• This page, SE 400.00 Substitute Teachers, is   offered by
  • Board of Review

SE 400.00 Substitute Teachers

Click on the case numbers below to access decisions regarding reasonable assurance of re-employment for substitute teachers.

0049 0631 94

0049 0631 94 (Jan. 8, 2021) – Due to the COVID-19 pandemic, the U.S. Department of Labor has required state agencies to re-assess an initial determination of reasonable assurance when the circumstances warrant it.  Here, the employer delayed the start of the 2020-21 school year due to the pandemic, and it failed to participate in the remand hearing to answer questions about when and how its plans for the school year had changed.  Board held the employer did not meet its burden to prove that, after issuing its usual re-employment letter in June, the claimant had reasonable assurance of re-employment in the next academic term under substantially similar economic terms.

0010 7230 82

0010 7230 82 (Sept. 16, 2014) – The claimant’s re-appointment letter was not reasonable assurance of re-employment as a long-term substitute teacher for the following academic term, because the letter did not offer a specific position and the claimant had to affirmatively apply for posted positions.  The offer was a mere possibility of re-employment and nothing more.

0002 1339 03

0002 1339 03 (May 12, 2014) – An adjunct professor offered only two courses in the fall semester, after teaching five courses during the prior academic period, had reasonable assurance of teaching based upon a pattern of courses not being cancelled due to inadequate enrollment, but the offer was not under substantially similar economic terms and conditions.  Board distinguishes adjunct professors from substitute teachers.


BR-121907-A (July 31, 2012) – Under G.L. c. 151A, § 28A, an on-call substitute teacher who worked during the spring academic term was not entitled to benefits over the summer, because she had reasonable assurance of re-employment as an on-call substitute teacher under the same economic terms and conditions for the fall. It makes no difference that she had worked very few days during the spring term.


BR-117509-A (Mar. 27, 2012) – If an on-call substitute teacher receives reasonable assurance to work as a substitute teacher for any school employer in the fall, he is precluded under G.L. c. 151A, § 28A from collecting benefits during the summer based upon any of the wages that he earned from substitute teaching.


BR-109037-OP (Aug. 4, 2009) – Claimant laid off from a full-time teacher position during the base period subsequently worked as an on-call substitute with reasonable assurance of returning to work as a substitute after summer vacation.  Because the entire base period employment is considered; not just the last job before summer break, she was eligible for benefits based upon the full-time teacher wages.

Help Us Improve Mass.gov  with your feedback

Please do not include personal or contact information.