It may be difficult to do justice to both your company policy (and the likely purpose of giving employees flexibility) and the legal requirements of leave laws, but here are some tips:

• Educate your employees on their state and federal leave rights and covered leave reasons so that they understand reporting requirements and other obligations despite unlimited time off through your company.
• Follow all requirements of the various leave laws (the FMLA, state FMLA equivalents, other state leave programs, etc.). This includes employee notices and approval/denial of leaves. Don’t skip items in this area as these are legal requirements, and your compliance efforts need to be aligned with existing laws.
• Require employees to report their time off covered by these laws to your leave administrator (internal or external) so that you can document employee usage and your compliance with the laws if requested by a state or federal regulator.