September 2026 Iowa Q&A roundup

Q           We have a paid-time-off (PTO) policy that combines sick and vacation time, with no separate bank for paid sick leave. Can we require the use of PTO for all types of reasons, like pregnancy, serious health conditions, etc., and can we continue requiring the use of PTO to supplement the state’s wage replacement benefits?

This will depend entirely on what state you’re in and the structure of the state system. Under federal law, PTO is PTO, with no distinction for reason. Depending on the state, you could have a mandated state-paid leave that’s financed through payroll taxes or a statute that requires you to offer internally paid leave. 

One area to review very carefully relates to your statement about using PTO “to supplement the state’s wage replacement benefits.” You generally can’t require that someone use PTO and another form of wage replacement at the same time. This is also true of the Family and Medical Leave Act (FMLA). Because the FMLA is unpaid, you can require the concurrent use of PTO, but if there’s another payment available, like workers’ compensation, you can’t require that the employee also use PTO, even as a supplement.