New Guidance on MA PFML Exemption Renewals and Approvals

As Massachusetts is entering its first renewal season for Paid Family & Medical Leave, we gathered the latest information from the Massachusetts Department of Family & Medical Leave (DFML) to help make your first exemption renewal process smooth.

Recently, the DFML issued a new MA PFML Confirmation of Insured Policy Form Number (COI)  which must be used for all private plan exemption renewals as well as new exemption applications. 

The DFML has also issued guidance on private plan exemption renewals which will make the renewal process easier going forward, but first things first. Let’s take a look at what you need to apply for a fully insured private plan, and then review the changes the DFML has made such as accepting requests to align policy and exemption renewal dates to make the renewal process easier moving forward.

How to Apply for a Fully Insured Private Plan with ShelterPoint*

The good news is that the process to obtain a fully-insured private plan with ShelterPoint is essentially the same as it was – and may be a similar process with other carriers. It begins with a quote and ends with providing us with a copy of the private plan exemption approval from the MA DFML to issue the Paid Family & Medical Leave policy.  Our easy 5-step process can be found here.  

The MA DFML has recently advised that you:

1. Use the new 2021 COI form, and
2. The new 2021 COI must be signed before you submit it via MassTaxConnect, and
3. Enter the carrier’s Policy Form Number (not your insurance policy number) exactly as it appears with the dashes and spaces incorporated.

 How to Process Your Exemption Renewal

This is where the lion’s share of the new MA DFML guidance comes into play.  In its effort to streamline the renewal process, the MA DFML has provided the following:

1.  A timeframe for when to file the exemption renewal: This process can only begin during the quarter immediately prior to the expiration of your exemption. You will need to complete a new PFML exemption application electronically through your MassTaxConnect account.
2. New 2021 COI:  The MA DFML requires the 2021 COI form for an exemption renewal; employers cannot submit the COI from a prior period.
3. Optional-Alignment of private plan exemption renewal date and policy renewal date:

Exemption periods that vary widely from the policy anniversary- The MA DFML is accepting requests to change the private plan exemption renewal date to line up with the anniversary date of your insurance policy – you simply need to send a request via an e-message on MassTaxConnect. The message would need to include the date requested for the next exemption to expire. If you are up for renewal, you would need to renew now and ask that the change be made for the following year.

• An example is an employer whose exemption is expiring 9/30/21, but their policy runs on a 1/1-12/31 cycle. The employer would go through the exemption renewal now and afterward send a separate e-message to request the MA DFML change their next exemption expiration to 12/31/2022. This change will align the exemption and anniversary to streamline administration.  

So, what do all these changes mean for you? This handy table provides real-world examples of how and when you can renew your private plan exemption:

You can apply to renew your exemption one quarter before the exemption approval termination date.

Why choose a fully-insured Private Plan?

In some cases, a fully-insured Private Plan’s rate may be lower than the State rate. Beyond the cost factor, insurance carriers have also built expertise and scalability around administering and paying claims. ShelterPoint provides a fully-insured, compliant, stand-alone private option for your Massachusetts Paid Family & Medical Leave needs.

Be sure to reach out to your broker – and brokers, be sure to reach out to your ShelterPoint sales team to assist you in this process.

This blog post is for informational purposes only and is not intended to provide legal counsel. Please consult with an appropriate professional for legal and compliance advice. The information in this material is as of the blog post’s date stamp; it is based on our knowledge of the applicable statutes and regulation, and may change as regulations evolve or the Massachusetts Department of Family & Medical Leave issues guidance regarding MA PFML regulations. 

*The ShelterPoint family of companies operates under the “ShelterPoint” name strictly as a marketing name, and no legal significance is expressed or implied. The ShelterPoint family of companies consists of ShelterPoint Life Insurance Company, a NY-domiciled carrier, and its wholly-owned subsidiary ShelterPoint Insurance Company, a FL-domiciled carrier, depending on the state. ShelterPoint is a registered service mark.

Massachusetts Paid F­amily & Medical Leave is available in MA only and will be underwritten by: ShelterPoint Life Insurance Company (a New York-domiciled carrier): Form# SPL PFMLP 0820 MA