Bonus: Should I Stay or Should I Go [on Leave]

Crime Victim Leave Expansion

The list of crimes for which employees can take protected time off has been expanded. The new law also permits the use of state paid sick leave for these purposes.

Previously, California law provided protections to employees from discrimination or retaliation for taking time off for court appearances, or to employees who were victims of crime or abuse.

Under Assembly Bill (AB) 2499, these protections remain in place, but broaden the definition of “victims” to include a victim of a “qualifying act of violence,” which means any of the following, regardless of whether anyone is arrested for, prosecuted for, or convicted of committing any crime:

• Domestic violence
• Sexual assault
• Stalking
• An act, conduct, or pattern of conduct that includes:
  • An individual causes bodily injury or death to another
  • An individual exhibits, draws, brandishes, or uses a firearm or other dangerous weapon, with respect to another
  • An individual uses or makes a reasonably perceived or actual threat of use of force against another to cause physical injury or death.

Additionally, paid sick leave for “safe” time purposes will no longer be limited to employees who are victims; it must also be available when an employee’s family member is a victim. The definition of “family member” will include a child, parent, grandparent, grandchild, sibling, spouse or domestic partner, or designated person.

The circumstances for which paid sick leave is available for the employee or their family member is:

• Seek, obtain, or attempt to obtain any relief (includes, but is not limited to, a temporary restraining order, restraining order, or other injunctive relief, to help ensure the health, safety, or welfare of the victim, their child, or a family member).
• Seek, obtain, or assist medical attention for or to recover from injuries caused by a qualifying act of violence.
• Seek, obtain, or assist services from a domestic violence shelter, program, rape crisis center, or victim services organization or agency because of a qualifying act of violence.
• Seek, obtain, or assist psychological counseling or mental health services related to an experience of a qualifying act of violence.
• Participate in safety planning or take other actions to increase safety from future qualifying acts of violence.
• Relocate or engage in the process of securing a new residence due to the qualifying act of violence, including, but not limited to, securing temporary or permanent housing or enrolling children in a new school or childcare.
• Provide care to a family member who is recovering from injuries caused by a qualifying act of violence.
• Seek, obtain, or assist in civil or criminal legal services in relation to the qualifying act of violence.
• Prepare for, participate in, or attend any civil, administrative, or criminal legal proceeding related to the qualifying act of violence.
• Seek, obtain, or provide childcare or care to a care-dependent adult if the childcare or care is necessary to ensure the safety of the child or dependent adult as a result of the qualifying act of violence.

Employees are permitted to use vacation, personal leave, paid sick leave, or compensatory time off that is available unless otherwise provided in a collective bargaining agreement.

Employers with 25 or more employees will be able to limit the amount of leave an employee may take when they or a family member are a victim of a qualifying act of violence, or a crime victim who is appearing as a witness in court, as follows:

• Qualifying Act of Violence Victim: 12 weeks (total).
• Relocation or Enrolling a Child in a New School or Childcare when Family Member Is a Crime Victim (Non-Fatal): 5 days.
• Family Member Is a Crime Victim (Non-Fatal): 10 days.
• If the absence also qualifies under FMLA or California Family Rights Act (CFRA), leave must run concurrently.

Finally, under the law, employers will be required to provide written notice of their rights established under this bill to new hires, to all employees annually, at any time upon request, and any time the employer becomes newly aware that an employee or an employee’s family member is a victim. The notice must inform employees of:

• Disability or paid family leave benefits made available through the state that might be available;
• Leave under a separate bereavement leave law possibly being available upon the death of a family member who is a victim; and
• Leave rights under other laws (Labor Code sections 230.2 and 230.5) to attend various court proceedings when they or a family member is a crime victim.

This bill took effect January 1, 2025.

Employer Ability to Require Employees Use Vacation Before Receiving Paid Family Leave Eliminated

On September 29, 2024, California’s governor signed into law AB 2123. Beginning January 1, 2025, AB 2123 eliminated employers’ ability to require employees to use up to two weeks of company-provided vacation before they start receiving paid family leave (PFL) insurance benefits paid.

Paid Family and Medical Leave Finalized Rules

On December 4, 2024, while chowing down on lobster rolls, the Maine Department of Labor (DOL)  adopted finalized rules for the Maine Paid Family and Medical Leave Program (PFML). OK, I don’t actually know if the Maine DOL was eating lobster rolls at the time these rules were finalized, but that’s my vision. Employer contributions and employee deductions to fund these benefits began on January 1, 2025. Employees can begin receiving benefits effective May 1, 2026.

