With blue skies and warm weather here (finally!), it’s easy to overlook some deadlines that are upcoming for employers in Connecticut. One relates to those who have employees who have taken FMLA and the other relates to authorized house counsel at those companies. These deadlines won’t affect everyone, but for those who are covered, it’s important to stay in compliance.
In-House Counsel Registration
New rules that went into effect January 1, 2008 provide a safe-harbor for those attorneys that work in-house at companies, but who are not licensed to practice law in Connecticut. I’ve summarized the requirements for the "Authorized House Counsel" rules in a post over the winter.
But the safe-harbor period expires June 30, 2008. House counsel must register by then or they could face penalties if they are caught working at these companies without prior registration. And according to the Law Tribune (registration required), only a few hundred attorneys have filed the necessary papers.
As of last week, 78 in-house counsel who paid and signed up were sworn in throughout Connecticut, said Kathleen B. Wood, administrative director of the Connecticut Bar Examining Committee. At the time, Wood’s office had received 277 applications. She had expected the number to be in the thousands.
For employers, ensuring that their employees are properly licensed and in compliance with the law should be a top priority. With just a few weeks to go before the expiration of the safe-harbor period, employers (and their house counsel) can download the necessary paperwork directly from the Connecticut Bar Examining Committee website here.
FMLA Forms for Connecticut Employers
The Connecticut Department of Labor, which has oversight of employers and family medical leave act enforcement, has reminded employers of another deadline. Specifically, for companies who as of October 1, 2006, employed in Connecticut 75 or more employees, the Department of Labor requires employers to submit a Family and Medical Leave Act (FMLA) Experience Report. The form can be filled out electronically here. It must be submitted by June 20, 2008.
What information is requested? Pretty basic information, actually: The Department requests the type of leave taken (birth/adoption, family illness, medical leave) and the number of leaves taken and the total weeks of leave taken by type.
This requirement is actually based on the DOL’s regulations. Specifically, Conn. Regs. Sec. 31-51qq-48 states that employers are required to complete forms that are necessary to assess the current experience of employers subject to the Act.