FMLA and QIP

Our company offers Quality Incentive Pay to employees each December, money permitting. A number of factors including attendance are taken into consideration in determining the amount an employee is paid. Currently, FMLA hours have been treated as hours worked. We are considering changing from sick, vacation, etc. to Paid Time Off. Management would like to consider paid time off in determining a "bonus" amount. For example, if an employee was out more than four weeks the QIP would be reduced. QIP would be further reduced for additional time off. With PTO would we be required by law to distinguish FMLA hours and to treat FMLA hours as actual work hours (i.e if an employee is out of work 5 weeks PTO for a FMLA qualifying event can we legally reduce QIP?)? Management would like to reward employees based on actual hours worked. I would appreciate any reference to FMLA regs which would apply. Thanks.

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