Annual Reporting Reminders:

Paid Leave Oregon (PLO) – Equivalent/Private Plan

Background

Employers with Oregon employees are allowed to implement an equivalent plan (also known as a private plan) instead of participating in the state administered paid leave program.  The plan must meet or exceed the standards of the state-run Paid Leave Oregon program. 

Equivalent plan employers are required to file an annual report that contains information on benefits usage and the plan’s financial information. Reporting is also required if an equivalent plan is terminated or withdrawn. 

Important Deadlines

January 31, 2025:  Equivalent plan reporting is due for plans continuing to provide benefits into 2025.  This is the first year the report has been required.  Reporting will include plan information from September 3, 2023 (or the initial effective date of the equivalent plan) through December 31, 2024.  Going forward, the reporting will be based on the calendar year.

30 days after plan withdrawal or termination: Plans that are terminated or withdrawn are required to file 30 days after the end of the plan.

How Does the Employer File?

The equivalent plan report is available on Paid Leave Oregon’s website here.  The completed form can be uploaded to the employer’s Frances online account or mailed to the address on the form. 

What Information Does the Employer Need to Report

The report includes the following sections.

Section 1 – Benefit Utilization Report.  Required for all employers with an equivalent plan.  This section includes detailed information on benefit applications and claims.  Equivalent plan insurance carriers and TPAs will provide reporting with the information needed for the employer to complete this section. 

Section 2 – Financial Information.  Required for employers who withheld employee contributions for their equivalent plan and who are continuing to provide the plan into the following year.  Data for this section will come from the employer’s payroll and accounting records.

Section 3 – Financial Report for Terminated or Withdrawn Plans.  Employers who withheld employee contributions to fund their equivalent plan and have terminated or withdrawn their equivalent plan must complete this section.  This report includes a plan reconciliation.  Any balance of employee contributions after reconciliation will be forfeited and paid to Paid Leave Oregon.

Employer Next Steps

• Download the Equivalent Plan Report here and gather the necessary information.
• Keep an eye out for communication from your equivalent plan insurance carrier or TPA. 
• IMA Compliance has confirmed that carriers will provide reporting data the first week or two in January.  Reports will be available through employer portals or sent directly to the employer.  This process varies by carrier.  Employers will need the information in the carrier reports to complete the reporting. 
• Contact your carrier or your IMA employee benefits team if you do not receive the carrier reports by January 20^th.
• Complete the reporting by January 31, 2025.  We recommend uploading the completed report to the Frances on-line portal rather than sending it through the mail.  The portal provides a way to track the submission.

Contact your IMA employee benefits team if you have additional questions.

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information. This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.

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