The rules are largely consistent with other PFML programs, but there are several key differences highlighted below:

• Good Cause Definition: A “good cause” standard clarifies circumstances which allow employees with “good cause” additional time to apply for benefits or request an appeal. “Good cause” is defined as any serious health condition or any physical, intellectual, or linguistic limitation that prevents filing.
• The final rules added a seven-day waiting period.
• Employers can determine undue hardship even if an employee provides reasonable notice of 30 days. An employer’s determination of undue hardship will not be considered reasonable unless the following are established: (1) the employer provided a written explanation of the undue hardship to employee; (2) the employee retains the ability to take leave within a reasonable time frame relative to the proposed schedule; and (3) the employer has made a good faith attempt to work out a schedule for the leave that meets the employee’s needs without unduly disrupting the employer’s operations, subject to the approval of the employee’s healthcare provider.
• The calculation of the average weekly wage is now determined by dividing the applicant’s reported wages in their base period by 52.
• Employers can substitute a similar private plan for the state plan starting April 1, 2025.

Paid Family and Medical Leave – Coming Soon!

Maryland’s paid family and medical leave insurance law applies to all employers with employees in Maryland. Payroll deductions will start July 1, 2025, and benefits will be available beginning July 1, 2026. Additionally, employers will need to remit the first payment to the state October 1, 2025.

Additionally, Maryland’s Department of Labor (MDOL) has released proposed regulations to implement the law. The proposed regulations provide important insights into how the State will likely interpret and enforce the law; a summary of notable proposals is outlined below.

Employer Responsibilities

• Employers must create and maintain an online account with the FAMLI Division for reporting and remitting contributions.
• Employers are responsible for 100% of contributions but can withhold up to 50% from employees’ wages. Small employers (fewer than 15 employees) have reduced contribution obligations.
• Employers must notify employees about FAMLI leave and benefits at hire, annually, and when an employee’s leave may qualify for FAMLI.

Employee Eligibility and Benefits

• The proposed regulations define a “covered employee” as one who has worked at least 680 hours performing qualified employment in the state over the four most recently completed calendar quarters.
• Benefits are based on the employee’s average weekly wage.

Claims Process

• Employees must submit a complete claim application within 60 days of taking leave.
• Employers have five business days to respond to a claim application.
• Payments are made biweekly. The first payment will be made within five business days after approval.

Equivalent Private Insurance Plans (EPIPs)

• EPIPs must meet or exceed the benefits and requirements under the state plan.
• Employers must participate in the state plan until their EPIP is approved.
• Employees may appeal the denial of benefits to the state, which may pay the benefits that are due and not paid by the employer.

Benefits Coordination

• FAMLI leave will run concurrently with FMLA. If an employee takes leave under FMLA for a reason that would also qualify for FAMLI leave but does not apply for FAMLI benefits, the amount of FAMLI leave available to the employee may be reduced by the amount of FMLA leave taken. This ensures the total leave taken under FAMLI and FMLA does not exceed the maximum allowable leave period. We are big fans of this rule, but unsure how the state will effectively administer.

For a comprehensive overview of the program, please reference TPG’s PFML Overview Guide.

Expanded Reasons for Use of Earned Sick Time

The Massachusetts legislature expanded the reasons employees can use Earned Sick Time. Employees may now use Earned Sick Time to “address the employee’s own physical and mental health needs, and those of their spouse, if the employee or the employee’s spouse experiences pregnancy loss or a failed assisted reproduction, adoption or surrogacy.”

These new conditions are in addition to the current reasons employees can use Massachusetts Earned Sick Time:

• To care for the employee’s child, spouse, parent, or parent of a spouse, who is suffering from a physical or mental illness, injury, or medical condition that requires home, professional medical diagnosis or care, or preventative or routine medical care;
• To care for the employee’s own physical or mental illness, injury, or medical condition that requires home, professional medical diagnosis or care ,or preventative or routine medical care;
• To address the psychological, physical, or legal effects of domestic violence against the employee or employee’s child; or
• To travel to and from an appointment, pharmacy, or other location.

The change took effect November 21, 2024.

