Feb

The Paid Family and Medical Leave (PFML) landscape has become increasingly complex as states propose a variety of paid leave laws across the country, even though there were no new mandatory programs enacted in 2024. Multiple states are, however, working to finalize regulations and establish their PFML programs, beginning to collect contributions in 2025, and preparing to pay benefits in 2026. In addition, while various federal programs have been proposed with the goal of aligning practices across states, there has been little movement; and we expect, with the new administration, the stalemate will continue.

Outside of New England, California, Colorado, Delaware, Hawaii, Maryland, Minnesota, New Jersey, New York, Oregon, Puerto Rico, Washington, and the District of Columbia have mandatory paid family and/or medical leave laws in place. Employers should be aware of all paid leave laws for the jurisdictions in which they have employees working and ensure they comply with any and all applicable regulations.

The recent experience of state PFML programs in New England is detailed below.

Connecticut

The Connecticut Paid Leave Program has now been in effect for three years. The program continues to grow, as shown in the summary below.

Connecticut Paid Leave	FY 2022¹ (12/1/2021 – 5/31/2022)	FY 2023² (6/1/2022 – 5/31/2023)	FY 2024³ (7/1/2023 – 6/30/2024)
Total Applications	44,127	90,393	91,883
Denial Rate	40%	30%	25%
Percent of Approved Claims by Leave Reason⁴	44% medical 18% pregnancy/ childbirth 29% bonding 9% care for a family member <1% family violence, organ/bone marrow donation, and military 45% medical 19% pregnancy/ childbirth 27% bonding 9% care for a family member <1% family violence, organ/bone marrow donation, and military 53% medical 18% pregnancy/ childbirth 16% bonding 12% care for a family member <1% family violence, organ/bone marrow donation, and military
Average Claimant	Claimants aged 26-41 had the most approved claims (53%) 65% of claimants were female, 32% males, 0.1% non-binary, and the remainder did not specify gender Claimants aged 27-42 had the most approved claims (52%) 64% of claimants were female, 34% males, 0.25% non-binary, and the remainder did not specify gender Claimants aged 28-43 had the most approved claims (48%) 63% of claimants were female, 34% male, 0.16% non-binary, and 2.4% did not specify gender
Average Weekly Benefit	$562	$729	$707
Claim Decision Turnaround Time from Receipt of Completed Claim File	--	5 days	93% of claims decisions made within 5 days of receipt of a completed claim file
Average Duration	6.79 weeks	6.82 weeks	7.78 weeks
Approved Benefit Payments	$81 million	$294 million	$379 million

CT Paid Leave Changes as of January 1, 2025
Based on the Paid Leave claims experience, Connecticut is not making any major changes to the program in 2025. The contribution rate will remain at 0.5% up to the Social Security wage contribution cap, which is increasing to $176,100 in 2025, up from $168,600 in 2024. In addition, the CT minimum wage increases to $16.35 in 2025, from $15.69 per hour in 2024, which results in an increase of about $40 for the maximum weekly benefit, now $981.00 ($941.40 in 2024).

Maine

Maine's Governor signed the state’s PFML program into law in 2023.

Contributions to Maine’s PFML program began January 1, 2025. Benefits do not become available until May 1, 2026. Additional information can be found on the State’s Department of Labor website.

Massachusetts

Over the past four years, the Massachusetts PFML program has evolved as benefit limits, contribution rates, reporting requirements, and more have been adjusted.

The number of applications for the MA state PFML program has increased annually, as well as the number of approved claims. While benefits paid in 2024 increased, some improvements have been made, namely a reduction in processing times from the state and a reduced average duration across the board.

