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Run: Paid Family Leave State Programs Policy

A Paid Family Leave State Programs Policy that explains eligibility, benefit coordination, FMLA interaction, and reinstatement for state paid family leave cl...

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Purpose

This policy explains how the policy holder administers state paid family leave benefits, coordinates those benefits with FMLA and other leave programs, and manages employee notice, documentation, benefits continuation, and reinstatement obligations. This policy is intended to be applied consistently while honoring all applicable federal, state, and local laws, including state paid family leave statutes and the FMLA.

Scope

This policy applies to all employees in jurisdictions where a state paid family leave program exists, as well as to managers, HR, payroll, and leave administrators responsible for processing leave requests. **California employees:** leave administration must also account for California Paid Family Leave and any related job-protected leave rights under applicable California law. **New York employees:** leave administration must account for New York Paid Family Leave and any applicable reinstatement, notice, and benefits rules. **Washington employees:** leave administration must account for Washington Paid Family and Medical Leave and any applicable job protection thresholds. If a state law provides greater rights than this policy, the law controls.

Definitions

For purposes of this policy: - **Eligible employee** means an employee who meets the applicable state program requirements and any employer administrative requirements that do not conflict with law. - **Qualifying reason** means a family-related reason covered by the applicable state paid family leave law, such as bonding, caring for a family member, or other covered family care events. - **Benefits coordination** means the process of determining how state paid family leave interacts with employer-provided PTO, sick leave, vacation, short-term disability, and unpaid leave. - **Equivalent position** means a position with substantially similar pay, benefits, shift, location, status, and essential function requirements, as required by law. - **Good-faith** means honest, timely participation in the leave process, including providing accurate information and responding to reasonable requests for documentation.

Policy Statement

The policy holder will administer state paid family leave in compliance with applicable law and will not interfere with, restrain, or deny rights provided under state leave laws or the FMLA. Employees may use state paid family leave only for qualifying reasons under the applicable state program and must follow the notice and documentation requirements described in this policy. Where leave qualifies under both a state paid family leave program and the FMLA, the policy holder may designate leave concurrently to the extent permitted by law. The policy holder will maintain benefits, restore employees to work as required by law, and engage in the interactive process when an employee requests a reasonable accommodation related to return-to-work or an essential function of the job.

Procedure

1. **Notice of need for leave** - Employees should notify HR or their manager as soon as practicable when they know they may need leave. - If the need for leave is foreseeable, employees should provide advance notice in accordance with the applicable state law and company reporting procedures. 2. **Leave request submission** - Employees must submit the required leave request forms and supporting documentation requested by the state program or the policy holder. - HR may request only information permitted by law and will handle medical and family information as confidential personnel data. 3. **Eligibility review** - HR or the leave administrator will review the request for state program eligibility, FMLA eligibility, and any other applicable leave rights. - The policy holder will notify the employee of approval, denial, or additional information needed within the timeframes required by law. 4. **Benefits coordination** - The policy holder may require or allow employees to use accrued PTO, vacation, or sick leave to supplement or coordinate with state paid family leave only to the extent permitted by law. - If short-term disability or another wage-replacement benefit applies, HR will coordinate benefits to avoid prohibited duplication or offset issues. 5. **Concurrent leave designation** - When permitted, the policy holder may designate leave concurrently under the FMLA and the applicable state paid family leave law. - Employees will be informed when concurrent designation applies and how it affects leave balances and job protection. 6. **Return-to-work and reinstatement** - Before returning from leave, employees may be asked to provide a fitness-for-duty certification or other return-to-work documentation only if permitted by law and job-related. - The policy holder will reinstate employees as required by the applicable state law and the FMLA, subject to lawful exceptions. - If the employee cannot perform one or more essential functions of the job upon return, HR will engage in the interactive process to evaluate whether a reasonable accommodation is available.

Roles & Responsibilities

**Employees** must provide timely notice, truthful information, and required documentation; use leave only for qualifying reasons; and communicate return-to-work timing. **Managers** must route leave requests to HR promptly, avoid discouraging or interfering with leave use, and maintain confidentiality. **HR / Leave Administrator** must evaluate eligibility, coordinate benefits, issue required notices, track leave usage, and manage reinstatement and recordkeeping. **Payroll** must administer wage replacement, offsets, and deductions as directed by HR and in accordance with applicable law. **Policy holder** must ensure the policy is applied consistently and in good faith, with state-specific carve-outs where required.

Compliance / Discipline

Failure to follow this policy, including failure to provide required notice, misuse of leave, falsification of documentation, or interference with leave administration, may result in delay, denial, or termination of leave benefits to the extent allowed by law and may also result in corrective action up to and including termination. Nothing in this policy limits employee rights under the FMLA, the NLRA, the ADA, Title VII, or applicable state leave laws. Any discipline will be applied in a non-retaliatory manner and consistent with documented warning and PIP procedures where performance issues are unrelated to protected leave.

Review & Revision

This policy will be reviewed at least annually and whenever state paid family leave laws, FMLA guidance, or related wage-and-hour requirements change. The policy holder may update jurisdiction-specific provisions, including state carve-outs, notice forms, and reinstatement procedures, without prior notice where permitted by law.

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