Paid Family and Medical Leave Act Doesn’t Require Employers to Allow Benefits Accrual

In one of the first decisions interpreting the Massachusetts Paid Family and Medical Leave Act (PFMLA), the Supreme Judicial Court (SJC) held that PFMLA does not require an employer to allow employees to accrue benefits, such as vacation time and sick time, during PFMLA leave. Bodge, et al. v. Commonwealth, et al., (September 13, 2024).

In this case, a group of state troopers sued the State Police, claiming the State Police’s policy of not providing for accrual of employee benefits, including vacation time and sick time, while on PFMLA leave violated the PFMLA. The SJC held that the State Police’s policy did not violate the PFMLA.

The SJC noted PFMLA states, “An employee who has taken family or medical leave shall be restored to the employee’s previous position or to an equivalent position, with the same status, pay, employment benefits, length-of-service credit and seniority as of the date of leave.” The SJC held this part of the statute simply required that an employee’s benefits remain unchanged, not increased or decreased, from when they begin leave to when they return from leave. Thus, an employee returning from PFMLA leave can continue to accrue benefits as if the employee never took the leave, but the employee does not have the right to continue accruing benefits during the leave.

Final Proposed Rules

Throughout 2024, Minnesota Paid Leave asked a broad cross-section of workers, industries, service providers, and advocates for feedback on draft rules to build out the Paid Leave program.

Informed by that feedback, Paid Leave published final proposed rules in late November 2024. Public comments on the final proposed rules were collected through January 3, 2025.

These rules cover topics including provider certification; seasonal employment; opting in; intermittent leave; the role of the employer; covered employment; leave modifications; overpayments; job protections; benefit payment schedules; private plans; claims administration; small employer assistance grants; and safety leave.

All 19 pages of the proposed final rules can be found here, but we’ve summarized some key points below.

• Employer Response to Requests for Information: An employer must respond to the commissioner’s request for information about an employee’s application within seven calendar days of the request. If no response is received, the commissioner must process the application without the employer information. If employer information is received after a determination of an applicant’s eligibility, the commissioner must use the additional information to adjust the amount of leave and benefits determined, if necessary.
• Backdating an Application: If an applicant is unable to apply in a timely manner due to incapacitation or no fault of their own, the department shall backdate the application to the effective date of leave. The applicant must provide information and documentation showing the factors that prevented the applicant from applying for benefits when the qualifying event occurred. An applicant seeking to backdate an application or weekly payment must file for benefits within seven days after the factors preventing a timely application no longer exist.
• Private Plans:
  • A self-insured employer or private plan insurer must submit an annual report. Beginning in 2027, and annually thereafter, a self-insured employer or private plan insurer must submit the necessary detail by November 1.
  • An employer remains liable for premiums on wages paid until the effective date of the approved private plan. Employees remain eligible for benefits from the state-administered plan until the effective date of an approved private plan.
  • In addition to the notice required by Minnesota Statutes, an employer must provide notice to their employees about coverage under a private plan. An employer must provide the notice not more than 30 days from the start date of the employee’s employment, or 30 days before premium collection begins, whichever is later.
• Certification for Caregiving Leave: Certification to care for a family member with a serious health condition must include: the relationship of the applicant; the proposed leave schedule; a signed attestation by the healthcare provider that affirms: (1) the family member requires care from the applicant and the healthcare provider is treating the family member; and (2) the date on which the serious health condition commenced, the probable duration of the condition, and the facts establishing that the family member requires care. If more than one applicant seeks leave to provide care for the same family member, the applicants’ certification must be completed by the same healthcare provider. TBD on how well the state manages to track this provision . . . I’m 50% sure they will do so correctly.
• An applicant seeking leave to care for a family member with a serious health condition must attest that the person the applicant is taking leave to care for is the applicant’s family member.
• Safety Leave Certification: A qualified person eligible to sign documentation certifying safety leave includes: an individual who is licensed, certified, or otherwise authorized under law to practice as a mental health professional or practitioner; a licensed healthcare professional; a domestic abuse advocate or sexual assault counselor; a victim’s advocate; a judge, referee, appointed court administrator, prosecutor, or probation officer; a Title IX coordinator; a peace officer, part-time peace officer, or reserve officer; or any other person acting in their professional capacity who can submit documentation that includes the necessary information.

