Connecticut Public Schools Face Major Leave Law Changes This Fall – A Guide for Schools

New Requirements for Non-Certified School Employees Take Effect October 1, 2025

Starting October 1, 2025, Connecticut public schools will experience a significant shift in how they handle employee leave benefits. Public Act 25-174 extends two key state programs—the Connecticut Family and Medical Leave Act (CT FMLA) and Connecticut Paid Family and Medical Leave (CT Paid Leave)—to employees of “public school operators”[1] whose positions do not require a license under Chapter 166 of the Connecticut General Statutes (hereinafter referred to as “non-certified school employees”). This change represents a major expansion for public school operators (hereinafter “schools”), which have been largely exempt from these requirements until now.[2]

The new law affects a broad range of school personnel, including custodians, paraprofessionals, cafeteria staff, administrative personnel, and anyone else whose position does not require professional certification. Importantly, these changes do not impact certified school personnel, who will not be eligible for CT FMLA or CT Paid Leave unless their union has collectively bargained with their employer to participate in such programs.

Understanding the Two Different Programs

The expansion involves two distinct but complementary programs that schools must now navigate.

• CT FMLA provides job-protected unpaid leave, functioning similarly to the federal FMLA but with some important differences, including but not limited to who is a covered family member under the law. Under CT FMLA, eligible employees can take up to 12 weeks of unpaid leave in a 12-month period for qualifying reasons, with an additional 2 weeks available for certain pregnancy-related conditions. The key benefit here is job protection—employees have the right to return to their same position or an equivalent one when their leave ends.
  
  
• CT Paid Leave operates differently, focusing on income replacement rather than job protection. This program provides eligible employees with partial wage replacement during their leave, funded through a 0.5% payroll tax deducted from employee paychecks. Importantly, CT Paid Leave does not provide job protection on its own—employees must rely on CT FMLA, federal FMLA, or other applicable laws for that security. Although employers are responsible for ensuring the appropriate payroll deduction, the Connecticut Paid Family and Medical Leave Insurance Authority (Authority) is the state agency that administers this program.

These programs often run concurrently, with employees potentially receiving both job protection through CT FMLA and income replacement through CT Paid Leave. However, the application processes differ significantly. For CT FMLA, employees apply directly to their employer for job-protected leave. For CT Paid Leave, employees must apply directly to the Authority, not their employer, for income replacement benefits.

As such, the Authority—not the employer—decides if an employee qualifies for income replacement and makes all eligibility determinations and benefit calculations for CT Paid Leave. Schools are not involved in approving or denying these benefits, though they may need to provide employment verification or other documentation to support employee applications.

Eligibility Requirements

The eligibility requirements for each program reflect their different purposes and funding mechanisms.

• For CT FMLA, non-certified school employees need only to have worked for the public school operator for at least three months during the previous twelve-month period. Unlike federal FMLA, there's no minimum hours’ requirement for the CT FMLA, making it more accessible to part-time and seasonal employees.
  
  
• CT Paid Leave has different eligibility criteria tied to wage earnings. Non-certified school employees must currently work for the school or have worked within the 12 weeks immediately before their need for benefits began. Additionally, they must have earned at least $2,325 during their highest-earning quarter within the designated base period.

Recognizing that school employees often have unique employment patterns with summer breaks and seasonal variations, the law allows the Authority to establish alternative calculation methods specifically for non-certified school employees. This is particularly relevant for schools with seasonal staffing. The Authority is currently developing special calculation methods to account for the unique employment patterns of school personnel, including summer breaks and intermittent work schedules. These guidelines should provide clarity on how base periods and benefit eligibility will be determined for employees who don't work traditional year-round schedules.

Qualifying Reasons

Both CT FMLA and CT Paid Leave cover the same core qualifying reasons for leave. These include the birth or placement for adoption or foster care of a child and care for that child within the first year, caring for a family member with a serious health condition, the employee's own serious health condition, serving as an organ or bone marrow donor, addressing certain military family exigencies, and caring for seriously injured or ill military family members.

Notably, CT Paid Leave may be available for one additional qualifying reason: addressing issues arising from being a victim of family violence or sexual assault.

Financial and Administrative Implications

The financial impact on schools varies between the two programs. CT FMLA imposes no direct costs on employers, though schools will need to manage the administrative burden of processing leave requests and ensuring compliance.  CT Paid Leave requires more active financial management, as schools must deduct the 0.5% payroll tax from all non-certified school employee paychecks and remit these contributions to the Authority on a quarterly basis.

Beyond the direct costs, schools face significant administrative challenges. They'll need to establish systems for tracking and transferring contributions to the Authority, which may require coordination with payroll departments or external vendors. The quarterly reporting requirements and the need to maintain records for at least three years add ongoing compliance obligations.

Schools will also need to coordinate these new programs with existing paid time off (PTO) policies. Under CT Paid Leave, employers may require employees to use accrued PTO concurrently with CT Paid Leave benefits, provided the total compensation doesn't exceed the employee's regular rate. Similarly, CT FMLA allows employers to require the use of accrued PTO during leave, though employees must be allowed to retain at least two weeks of accrued time off. This means schools will need to carefully track and calculate how PTO policies interact with these new leave programs.