Massachusetts Paid Family and Medical Leave	FY 2021⁵ (1/1/2021 – 6/30/2021)	FY 2022⁶ (7/1/2021 – 6/30/2022)	FY 2023⁷ (7/1/2022 – 6/30/2023)	FY 2024⁸ (7/1/2023 – 6/30/2024)
Total Applications (Approved + Denied)	53,429	140,038	171,219	211,887
Denial Rate	23%	20%	16%	15%
Percent of Approved Claims by Leave Reason	58% medical 42% bonding <1% military Note: care for a family member not available until 7/1/21	59% medical 31% bonding 10% care for a family member <1% military 63% medical 27% bonding 10% care for a family member <1% military 64% medical 24% bonding 12% care for a family member <1% military
Average Claimant	Claimants aged 30-39 had the most approved claims (44%) 57% of claimants were female, 28% male, 15% unknown, and 0.06% non-binary Claimants aged 31-40 had the most approved claims (40%) 61% of claimants were female, 35% male, 4% unknown, and 0.21% non-binary Claimants aged 31-40 had the most approved claims (38%) 61% of claimants were female, 36% males, 2% unknown, and 0.25% non-binary Claimants aged 31-40 had the most approved claims (37%) 61% of claimants were female, 36% males, 3% unknown, and 0.25% non-binary
Average Weekly Benefit	Medical leave: $699.00 Family leave: $705.98 Medical leave: $754.84 Family leave: $793.55 Medical leave: $791.36 Family leave: $774.01 Medical leave: $824.63 Family leave: $892.31
Median Turnaround Time for Initial Decision	17 calendar days	17 calendar days	17 calendar days	13 calendar days
Average Duration⁹	10.7 weeks	12 weeks	9.4 weeks	8.7 weeks
Total Benefits Paid	$168 million	$603 million	$833 million	$1.05 billion

MA PFML Changes as of January 1, 2025
The MA PFML weekly maximum benefit amount increased effective January 1, 2025. The maximum weekly benefit is $1,170.64 in 2025, compared to $1,149.90 in 2024. The higher maximum applies for any leaves with a benefit year beginning January 1, 2025, or later.

The total contribution rate of 0.88% will remain unchanged in 2025. For employers with 25 or more covered individuals, the medical leave contribution is 0.70%, with employers funding 0.42% and employees responsible for up to 0.28%. The family leave contribution is 0.18%, with employers able to collect the total contribution from employees. Employers with less than 25 employees are not required to submit the employer portion of premiums, so the effective total contribution rate is 0.46%.

New Hampshire

New Hampshire began paying benefits for the first Voluntary PFML Plan in the nation on January 1, 2023. While state workers are automatically covered, private employers may purchase coverage through the State’s insurance carrier partner, MetLife, and receive a 50% Business Enterprise Tax (BET) Tax Credit. Individuals who are not covered by a NH PFML plan or equivalent plan may purchase individual plan coverage.

The experience of the first year of the program is outlined below.

New Hampshire Paid Family and Medical Leave	2023¹⁰
Number of Enrolled State Workers	8,862 workers
Number of Group Policies	217 group policies, 5,372 workers
Number of Individuals Enrolled	192 employers, 478 workers
Total Claims Filed	444 claims for PFL, 100 for PML 395 continuous leaves, 149 intermittent leaves
Denial Rate	4%
Percent of Claims by Leave Reason	17% medical 1% pregnancy/maternity 63% bonding 18% care for a family member

New Hampshire Paid Family and Medical Leave Changes as of 1/1/25
The maximum weekly benefit for NH PFML is 60% of the Social Security wage cap, which is $176,100, up from $168,600 in 2024. Therefore, the maximum weekly benefit is $2,031.92, an increase from $1,945.38 in 2024.

Rhode Island

Rhode Island established the first statutory disability program in the country in 1942, known as Rhode Island Temporary Disability Insurance (TDI). In 2014, they became the third state to offer family leave benefits through their Temporary Caregiver Insurance (TCI) program. The state does not allow private plans, making the model slightly different than other PFML programs in the region.

Rhode Island TDI and TCI	2020 Annual Report¹¹	2021 Annual Report¹²	2022 Annual Report¹³	2023 Annual Report¹⁴
Total Claims Filed	TDI: 44,494 TCI: 16,139 TDI: 56,022 TCI: 14,912 TDI: 52,682 TCI: 15,044 TDI: 51,324 TCI: 14,199
Total Payments	TDI: $180,327,767 TCI: $15,186,061 TDI: $208,367,267 TCI: $16,117,175 TDI: $224,336,990 TCI: $21,351,599 TDI: $239,534,900 TCI: $27,718,664
Average Weekly Benefit	TDI: $531 TCI: $567 TDI: $574 TCI: $626 TDI: $608 TCI: $650 TDI: $633 TCI: $684
Average Claim Duration	TDI: 11.4 weeks TCI: 3.3 weeks TDI: 9.6 weeks TCI: 3.7 weeks TDI: 9.4 weeks TCI: 4.1 weeks TDI: 11.3 weeks TCI: 4.5 weeks

RI Temporary Disability and Temporary Caregiver Insurance Changes as of January 1, 2025
On January 1, 2025, a few updates to TDI and TCI became effective. The State’s taxable wage base increased to $89,200 in 2025, up from $87,000 in 2024. The contribution rate in 2025 is 1.3%, which is an increase of 0.1% from the previous year. The maximum weekly benefit is $1,070, not including the dependency allowance,¹⁵ and the minimum weekly benefit is $139.