Paid Sick Leave Law

Is it just me or do you find it fascinating that conservative midwestern states are passing Paid Sick Leave legislation? Since Missouri is the “Show Me State,” I’m here to “show you” the provisions of this law. In the November election, Missourians voted in favor of Proposition A to create a new statewide paid sick and safe time (“paid sick time”) law that will become operative on May 1, 2025.

The law will apply to all employers, though different standards will apply depending on whether an employer has 15 or more, or 14 or fewer (“small employers”), employees in Missouri.

Generally, the law applies to an individual employed in Missouri but contains numerous exceptions. We’ve noted the most significant, but not all, exceptions below:

• Individuals employed for less than four months in any year in a resident or day camp for children or youth, or individuals employed by an educational conference center operated by an educational, charitable, or not-for-profit organization;
• Individuals employed by certain rail carriers;
• Individuals employed on a casual or intermittent basis as a golf caddy, newspaper carrier, or similar occupation;
• Individuals employed by a retail or service business whose annual gross volume sales made or business done is less than $500,000;
• Employees connected with the publication of any weekly, semiweekly, or daily newspaper with a circulation of less than 4,000, most of which is within the county where published or neighboring counties.

Under the law, employees can use leave for themselves or to care for or assist family members – defined as a child, grandchild, grandparent, parent, sibling, spouse, along with an individual with whom the employee is in a continuing social relationship of a romantic or intimate nature, and a person for whom the employee is responsible for providing or arranging health or safety-related care – for the following reasons:

• An employee’s mental or physical illness, injury, or health condition including diagnosis, treatment, and preventative medical care;
• Care of a family member with a mental or physical illness, injury, or health condition, including diagnosis, treatment, and preventive medical care;
• If the employee or their family member is a victim of domestic violence, sexual assault, or stalking:
  • Medical attention needed to recover from physical or psychological injury;
  • Services from a victim services organization;
  • Psychological or other counseling;
  • Relocation or taking steps to secure an existing home; and
  • Legal services, including preparing for or participating in any civil or criminal legal proceeding.
• Closure of employee’s place of business by order of a public official due to a public health emergency;
• Care for a child whose school or place of care has been closed by order of a public official due to a public health emergency; and
• Determination that an employee’s or family member’s presence in the community may jeopardize others’ health because of exposure to a communicable disease, whether or not the individual has actually contracted the disease.

The law does not allow employers to impose a waiting period before employees can use paid sick time; once accrued, employees can use it.

Employers with a paid leave policy, such as PTO, who make available an amount of paid leave sufficient to meet the law’s requirements and may be used for the same purposes do not have to provide additional paid sick time. Otherwise, when employment begins or on May 1, 2025 – whichever is later – employees must accrue one hour of paid sick time for every 30 hours worked.

The law is silent on an annual cap and overall accrual. However, small employers can limit annual use to 40 hours, and other employers can limit annual use to 56 hours. Employers can limit carryover to 80 hours.

Requests for leave can be made orally, in writing, electronically, or by any other means acceptable to the employer. When possible, the request must include the expected duration. For foreseeable absences, employees must make a good-faith effort to provide advance notice and must make a reasonable effort to schedule leave in a manner that does not unduly disrupt the employer’s operations. For unforeseeable absences, employers can require employees to provide notice as soon as practicable. If an employer enforces such notice for unforeseeable absences, it must provide a written policy explaining those procedures. If employers do not provide employees a copy of the policy, they cannot deny leave use due to non-compliance.

When employees use leave on three or more consecutive workdays, employers may require “reasonable” documentation. Examples of reasonable documentation include:

• Sick Time: Documentation signed by a healthcare professional indicating that leave is necessary.
• Safe Time
  • A police report indicating the individual was a victim;
  • A written statement from an employee or a victim service provider’s agent affirming the individual is or was receiving services;
  • Documentation signed by a healthcare professional;
  • A court document indicating the individual is or was involved in a legal action;
  • A written statement from the employee affirming they are taking or took leave for a covered reason.

Paid Sick Time does not need to be paid out at separation, but employers must reinstate that leave should they rehire the employee within nine months of separation.

Within 14 calendar days of employment beginning or on April 15, 2025 – whichever is later – employers must provide written notice of the following on a single piece of paper, at least 8.5 x 11 inches, in no less than 14-point font:

• Beginning May 1, 2025, employees accrue and are entitled to paid sick time at the rate of one hour for every 30 hours of work, and may use earned paid sick time, subject to the law’s limits and terms;
• Employers cannot retaliate against employees who request or use earned paid sick time;
• Employees have the right to bring a lawsuit if earned paid sick time is denied or they are retaliated against for exercising their rights under the law; and
• Contact information for the state labor department.

