Private Plans Updates: The Department of Family and Medical Leave recently revised their stance on an employer’s option for private plans. The DFML has stated that benefits under a private PFML plan that has been approved for an exemption do not have to begin until January 2021. Employers thus may receive approval of a private plan even though the plan does not provide paid leave benefits until January 2021, when the public programs leave benefits commence.

Under the DFML’s previous stance, a private plan would had to have provided benefits in advance of approval and applying for the exemption now would have required an employer to provide the paid leave benefits now, 18 months earlier than the public program’s benefits commence in January 2021.

The department also changed the deadline for the First Quarter in which the new leave is in effect (July – September 2019) for private plan exemption.  The deadline has been updated from June 30, 2019 to September 20, 2019.  This will provide time to avoid first quarter contributions for PFML.

Notice Update: Employers do not need to provide notification of the Paid Family and Medical Leave Act until June 30, 2019.  This date was moved from May 31, 2019.  A copy of the sample notice that was released by the agency is available here.

Next Steps: We are continuously monitoring this law and will provide updates as they are made available by the agency.  The effective date of July 1, 2019 has remained unchanged and we are still awaiting final regulations to be released. For the Compliance Alert that has more detailed information, please click here.

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This information is provided as a courtesy, may change and is not intended as legal or tax guidance. Employers with questions or concerns outside the scope of a Payroll Service Provider are encouraged to seek the advice of a qualified CPA, Tax Attorney or Advisor.