Other Conforming Changes Relevant to Public Schools

Current state law requires that boards of education provide benefits equal to those provided by the federal FMLA to non-certified school employees who have been employed by the board for at least twelve months and worked at least 950 (rather than 1,250) hours for such board in the previous twelve months. Effective October 1, 2025, the new law removes the lower work-requirement threshold for these employees. Therefore, effective October 1, 2025, all school employees will need to meet the 12 months of employment and 1,250 work hours requirements in order to be eligible for federal FMLA benefits.

Interaction Between Federal FMLA and CT FMLA

Interaction between various laws is one of the most complex areas schools will need to navigate. The leave benefits and programs can run concurrently, with the more favorable provisions applying to the employee. However, eligibility requirements differ significantly—federal FMLA requires twelve months of employment and 1,250 hours worked, while CT FMLA only requires three months of employment with no hours requirement. This means some employees may qualify for CT FMLA but not federal FMLA, or vice versa.  

Additionally, CT FMLA covers more qualifying reasons than federal FMLA, creating situations where employees might have state-level job protection for circumstances not covered by federal law.

Immediate Steps for Compliance

With the October 1, 2025 effective date approaching, schools need to begin preparation immediately.

• The first critical step is registering with the Connecticut Paid Leave Authority, which can be done through its website at ctpaidleave.org. This registration process includes understanding the quarterly wage reporting requirements and establishing the necessary record-keeping systems.
  
  
• Schools should also begin updating their payroll systems to accommodate the new 0.5% tax deduction for their non-certified school employees. This may require working with payroll providers to ensure proper withholding and remittance procedures are in place.
  
  
• Policy updates represent another major area of preparation. Employee handbooks and leave policies will need comprehensive revision to reflect the new eligibility criteria and benefit structures. These updates should clearly explain which employees are subject to CT FMLA and CT Paid Leave, as well as how CT FMLA and CT Paid Leave interact with each other and with existing federal FMLA coverage, as the interplay between these programs can be complex.

Training and Communication Strategies

There are a number of important training and communication strategies that should also be implemented.

• Human resources personnel will need extensive training on the new laws and regulations to effectively manage leave requests and maintain compliance. This training should cover not only the technical requirements but also the practical aspects of coordinating multiple leave programs and managing employee expectations, particularly given that certified employees and non-certified school employees will have access to different leave benefits.
  
  
• Employee communication is equally important. Schools must inform eligible employees about their rights and benefits, including eligibility requirements, application processes, and anti-retaliation protections. These communications will look different for certified and non-certified school employees, and communication should be ongoing rather than a one-time announcement, as employees may need reminders and clarification as situations arise.

Notice Requirements

Schools must provide notices to employees about their leave rights, including posting required notices about leave entitlements and providing individual notices when employees request leave or when the school has reason to believe an employee may need leave benefits. Under the CT FMLA, non-certified school employees must, in turn, provide advance notice to their employer when leave is foreseeable, following the same general principles as federal FMLA.

Navigating Complex Interactions

As noted above, one of the most challenging aspects of compliance will be managing, for non-certified school employees, the interaction between federal FMLA, CT FMLA, and CT Paid Leave. These programs can run concurrently, but they don't always align perfectly.

The timing of benefit entitlements adds another complexity, particularly given the October 1, 2025 implementation date. Schools will need to carefully track how different leave entitlements interact and ensure employees receive the most favorable treatment available under applicable laws.  It may make sense to start tracking this at the beginning of the school year rather than waiting for the official change to the law. 

For schools with unique employment patterns, such as those with significant seasonal variation or complex staffing arrangements, the calculation of base periods and benefit eligibility may require special attention. The Authority's development of alternative calculation methods for school employees should provide helpful guidance, but schools may need to adapt their practices as these guidelines become available.

Looking Ahead

As Connecticut schools prepare for these changes, the focus should be on building sustainable compliance systems rather than simply meeting the minimum requirements. What does this entail? This means establishing clear policies, training staff thoroughly, and creating systems that can adapt as regulations and guidance evolve.

Schools should also consider the broader implications of these changes for their employment practices and employee relations. The expansion of leave benefits for non-certified school employees may affect recruitment and retention, particularly for positions that have traditionally offered limited benefits. Understanding these broader impacts can help schools develop comprehensive strategies for managing their workforce under the new requirements.

Given the complexity of these changes and their significant impact on school operations, most schools will benefit from legal counsel during the implementation process. This is particularly important for policy development, compliance planning, and staff training to ensure that schools not only meet their legal obligations but also create positive experiences for employees who need to use these benefits.

The October 1, 2025 deadline will arrive quickly, making immediate action essential. Schools that begin preparation now will be better positioned to implement these changes smoothly and maintain compliance with Connecticut's expanded leave requirements. The investment in proper preparation and systems will pay dividends in reduced administrative burden and improved employee relations as these new programs become part of the regular operational landscape.

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[1] Public school operators include local and regional boards of education, interdistrict magnet school operators, state and local charter schools, endowed and incorporated academies, and cooperative arrangements between multiple boards of education.

[2] Under the current and revised laws, if a board of education’s employees collectively bargain be covered by CT Paid Leave, then all of the board’s employees who are not in a bargaining unit also become covered by the program.