Beginning April 15, 2025, employers must conspicuously display a poster in an accessible place in each establishment that contains the information required in the time-of-hiring notice.

For at least three years, employers must retain and allow the state labor department access to records documenting hours worked and earned paid sick time taken. However, that information is not required to be included on employee wage statements.

Paid Sick Leave Law

Nebraska, “The Good Life,” am I right? For 100% of my readers, I assume you did not know this was Nebraska’s state slogan, but we’re starting to make that more of a reality. After taking a lifelong hiatus from offering this type of benefit to employees, Nebraskans overwhelmingly voted in favor of Initiative Measure 436 to create a new statewide paid sick time law in the November 2024 election. The law will become effective on October 1, 2025. Equally important breaking news from the month of November: The Cornhuskers football team qualified for their first bowl game since 2016. Go Big Red.

Back to Paid Sick Time. The law will apply to all employers, though different standards for those with 19 or fewer employees. The “small employer” definition appears to be based on the number of employees anywhere, not just in Nebraska. For an employee to be eligible, they must work in Nebraska for at least 80 hours in a calendar year.

Employees can use leave for themselves or to care for a family member – defined as a child, parent, grandchild, grandparent, sibling, spouse, or any other individual related by blood to the employee or whose close association with the employee is the equivalent of a family relationship for the following reasons:

• Mental or physical illness, injury, or health condition;
• Medical diagnosis, care, or treatment of a mental or physical illness, injury, or health condition;
• Preventive medical care;
• In the case of a child, attending a meeting necessitated by their mental or physical illness, injury, or health condition, at a school or place of care;
• Closure of employee’s place of business by order of a public official due to a public health emergency;
• Care for a child whose school or place of care has been closed by order of a public official due to a public health emergency; and
• Determination that the employee’s or family member’s presence in the community may jeopardize other’s health because of exposure to a communicable disease, whether or not the individual has actually contracted the communicable disease.

The law does not allow employers to impose a waiting period before employees can use paid sick time.

Employers with a paid leave policy, such as PTO, who make available an amount of paid leave sufficient to meet the law’s requirements need not provide additional paid sick time. Otherwise, when employment begins or on October 1, 2025 – whichever is later – employees must accrue one hour of paid sick time for every 30 hours worked.

Small employers can cap annual accrual at 40 hours, and other employers can cap accrual at 56 hours. All unused leave must carry over from year to year (with no designated carryover cap). The law is silent concerning whether, and in what amount, employers can cap overall accrual.

An employer requiring notice of the need to use paid sick time must provide a written policy that contains reasonable procedures for employees. If employers do not provide employees a copy of the policy, they cannot deny leave use due to non-compliance.

The law requires employers to allow paid sick time use upon an employee’s oral request, which, if possible, must include expected duration. The law is silent on the amount of notice an employee must provide for foreseeable and unforeseeable absences.

If employees use paid sick time on four or more consecutive workdays, an employer may require the employee provide “reasonable” documentation. However, if the employee or family member did not receive services from a healthcare professional, or if documentation cannot be obtained in reasonable time or without added expense, the employee can provide a written statement indicating they took paid sick time for a covered reason.

Employers cannot require disclosure of an employee’s or family member’s health information.

When employment begins or by September 15, 2025 – whichever is later – employers must give employees written notice of the following:

• Beginning October 1, 2025, employees are entitled to paid sick time;
• The amount of paid sick time;
• The terms of its use;
• Retaliation against employees who request or use paid sick time is prohibited;
• Each employee has the right to file a suit or complaint if statutory paid sick time is denied or the employee is subjected to retaliation for requesting or taking leave; and
• Contact information for the department where questions about rights and responsibilities under the law can be answered.

In an accessible place at each establishment, employers must display a poster that contains the information required in the time-of-hiring notice. If there is no physical workplace or an employee teleworks, employers must provide notice via electronic communication or a posting in a web-based platform.

Additionally, the following information must be recorded in, or on an attachment to, the paycheck:

• Paid sick time available to the employee;
• Paid sick time taken by the employee to date in the year; and
• Amount of pay the employee has received as paid sick time.

