Changing FMLA counting methods can be challenging and requires keen attention to detail, but may well be worth the effort for your organization. Although a rolling backwards calendar can be the most complex to administer without the assistance of software, there are many advantages to the employer.

Under the regulations, you must provide employees with at least a 60-day notice of the upcoming change. You will also need to remember that any benefit period designated in other statutory leaves will be retained ꟷ even if different than what you select under the FMLA ꟷ which may result in different leave years for different types of leave.

Lastly, and probably the most challenging, it will require looking at any employees currently utilizing FMLA benefits. You need to ensure that the transition takes place in such a way that each employee retains the full benefit of their leave entitlement under whichever method that gives the employee the greatest benefit.