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With no grand announcement, Connecticut quietly expanded employee’s paid sick time benefits. The Bill greatly expands the law’s reach.

Background

For those who are unfamiliar with Connecticut’s Paid Sick Time, it was the first mandatory paid sick time law passed by any state. In summary, the law required employers with 50 or more employees to provide 40 hours of paid sick time (“Sick Leave”) to employees. The 40 hours of Sick Leave accrued at a rate of 1 hour of sick time per 40 hours worked. Notably, the law, as originally written, did not apply to all workers—only “service workers.” Connecticut curiously interpreted service worker broadly, using the term as a de facto umbrella for all employees.

The New Law

The amendment liberalizes paid Sick Leave in a few critical ways:

• Service Workers Removed: The phrase service worker was removed and replaced with “employee.” This removes all doubt – every industry is covered.
• Improved Accrual: Now, Connecticut’s accrual rate is 1 hour of sick time per 30 hours worked.
• Decreased Employee Headcount Threshold: Connecticut also reduced the number of employees an employer must have to be covered. Over the next three years, Connecticut is going to reduce the employee threshold as follows:
  • Effective January 1, 2025: 25 or more employees.
  • Effective January 1, 2026: 11 or more employees.
  • Effective January 1, 2027: 1 or more employees.
• New Coverage: The amendment expands the reasons employees can utilize Sick Leave to include caring for a sick family member, public health orders, and caring for family members who are victims of sexual or family violence.
• New Protections: Employers cannot require an employee to find a replacement on days they use Sick Leave.
• Mergers and Transfers: Employees who are transferred to another division, entity, worksite, or even to a new owner must retain their Sick Leave without any interference.
• Record Keeping Requirements: Employers will have to keep records of (i) the number of hours of paid Sick Leave accrued by employees and (ii) the number of hours of paid Sick Leave used by employees during the calendar year. Most payroll systems can track both the accrual and use of sick time. Also, if employees are offered five days of any kind of paid time off, the law allows you to track the use of the first five days to satisfy the record keeping requirement. We believe this will meet employer obligations under the law.
• Notice: Employers need to provide employees with written notice of the new terms of this law by the latter of January 1, 2025, or their date of hire.
• Seasonal Employees: The amendment clarifies that “Employee” does not include Seasonal Employees. Seasonal Employee work one hundred and twenty days or less in any year.

There are other protections and requirements that this article does not discuss. If you are not currently in compliance with the mandatory Sick Leave requirements, you should work with counsel to devise a plan that works for your company.

Brody and Associates regularly advises management on complying with the latest local, state and federal employment laws.  If we can be of assistance in this area, please contact us at info@brodyandassociates.com or 203.454.0560