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Inside the Issues: Navigating Proposition A

Navigating Proposition A: Compliance Strategies and Insights for Employers 

On February 27, 2025, the Springfield Chamber of Commerce hosted Inside the Issues: Navigating Proposition A – Compliance & Implementation Insights, with a panel of experts aimed at helping local businesses navigate the upcoming changes under Proposition A. The panel featured Sara Choate (KPM CPAs & Advisors), Carolyn O’Kelley (Ollis / Akers / Arney Insurance and Business Advisors), and Kristen O’Neal (Spencer Fane LLP), each providing valuable insights into compliance, strategic planning, and legal considerations.

Proposition A Overview

Passed through a statewide vote in November 2024, Proposition A introduces statutory changes to mandatory paid sick leave requirements and a minimum wage increase for eligible employers in Missouri. Notably, the law does not apply to public employers and businesses with annual gross revenue under $500,000, but it generally affects all other employers.

As of January 1, 2025, the minimum wage was increased to $13.75 per hour, increasing to $15.00 per hour on January 1, 2026. Starting January 1, 2027, this will be adjusted annually based on changes in the Consumer Price Index.

Proposition A also requires eligible employers to provide one hour of paid sick leave for every 30 hours worked. Key components of the paid sick leave portion include:

  • Employees can take leave in 1-hour increments, and employers cannot request proof unless leave consists of three or more consecutive workdays;
  • Proposition A leave is defined as a protected absence, similar to ADA and FMLA;
  • Employees can carry over up to 80 hours of unused paid sick leave from one year to the next, though employers with 15 or more employees may cap the usage to 56 hours per year or 40 hours annually for smaller businesses;
  • Employers do not have to pay out accrued sick time if an employee leaves* or is terminated;
    • *If an employee leaves and returns within nine months, they are entitled to their previously accrued sick leave;
  • Employers may choose to frontload sick leave or have employees accrue sick leave over time; and
  • Employers must keep a record of all Proposition A sick leave usage.

Next Steps

Although there are many unknowns with the implementation of the paid sick leave provisions due to an ongoing lawsuit and efforts from the Missouri State Legislature to amend statutory language, panelists overall emphasized that businesses should first take a strategic approach to compliance by assessing their current policies and making informed adjustments.

Assess Current Policies and Define Business Goals – Proposition A presents an opportunity for businesses to evaluate and refine their existing leave policies. Companies should assess what is effective, identify areas for improvement, and establish a clear and compliant approach moving forward. The panel recommended starting with a thorough review of current policies, determining desired updates and outcomes, and then bridging the gap between those goals and the requirements of Proposition A.

Determine Your Cost and Risk Analysis – Calculate financial impacts of the different options identified within Proposition A, including frontloading time vs. accrual models and how to manage potential rollover of time or time sharing. Engaging with an attorney as you work through potential policy options can help clearly identify the level of risk you are willing to take within the currently ill-defined requirements.

Identify Tracking Challenges – For ease of tracking and complying with all the provisions of Proposition A, it was recommended for employers to shift from frontloading sick time to an accrual-based method to protect themselves from potential complications. Although it’s not required in the statutory language, it was recommended that employers track vacation time, or time outside of the Proposition A required paid sick leave, separately from the Proposition A time. It was not recommended that employers ask employees to specify the exact protected reason they are taking the Proposition A paid sick leave, just that this leave falls under one of the eligible uses. While the statutory language is unclear on whether employers must provide employees with continuous access to seeing their accrued sick time balance, doing so may be considered a best practice with the increased tracking.

Communicate with Employees – Missouri employers must provide written notice to employees about their rights under Proposition A by April 15, 2025. This notice must inform employees of their entitlement to paid sick leave, the rate of accrual, permitted uses, and protections against retaliation for using leave. Employers can satisfy this requirement by posting a notice in a visible location at the workplace in no less than 14-point font. Panelists also recommended not rolling out an official policy until more guidance has been provided; however, communicating your intentions and efforts as an employer to comply with this law early and often is crucial. The panel strongly urged employers to prepare transparent and consistent messaging to reassure employees that their rights are being recognized and upheld, rather than overlooked. Not having the messaging prepared may allude to a lack of transparency.

Prepare for Regulatory Changes – The Missouri Department of Labor and Missouri Chamber have released an FAQ related to the paid sick leave, however, guidance remains broad. It is recommended that businesses stay alert to new guidance, including from any legal sources, business groups or associations, state departments, and more. Additionally, several bills are moving through the legislature in an attempt to soften the impact on businesses by delaying the rollout, reworking the accrual amount, exempting small businesses and more. However, note that the legislative session runs through May, and unless an emergency clause is passed with a bill, the earliest a change would statutorily go into effect is August 2025 (barring any legal action). The Springfield Chamber is closely monitoring and engaging in the movement of these proposals.

Remain engaged and consult experts – Panelists stressed that many questions surrounding Proposition A remain unanswered, and that employers should remain engaged in the process. They encouraged employers with questions to seek legal counsel and strongly recommended that they err on the side of caution when crafting their policies. It was also recommended that employers have detailed documentation when making termination decisions after Proposition A, specifically clearly identifying any performance issues to help avoid litigation or claims related to the protected paid sick leave time.

Operate Under Assumption Paid Sick Leave Will Go Into Effect on May 1 – Another key recommendation from the panel was to proceed under the assumption that Proposition A will take effect as scheduled, rather than relying on potential legislative changes or delays. They advised businesses to develop a compliance plan in advance but to remain flexible, implementing changes only when required to account for any legal or legislative developments. While uncertainties remain, businesses are advised to prepare now, stay informed, and engage in strategic planning to ensure smooth implementation.

For further updates and resources, stay connected with the Springfield Chamber and industry experts. If you have specific questions related to Proposition A legislation, please reach out to the Chamber’s public affairs team; if you have questions about your own specific policy, please reach out to a legal representative for further guidance.

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