PFML – Benefits Coordination

Washington State's new Paid Family & Medical leave program started collecting premiums this month, but I still have a lot of burning questions regarding benefits coordination. Here's my list so far.

​I’ve got questions about how the state’s new Paid Family & Medical Leave (PFML) will coordinate with other sources of income. Unfortunately, this doesn’t look to be an item on the rulemaking docket yet. The Employment Security Department (ESD) has advised me to keep checking back. In the meantime, I’m creating a list of the issues we’ll need to see addressed. 
First, let me start off with defining two types of benefits provisions. When an individual qualifies for more than one salary replacement program, the benefits could be “stacked” or “offset.” These provisions are often included within insured STD and LTD contracts.

• Stacked benefits = both salary replacement plans will pay benefits, up to a percentage of pre-disability earnings (e.g., an STD policy paying benefits in addition to employee wages received under sick time or PTO to 100% of pre-disability earnings)
• Offset benefits = one salary replacement plan will be reduced by the proceeds of another salary replacement plan (e.g., an LTD policy offsets SSDI dollar-for-dollar)

Here’s my list of questions so far. I would love to hear your thoughts and additions!

1. STD coverage – will it be stacked with PFML or offset?
2. LTD coverage – will it be stacked with PFML or offset?
3. Will employer-paid disability be handled differently than employee-paid disability coverage?
4. Sick leave, vacation, and PTO – will they be stacked with PFML or offset?
5. If sick leave, vacation, and PTO are offset, will the employee be able to waive their right to PFML until they have exhausted their sick, vacation, and PTO pay?
6. Employer “top off” payments – will an employer be allowed to provide employees with additional wages (i.e., self-fund) to provide a higher level of leave payment?
7. How will intermittent leave be handled, such as needing one day off per week for chemotherapy?

​My next task is to research how other states’ paid leave programs work alongside disability insurance plans and employer-paid wages!