Employees must have paid contributions of at least $18,000 in the base period or meet the alternative conditions wherein they earned at least $3,000 in one of the base period quarters, have total base period taxable wages at least 1.5 times the highest quarter of earnings, and have base period taxable wages equal at least $6,000.

Vermont

The Vermont Optional Family and Medical Leave Insurance (FMLI) program began providing benefits to state employees on July 1, 2023, and opened to private sector employers on July 1, 2024. The program will expand on July 1, 2025, to allow individuals and employers with one employee to purchase coverage through the individual pool. Insurance coverage is available through the State’s insurance partner, The Hartford.

Data on 2023 and 2024 VT FMLI experience has not been published. Details on the FMLI program can be found on The Hartford’s VT FMLI website.

Paid Family Leave Insurance Rules

In addition to the mandatory programs mentioned, and the voluntary programs in New Hampshire and Vermont, several states have established paid family leave insurance rules. These rules allow insurance carriers to offer insured paid family leave products to interested employers and have been enacted in Alabama, Arkansas, Florida, Kentucky, Tennessee, Texas, and Virginia. The rules provide the minimum requirements a PFML plan must offer. New Hampshire has also established insurance rules, even though they have a state PFML program. Take up of these offerings has been minimal.

Now what?

As the PFML landscape continues to evolve at the local, state and federal level, legislation needs to be monitored on an ongoing basis. If any of your employees are subject to a state PFML program, you should periodically review your plans, policies, and processes to confirm they are in compliance with any legislative changes.

For instance, employers should be aware that in January 2025:

The Department of Labor issued guidance on how to handle time off that qualifies under both state paid family medical leave laws and the federal Family and Medical Leave Act (FMLA). Employers must ensure they are in compliance with both laws when administering the programs. This new DOL guidance can be found here.
The Internal Revenue Service issued guidance on the income and employment tax treatment of contributions and benefits paid in certain situations under a state paid family and medical leave program, as well as the related reporting requirements. This new IRS guidance can be found here.

The following checklist can be helpful when employers are reviewing their policies, plans, and processes:

Register in any state that enacts a new PFML program in which employees are working
Review your contribution strategy and ensure contributions are being collected
Update employee notices and benefit documentation
Consider private plans where available and in accordance with your corporate philosophy
Ensure company sponsored leave programs coordinate with PFML to the extent possible
Monitor changes in legislation that may impact compliance

If you need assistance ensuring PFML compliance or assessing the optimal plan set up for your organization, visit our Spring Consulting Group Paid Family and Medical Leave dashboard for additional information.

Grace Giannattasio, Consultant, Spring Consulting Group, An Alera Group Company, LLC
[email protected]
linkedin.com/in/grace-giannattasio
Updated on 2/13/25 to include the new IRS guidance.

[1] Connecticut Paid Leave Annual Report 2022; CT began accepting applications in December 2021 however benefits began in January 2022

[2] Connecticut Paid Leave Annual Report 2023

[3] Connecticut Paid Leave Annual Report 2024

[4] CT breaks out leave for pregnancy/childbirth, while this is included in medical leave for MA

[5] FY2021 Annual Report for the Massachusetts Paid Family and Medical Leave Program

[6] FY2022 Annual Report for the Massachusetts Paid Family and Medical Leave Program

[7] FY2023 Annual Report for the Massachusetts Paid Family and Medical Leave Program

[8] FY2024 Annual Report for the Massachusetts Paid Family and Medical Leave Program

[9] Assumes a 5-day work week in 2021, 2022, and 2023. For FY24, duration was calculated using actual work weeks reported by applicants and includes intermittent leave hours.

[10] New Hampshire Paid Family and Medical Leave Annual Report, Implementation and Year 1, 2021 – 2023

[11] 2020 DLT Annual Report

[12] 2021 DLT Annual Report

[13] 2022 DLT Annual Report

[14] 2023 DLT Annual Report

[15] Dependency allowance provides the greater of $20 or 7% of the benefit rate for up to 5 dependents