FAQ on Paid Prenatal Leave

The New York State Department of Labor (NY DOL) released Frequently Asked Questions regarding the January 1, 2025, requirement for employers to provide paid leave for pregnant employees to attend prenatal medical appointments and procedures. This amendment entitles eligible employees to up to 20 hours of paid prenatal leave in a 52-week period.

Some key takeaways are:

• Employers cannot use a more generous sick leave or PTO policy to satisfy the requirement. The 20 hours of paid prenatal leave are in addition to any paid time off benefits already provided, whether by law (e.g., New York paid sick leave) or voluntary (e.g., PTO).
• Employees cannot be required to exhaust other available paid time off benefits before using paid prenatal leave.
• Employees can use paid prenatal leave for pre-pregnancy care related to a future pregnancy as well as end-of-pregnancy care, but not for postpartum care following childbirth. The law applies to fertility treatment or care appointments, including in vitro fertilization.
• Employers cannot require verification of employee eligibility or other documentation of the need for the absence.
• The “52-week period” is measured looking forward from the first time an employee uses leave. An employee may use Leave on more than one pregnancy per year, but only 20 hours are available in a 52-week period.
• Spouses, partners, or other support persons cannot use Paid Prenatal Leave to attend prenatal appointments with a pregnant person. Paid Prenatal Leave may only be used by the employee directly receiving prenatal health care services.

Paid Leave Oregon Pre-Placement Leave

As a reminder, effective January 1, 2025, Paid Leave Oregon covers “pre-placement leave.” Pre-placement leave is available to eligible employees needing time away from work to attend required appointments prior to adoption or foster placement:

• Counseling sessions
• Court appearances
• Legal consultations
• Physical examinations
• Home studies
• Related travel to another state or country
• Other tasks critical to completing the legal adoption or foster care process

Leave for this reason was previously covered under OFLA but is no longer available as of December 31, 2024.

Paid Leave Oregon Batch 12 Rules

Paid Leave Oregon recently filed their batch 12 rule changes, which was approved by the Oregon legislators and went into effect 01/01/2025.  Below are changes we want to highlight:

• OAR 471-070-0930 – Permissible Disclosure: Amendment to confidentiality rules, allowing PLO weekly benefits to be reported to employers.
• OAR 471-070-1000 – Benefits: Definitions added related to pre-placement and foster care leave (detail above). “Pre-placement leave” can be used before the actual foster or adoption placement of a child, if leave is required for the placement process.
• OAR 471-070-1100 – Benefits: Amendment to application process related to pre-placement and foster care. Requirement added to obtain verification for both pre-placement and foster care leave.
• OAR 471-070-1115 – Benefits: Requires one of the following verification forms for pre-placement:
  • Court order verifying the intended placement.
  • Letter signed by the attorney representing the foster or adoptive parents verifying intended placement.
  • Document from foster care or adoption agency involved.
  • Document for the child issued by the US Citizenship and Immigration Services.
  • Documents approved by the department for this purpose.
• OAR 471-070-1120 – Benefits: Amendment requiring certain information to determine serious health condition – specifically, applicants need to provide a description of the condition, meaning symptoms or required treatment.
• OAR 471-070-1320 – Weekly benefit amount added to employer communication.
• OAR 471-070-1420 – Benefits: Proposed amendment clarifying how pre-placement leave can be taken – pre-placement leave can only be taken on an intermittent basis. The State is taking an interesting stance here because pre-placement travel, specifically out of state or country, would not be intermittent.

Annual Equivalent Plan Report

Employers with private plans must file an annual Equivalent Plan Report with the OED by January 31, 2025. The first reporting period for annual reporting runs from September 3, 2023, through December 31, 2024. The report requires the following information: Total benefit applications approved and denied during the period, number of leave workdays taken for all employees, number of benefit applications canceled before leave, number of appeals received after denial decision issued, number of employees who appealed their denial and were granted, and number of employees who appealed their denial and were denied benefit.

For employers who withhold employee contributions, they must also report aggregate financial information and include the following: A total amount of employee contributions withheld during the reporting period, total plan expenses paid during the reporting period, including the total benefit amount paid and total administrative costs, the balance of employee contributions held in trust at the end of the reporting period, and the balance of benefits approved but not yet paid, if the plan is an employer-administered plan and the plan is ending.