Paid Leave Oregon Updates:

Benefit Increases and Equivalent Plan Reapplication Reminder

Benefit Updates: Effective 7/6/25 through 6/30/26

The Paid Leave Oregon (PLO) maximum benefits are tied to the State Average Weekly Wage (AWW). The AWW is adjusted annually in June. This change will be applied to benefits paid through both the State plan and through Equivalent plans.

• State average weekly wage: $1,363.80 (increased from $1,307.17)
• Maximum weekly benefit: $1,636.56 (120% of SAWW)

• Maximum employee wage for contributions: $176,100 for 2025. This is adjusted annually in January.

Refiling Reminder

Employers who opted out of state coverage and have an Equivalent Plan are required to refile an application with the Oregon Employment Department (OED) annually for the first 3 years of the plan. The refiling process occurs during the quarter preceding the anniversary date of the PLO coverage. The application must be submitted at least 30 days prior to the anniversary date. 

NOTE: The anniversary date is based on the date the OED originally approved the employer’s plan. Plans effective 9/3/23 will have a 10/1 anniversary date.

Important Dates

Applications must be submitted no later than:

• October 1 original effective date (includes 9/3/23 plans): Due by August 31

• January 1 original effective date: Due by December 1

• April 1 original effective date: Due by March 1

• July 1 original effective date: Due by May 31

IMPORTANT: If the re-approval application is not submitted by the deadline, the OED will cancel the equivalent plan, and the employer will be required to participate in the state plan.

What if an employer’s anniversary was written to align with its Life or Disability policy year or if the plan changed the plan mid-year? 

OED reapproval is still based on the original effective date even if your equivalent plan policy was written to match up with an existing life or disability policy. For example, plans that began on 9/3/23 but have a 1/1/26 policy renewal will need to file with the OED for reapproval for 10/1/25. If no substantive changes are made on the 1/1/26 carrier policy renewal no filing will be needed for 1/1/26.

What is needed to apply for reapproval of the PLO equivalent plan?

The reapproval process will be like the original equivalent plan application process. There is an online questionnaire, and employers will need to load a copy of the plan document that will be effective on their anniversary date. Review the Equivalent Plan Checklist from the OED to help prepare for the application. 

Employers will need to pay a $150 application fee if they are renewing without substantive changes and a $250 application fee if they make substantive changes.

NOTE: A carrier change is considered a substantive change.

What to expect during the reapproval process?

The process includes three steps: 

• Reapplication: Employer will submit for reapplication through Frances on-line. Once completed, the employer will receive a “Receipt of Equivalent Plan Application” notice. This is posted on Frances and mailed. The notice confirms the application will be reviewed and a fee will be assessed based on substantive or non-substantive changes. The employer cannot pay the application fee at this point.
• Payment: Once the state makes the fee determination, they send the employer an “Equivalent Plan Application Fee Assessment” notice. This letter includes the fee amount and payment instructions and is posted on Frances and mailed. 
  
  IMPORTANT: Payment should be made immediately upon receipt of the notice. The state will not review the application and move to the next step without payment.

• Review and approval: Once payment is received the state will review the application. Employers will receive an approval letter. This will be posted on Frances and mailed.

Summary

Employers with a PLO equivalent plan should log into their Frances portal at least 30 days prior to their renewal date and take appropriate steps to renew the plan. If the deadline is missed, the OED will cancel the equivalent plan, and the employer will be required to participate in the state plan.

 

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.