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12.08.25
Minnesota Paid Family and Medical Leave: Managing Leave in Your Workplace
By Cale Dunwoody, Vice President of Public Policy, FMWF Chamber
Learn how to manage Minnesota PFML in your workplace. Get guidance on leave requests, benefits, compliance and supporting employees in 2026.
January 2026 will be here before we know it, and with it comes a new set of responsibilities for Minnesota employers. Beyond premiums and payroll updates, the most significant impact will be how Minnesota Paid Family and Medical Leave (PFML) leave requests are managed day-to-day. Understanding your role now will help ensure a smooth transition for your team and your operations.
Here’s what you need to know to manage PFML in your workplace.
Your Role in the PFML Application Process
Under PFML, the leave process begins with the employer. Before an employee can apply for benefits, they must notify you. Here is the application process for PFML:
- Employee notifies employer about intention to take leave.
- Employee submits an application for Paid Leave.
- The company’s Paid Leave Administrator reviews the application for leave.
- The State’s Paid Leave Division makes a decision regarding the employee's application.
- Employee and Paid Leave Administrator are notified of the determination.
Be sure to establish clear internal procedures now so employees know exactly who to notify and how.
During this process, you can:
- Review the applications submitted by employees.
- Confirm that the information submitted by the employee is correct.
- Track the status of the applications.
- View past determinations from Paid Leave.
- You can require employees to comply with your usual and customary leave notice requirements, unless the reason for an employee’s leave prevents this.
Continuous vs. Intermittent Leave: What Employers Can Define
Employees may take leave all at once or in smaller increments throughout the year. Employers can set reasonable parameters around how intermittent leave is used.
Key considerations include:
- Intermittent leave increments: Employers determine the shortest block of time employees are allowed to use intermittent leave. From one minute to one day, an employer may require larger blocks such as half-days or full days for intermittent leave.
- 480-hour rule: An employee may take up to 480 hours of intermittent leave in a year, which is equal to 12 weeks at 40 hours per week. After an employee uses those 480 hours, the employer may require any remaining PFML leave—up to the 20-week annual maximum—to be taken as one continuous block for the rest of that benefit year.
Coordinating PFML with PTO, Sick Leave, FMLA and PPL
PFML does not replace existing employer policies. Employers may decide how PFML interacts with their current benefits.
- PTO, sick time, vacation: Employers may offer these benefits as supplement payments to “top off” an employee’s PFML benefits, to make up the difference between an employee’s Paid Leave benefits and regular pay.
- Substitute Benefits: An employee may elect to use their PTO, sick time and vacation time to substitute PFML benefits, to receive full wages during their leave. This must be reported to the Paid Leave division, and the division will adjust the employee PFML payment.
- FMLA and PPL: Employers may require FMLA and PPL to run concurrently with PFML benefits.
- ESST: Paid Family and Medical Leave and Earned Sick and Safe Time (ESST) are different programs. ESST is paid time off employers must provide to employees in MN for certain uses.
- Other Leaves: If an employer shows that an employee has already taken job-protected leave for a reason that qualifies under Paid Leave once the program starts, then the amount of Paid Leave the employee can take may be reduced.
Employers cannot require employees to use PTO before or during PFML, but you may offer it as an optional “top off” to, or substitute of, PFML benefits.
Job Protections and Benefits During PFML
PFML includes strong employee protections. While on leave, eligible employees must receive:
- Job protection: Employees must be restored to the same or an equivalent role with the same pay, benefits and seniority. Job protections take effect 90 days after date of hire.
- Health insurance continuation: Employers must generally continue to fund their portion of health insurance premiums during the leave.
- Anti-retaliation: Employers cannot interfere with or retaliate against employees using PFML.
Supporting a Smooth Return to Work
Consider how your organization will:
- Utilize Small Employer Assistance Grants (up to $3,000) if your business qualifies.
- Plan for temporary coverage during extended absences.
- Support a phased or flexible transition back to work.
If You Missed Earlier Parts of the Series
If you're building your PFML preparedness plan, be sure to review earlier articles in our Minnesota PFML series:
- Minnesota Paid Family and Medical Leave: What Employers Need to Know – Overview of eligibility, covered leave types and business impacts
- Minnesota Paid Family and Medical Leave: Premiums, Taxes and Employer Costs – Understanding payroll deductions, premium structure and tax implications
- Your PFML Compliance Checklist – Three key steps to ensure your business is ready before January 2026
These resources offer essential context before you finalize your policies and procedures.
Disclaimer: Please consult an HR professional or employment attorney to ensure full PFML compliance for your business. Information in this article was sourced from the Minnesota Department of Employment and Economic Development (DEED) to ensure accuracy and clarity for employers preparing for Minnesota Paid Family and Medical Leave compliance.
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