By: HUB's Absence Management Team

The Massachusetts Department of Family and Medical Leave (MA DFML) has released reporting requirements for Paid Family and Medical Leave (MA PFML) private plans.

Overview

Since the implementation of the MA PFML program in 2021, employers, insurance carriers, and third-party administrators (TPAs) have been required to maintain reports, information and records related to approved MA PFML private plans. The MA DFML has now announced that these records will need to be provided to the state by August 31, 2024.

Requirements

All employers with an approved private plan, or their insurance carrier or TPA on the employer’s behalf, are required to submit the data listed in the DFML FY24 Reporting Template for the time period beginning July 1, 2023, and ending June 30, 2024. This means that employers who do not currently have a private plan, but did have one during the designated reporting period, must submit records for the time period that they did have a private plan. The data must be submitted through an online portal that will open beginning July 1, 2024.

Employers with a self-funded and self-administered private plan are responsible for submitting their reports. For employers with a fully insured private plan, their carrier will submit the reporting on their behalf. If the private plan is self-funded but administered by an insurance carrier or TPA, employers should discuss reporting with their administrator to determine who will submit the reporting.

Employers who refuse or fail to submit a report by August 31, 2024, may have their private plan approval withdrawn by the MA DFML. More information can be found on the MA PFML website.

Next Steps

Employers with self-insured, self-administered private plans should review their records from the reporting period to ensure that all required information is available. Employers with a self-insured plan administered by a carrier or TPA should consult with their administrator to discuss the reporting requirements. Though insurance carriers are required to submit reporting on behalf of employers with fully insured plans, it is still advised that the employers reach out to their carrier to ensure there are plans in place to submit the reporting.

NOTICE OF DISCLAIMER

Neither Hub International Limited nor any of its affiliated companies is a law or accounting firm, and therefore they cannot provide legal or tax advice. The information herein is provided for general information only and is not intended to constitute legal or tax advice as to an organization’s specific circumstances. You should consult an attorney, accountant, or other legal or tax professional regarding the application of the general information provided here to your organization’s specific situation in light of your organization’s particular needs.