Enhancing support: The changing paradigm of paid sick leave programs
As more cities and states mandate employers to provide accrued paid sick leave to their employees, we are witnessing a trend of expanded benefits from places that already require sick leave. Today, 40+ locations require employers to provide paid sick leave, and many have enacted changes that will be live in early 2025.
These changes could be occurring for various reasons, such as increased awareness about the advantages of paid sick leave, addressing disparities in access, or the influence of the COVID-19 temporary legislation coming to an end. This is a dynamic area that employers need to stay informed about.
This blog post will focus on three existing programs, Connecticut, Michigan, and Washington, and how they are making changes for 2025.
Connecticut
Connecticut passed paid sick leave legislation in 2011, becoming the first state to require that employees earn paid sick leave from many employers. Earlier this year, Governor Lamont signed legislation expanding the sick leave law to make paid sick leave more accessible.
- Expands employers mandated to provide paid sick leave: The number of employers covered under Connecticut’s Paid Sick Leave (PSL) requirements will greatly expand. Currently, only employers with 50 or more employees and operate in specific industries (service workers) are covered. The changes for 2025 eliminate the industry limitations, such that all private-sector employers will be covered. This reduces the employee count to 25, which reduces further to 11 employees in 2026 and one employee in 2027.
- Reduces accrual rate: In 2025, employers must also provide sick leave at a faster accrual rate, which will change from one hour of accrued sick leave for every 40 hours worked to a 1:30 ratio.
- Expands reasons for leave: Employees will also be able to utilize sick leave for more covered reasons, including mental health of the employee or a covered relation, safe time for a covered relation (expanded from child), or closure of employee’s workplace, a covered relations school, or place of care due to a public emergency. In addition to the existing covered relations for which an employee can take sick leave, the updates will allow usage for the following expanded list of covered relations: adult children, an individual to whom the employee stood in loco parentis, the employee’s grandchild or grandparent, the employee’s sibling, and an individual related to the employee by blood or affinity equivalent to a family relationship.
These changes will be effective on January 1, 2025.
Michigan
Michigan currently requires employers to provide accrued paid sick leave to employees under the Paid Medical Leave Act (PMLA), but that will change as of February 21, 2025, when the Earned Sick Time Act (ESTA) replaces the PMLA. The ESTA is more employee-friendly, providing eligibility for more employees, a faster accrual rate, and broader covered leave reasons.
ESTA) | PMLA | |
What is the effective date? | Replaces the existing law and becomes effective February 21, 2025. | Current law, effective through February 20, 2025. |
What employers are covered? | All employers who employ one or more employees, excluding the U.S. government. | Employers who employ 50 or more individuals. |
What is the accrual rate? | Accrue one hour of sick leave for every 30 hours worked. | Accrue one hour of sick leave for every 35 hours worked. |
What is the maximum annual accrual? | 72 hours | 40 hours |
Can sick time be frontloaded rather than accrued? | Yes, employers may frontload 72 hours of sick leave. | Yes, employers may frontload 40 hours of sick leave. |
What is the maximum annual usage? | 72 hours | 40 hours |
What leave reasons are covered? | Sick time (employee or covered relation), safe time, and other time, including meetings at the child’s school or daycare, closure of the workplace or child’s school, or the need to quarantine. | Sick time (employee or covered relation), safe time, and other time, including closure of workplace or child’s school or need to quarantine. |
Which covered relations may an employee take leave for? | Child, grandparent, grandchild, parent, spouse (defined more broadly), and other individual related by blood or with a relationship equivalent to family. | Child, grandparent, grandchild, parent, spouse. |
Washington
Since 2018, employers have been required to provide paid sick leave to their employees under Washington’s Paid Sick Leave (PSL) program. Beginning January 1, 2025, the PSL program will feature a few updated definitions that will broaden its scope and applicability to more employees in more situations.
- Expanded covered relationships: Employees will be able to utilize paid sick leave to care for additional covered relations, including the employee’s grandchild or grandparent. The definition of the employee’s child is being expanded to include the child’s spouse, including son-in-law or daughter-in-law. In addition, employees will also be able to take time off to care for an individual who regularly resides in the employee’s home and is cared for by the employee.
- Expanded leave reasons: The covered reasons are also being expanded. Currently, sick leave may be used when a child’s school or place of care is closed for health-related reasons, but this will be expanded to include closures due to a declaration of emergency by the local, state, or federal government.
Summary
Employers with Connecticut, Michigan, and Washington employees should review their sick leave policies to ensure alignment with the updated requirements. Employers should also ensure that their systems and processes are aligned with changes to the accrual rates. Finally, HR and managers should be trained to ensure that employee sick leave requests are handled appropriately and in alignment with the updated requirements.
How can Marsh McLennan Agency’s Absence, Disability, & Life Practice help?
Please contact us for additional information on drafting your paid sick leave policies or to learn more about how MMA ADL can assist in understanding these programs.
Marsh McLennan Agency’s Absence, Disability, & Life Specialty Practice helps clients understand, integrate, measure, and manage leaves of absence, time away from work, disability, and life insurance programs. Specializing in absence for over 20 years allows us to help employers meet employee expectations, reduce compliance risk, and manage costs. We are here to be your trusted partner, allowing you to prioritize what truly matters – your people.
