Employer Private Plan Reporting Obligations

Employers that meet their Paid Family and Medical Leave (PFML) law obligations through an approved M.G.L. c. 175M, sec. 11 private plan are required to maintain reports, information and records related to their approved plan and furnish required data to the Department of Family and Medical Leave (DFML) on request.

General Information

Employers that meet their Paid Family and Medical Leave (PFML) law obligations through an approved M.G.L. c. 175M, sec. 11 private plan are required to maintain reports, information and records related to their approved plan and furnish required data to the Department of Family and Medical Leave (DFML) on request. DFML is collecting information from each private plan for the 2024 fiscal year.

Why is DFML Requesting Reporting Data from Employers with Private Plans?

DFML collects data on private plans to evaluate PFML program goals, promote the integrity of private family and medical leave plans, and ensure that they meet the benefit requirements for private paid leave plan exemptions. DFML may require periodic reporting to ensure that a private plan complies with the requirements of M.G.L. c. 175M, 458 CMR 2.07(7).

Who Can Submit the Information Required by DFML?

Self-Insured Employers, Third Party Administrators or Private Plan carriers can submit the report to us by uploading it directly to DFML. Private plan insurance carriers for fully insured plans may submit aggregated data that includes multiple employers in a single report. 

Instructions to upload the documents and a link to the specific page will be released closer to the reporting date.

When Does the Reporting Take Place?

All employers with an approved exemption during any portion of the reporting period must submit reporting for the 2024 fiscal year, which spans July 1, 2023 to June 30, 2024. The responsible party for submission of the report is as follows:

• If the private plan is fully insured, the insurance carrier is responsible for submitting this report.
• If the private plan is self-insured and self-administered, the employer is responsible for submitting this report.
• If the private plan is self-insured and a carrier or Third-Party Administrator is administering the plan, please consult your administrator regarding report submission.

The submission form opened on July 1, 2024. Requested information must be provided by August 31, 2024.

DFML may withdraw approval of a private plan for refusing or failing to submit a required report.

What Information Will Self-Insured Employers or their Third Party Administrator or Carrier Need to Provide?

Requested information includes, but is not limited to:

• Name and contact information of private plan insurer and /or third-party administrator
• Contact information for individuals at the reporting employer or covered business entity
• Information on the demographics of covered employees
• Approved claims data, including leave types and duration
• Denied claims data, including reasons for denial
• Average weekly wage
• Average benefit amounts paid

You can see a complete list of required data, in the approved reporting template below.

Reporting Template and Submission Form

The DFML FY24 Reporting Template lists all required data as well as corresponding instructions. You must use this approved template to format your data: DFML FY24 Reporting Template

Once you are ready to submit, you can do so here: PFML Private Plan Exemption Annual Reporting - Formstack

Questions?

If you have questions, you can email us at [e-mail].