CT Expanded Paid Sick Leave

In case you missed it, the CRA & Ryan O'Donnell of Pullman & Comley held a CRA Engage Webinar: Understanding the New CT Paid Sick Leave Law. Below, you can find key takeaways from the new law, webinar recording, and presentation.

Watch Webinar Recording View Webinar Presentation

 
Who does this NOT apply to? (Exempt)

• Seasonal employees (Defined as an employee who works 119 days or less in any given year).
• Self-employed individuals

Accrual of Paid Sick Leave

• The employee accrues sick leave at a rate of 1 hour of paid sick leave for every 30 hours worked* by the employee. *Does not accrue during paid or unpaid time off
• Accrual begins January 1 or first day of employment.
• Accrual begins on day one, but employees can only use accrued hours 120 calendar days after their date of hire.
• Employee can only use a total of 40 hours of sick leave per year (40 is cap.). 

Key Takeaways

The verbiage of the new statute is broad, in that it states that employees may take paid sick days for own illness, injury, or health condition including mental/self-health care. The statute also expands to cover employees who care for family members (see PowerPoint for details).
 
This may affect a business’s “call out” policy in that there is NO advance notice requirements for use of paid sick leave – employees may opt to use paid sick leave as soon as “practicable”. NOTE: This means that if your business has requirements within any contract, handbook, etc., for an employee to provide notice within a certain number or hours of calling out or requesting time off, these need to be revised ASAP in accordance with state law.
 
Employers must disclose this new policy & information to all employees no later than January 1, 2025 (or upon hire) by means of written notice and labor poster.

Key Questions & Answers

When does the tracking of the accrued hours start?
Tracking of accrued hours begins January 1 of the calendar year, or their first day of employment.
 
Are part-time employees eligible? 
Yes. The accrual is not based on full-time status; rather, any covered employee must be allowed to accrue paid sick leave hours based on the hours worked.
 
If an employee quits or is terminated, are they owed the accrued hours? 
No.

Do employees get their normal hourly pay for the sick leave hours they use?
It depends. Each employer must pay either the normal hourly wage for the employee or the minimum fair wage rate under CT General Statutes Sec. 31-58, whichever is greater.

Can an employee swap shifts with a coworker in lieu of using paid sick leave?
An employee can swap shifts with a coworker instead of using paid sick leave, but it must be both voluntary and mutually consented to by the employees and the employer. 

Operators are encouraged to reach out to their POS System providers and/or Payroll Service providers, as these companies may have plans in place to track and document employee hours and Paid Sick Leave accrual and usage.

Helpful Links

• CT DOL Mandatory Labor Posters | Poster English | Poster Spanish (Employees must display English and Spanish posters in conspicuous and accessible areas)
• CT DOL Model Written Notice for every employee (Recommend to include notice in Employee Handbook)
• Pullman & Comley Blog Article on Expanded Paid Sick Leave
• CT DOL Paid Sick Leave FAQ

If you have questions, members are advised to consult with legal counsel. A reminder that CRA members receive complimentary consultations with Ryan O’Donnell as a benefit of membership, as well as special member pricing on legal services. Thank you to Ryan for being such an invaluable resource to our members. Click here to email Ryan.