CA AB 1522 - Mandatory SL ? Re: "Book" vs. "Accrue"

My client is a federal contractor, with a large CA operation. Under the terms of their contract, and in line with the provisions of the Service Contract Act, non-exempt employees do not accrue leave from the start of their employment, but rather they receive 10 days of leave that are "booked" at the end of the first year of service.

AB 1522 requires that employers begin accrual of Sick Leave after 90 days of employment, and employees are entitled to accrue paid sick days at a rate of no less than one hour for every 30 hours worked. Employers may limit the employee's annual use of paid sick leave benefits to 24 hours or 3 days per year, and cap the accrual of paid sick leave to 48 hours or 6 days per year.

My questions are these, and I'm looking for any feedback you may have:

1. Rather than set up a new accrual system just for the first year of service under the federal contract, my client wants to simply "book" 24 hours of SL to its CA employees at the 90-day mark, which I presume would be fine under AB 1522 even though the law specifies "accrual" of sick days ... it seems to me that "booking" the 3 days is more generous than the CA requirements, and as such CA would not have a problem with that ...

2. My client is also thinking about perhaps deducting the 3 sick days booked from the 10 days that they would normally book after the first year of service under the federal contract. My instinct is that I wouldn't mess with the SCA requirements without getting a written authorization from the Contract Officer who oversees the contract.

Anyone have any thoughts, or preferably any citations to support or refute what I've outlined above? Thanks,

Dr. Steve
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