Leave Act. 

What Does the CT FMLA Provide?

Similar to the federal FMLA, the CT FMLA allows eligible employees to take up to twelve weeks of job protected leave (plus an additional two weeks for incapacitation during pregnancy) in a twelve-month period for certain covered reasons.

How is the CT FMLA Different than the CTPL?

While the federal FMLA and the CT FMLA provide eligible employees with job-protected leave, the CTPL provides income replacement when a covered employee needs time off for the same qualifying reasons that an employee may take CT FMLA. The CTPL program is administered by the CT Paid Leave Authority, which is a quasi-public agency. Thus, the CT Paid Leave Authority will determine an employee’s eligibility for CTPL benefits, and not the School. 

School are responsible for designating and tracking leaves under the federal and CT FMLA. An employee is responsible for applying to the CT Paid Leave Authority to receive income replacement benefits. 

How is the CTPL Funded?

The CTPL is funded by employee contributions via payroll deduction. Therefore, Schools must deduct 0.5% of an employee’s wages each pay period, up to the Social Security Contribution Limit. This amount must be remitted to the CT Paid Leave Authority. 

What Employees are Eligible?

To be eligible for CT FMLA leave, an employee must have been employed by their employer for at least three months immediately preceding the first day of the leave. 

To qualify for CTPL benefits, a covered employees must have (1) earned at least $2,325 during the first four of the five most recently completed quarters and (2) been employed by an employer in the previous twelve weeks.

What Absences are Covered Under the CT FMLA and CTPL?

The CT FMLA and the CTPL cover all the absences that are protected under the federal FMLA, and more. For example, the definition of a “family member” is significantly broader under the CT FMLA and CTPL thereby allowing employees to take leave for a much broader list of family members. While leave taken under the federal FMLA and CT FMLA generally will run concurrently, this will not always be true in light of the different reasons an employee may take job-protected leave under federal and state law. 

What Should Schools Be Doing?

  • Register with the CT Paid Leave Authority and implement the required 0.5% payroll withholdings
  • Notify employees of these changes
  • Update leave policies to include the new CT FMLA requirements and inform employees of CTPL benefits
  • Review how other paid time off benefits will be coordinated with CTPL benefits
  • Update forms that are used to administer FMLA leaves, including the Notice of Employee Rights & Responsibilities and the Designation notice

For more information, please contact:

Nick Zaino
Partner
203.578.4270
[email protected]

Vincent Farisello
Partner
203.578.4284
[email protected]

This information is for educational purposes only to provide general information and a general understanding of the law. It does not constitute legal advice and does not establish any attorney-client relationship.