PTO Donation: A Small Business Guide to Leave Sharing

How PTO donation works, the tax trap that catches employers, the two IRS exceptions, and how to set up a leave donation program without an HR department.

Nick Anisimov

FirstHR Founder

Benefits•

July 22, 2026

•

18 min

PTO Donation

How leave sharing works, the tax trap that catches good intentions, and how to set one up without an HR department

Someone on your team is going through something serious and has run out of paid time off. A coworker, unprompted, offers to give them some of theirs. It is one of the better moments you get as an employer, and your instinct is to say yes immediately.

Wait a beat first. Not because the answer is no, but because of a genuinely counterintuitive rule: if you do this informally, the person being generous can end up paying tax on time off they gave away and never used. Income is taxed to whoever earned it, and handing your PTO to a coworker does not move that liability. The exceptions that fix this exist, they are narrow, and they require a written plan that is in place before anybody needs it.

This guide covers what PTO donation is, the tax trap and the two IRS exceptions in plain English, the three structures available, who gets taxed in each scenario, whether a small team should offer this at all, how to set one up, policy language you can adapt, and the compliance traps. Tracking balances and donated hours across a small team is what I built FirstHR for. This is general information rather than tax or legal advice, and the tax outcome here depends on details worth confirming with a professional.

TL;DR

PTO donation, or leave sharing, lets employees give accrued paid time off to a coworker in serious need. The catch is the assignment-of-income doctrine: outside a qualifying plan, the donor is taxed on the value of leave they gave away and gets no deduction for it. Two IRS exceptions flip that: a written medical emergency plan under Revenue Ruling 90-29, and a written major disaster plan under Notice 2006-59. Under either, the donor is not taxed and the recipient is taxed on what they receive as wages. The plan must exist in writing before anyone needs it.

The Short Answer

PTO donation, also called leave sharing, is a program that lets employees give accrued paid time off to a coworker facing a serious need. Under a qualifying written plan the donor is not taxed and the recipient is taxed on what they receive as wages. Without a qualifying plan, the donor is taxed on leave they gave away.

That last sentence is the whole reason this topic requires care rather than just goodwill, and it is the part most employers learn after the fact.

IRS exceptions that make donated leave tax-free for the donor

Charitable deduction a donor gets, in every structure, without exception

Before

When the written plan must exist: before any qualifying event, not after

What PTO Donation Is

A leave donation program is a company arrangement that lets employees surrender some of their accrued paid time off so a coworker with a qualifying need can be paid while they are out. It is voluntary in every direction: no law requires you to offer it and no employee can be required to give.

Definition

PTO Donation (Leave Sharing)

PTO donation, also known as leave sharing or a leave donation program, is an employer-administered arrangement under which employees may voluntarily surrender accrued paid time off, typically into an employer-sponsored leave bank, for use by a coworker experiencing a qualifying hardship such as a medical emergency or a federally declared major disaster. Because donated leave is compensation the donor already earned, the federal tax treatment depends on whether the plan meets specific IRS requirements. A qualifying written plan shifts the tax from the donor to the recipient.

Two structural points shape everything that follows. First, almost all workable programs use a leave bank: employees deposit hours into a pool and a recipient applies to draw from it, rather than naming a person directly. That keeps it from becoming a popularity contest and, under the disaster rules, direct designation is not permitted at all.

Second, the recipient is paid at their own rate, not the donor's. This has a consequence people find genuinely surprising, and it gets its own section below because explaining it after someone donates goes badly. If you are still designing how PTO builds up in the first place, the accrued PTO guide covers the accrual mechanics this program sits on top of.

The Tax Trap

Here is the rule that catches good intentions. Income is taxed to the person who earned it, and you cannot escape that by assigning it to somebody else. This is the assignment-of-income doctrine, and it applies squarely to accrued paid leave.

What Goes Wrong Without a Qualifying Plan

If an employee gives PTO to a coworker outside a plan that meets the IRS requirements, the cash value of the surrendered leave is included in the donor's gross income as wages. They pay income tax and payroll tax on time off they never took and no longer have. They also get no charitable deduction, no expense deduction, and no loss deduction for it. The person who did something kind ends up with a smaller paycheck and nothing to show for it, and they will find out when they see the pay stub rather than when they volunteered.

What makes this more than theoretical is how narrowly the exceptions are drawn. In a private letter ruling, the IRS examined one employer running two versions of a leave program. The existing version, limited to medical emergencies, qualified: donors were not taxed. A proposed modification that would also have covered employees facing a catastrophic casualty loss did not qualify, because it was no longer limited to medical emergencies and was not limited to a presidentially declared disaster either. Same employer, same generosity, one broader clause, and the tax bill moved onto the donors.

That is the practical lesson for a small business: breadth is the enemy here. The instinct to write a policy covering any employee going through a hard time is exactly the instinct that disqualifies the plan.

The Two IRS Exceptions

Two structures let the donor avoid tax, and both require a written plan. Everything else is the general rule above.

Exception 1: Medical Emergency Plans

Grounded in Revenue Ruling 90-29, this covers a medical condition of the employee or a family member that requires a prolonged absence from work and will result in substantial income loss because the employee has exhausted all other paid leave. Requirements: a written plan, a written application from the recipient describing the emergency, exhaustion of the recipient's own leave first, reasonable limits on donations, and return of unused leave. Under this structure the donor is not taxed, and amounts paid to the recipient are their taxable wages.

Exception 2: Major Disaster Plans

Governed by IRS Notice 2006-59, this requires a major disaster declared by the President under the Stafford Act. Donors deposit leave into a bank and may not designate a recipient. Annual donations must not exceed what the employee normally accrues in a year, the leave must be used for the specified disaster, and unused leave must be returned within a reasonable period. Per the IRS's own leave sharing FAQ, an employee who deposits leave under such a plan need not include it in income or wages, and may not claim any deduction for it.

For a small business, the medical emergency structure is almost always the relevant one. Disasters are episodic and the plan has to be tied to a specific declared event, whereas a medical emergency plan can sit in your handbook indefinitely, waiting for the day someone needs it.

Note the asymmetry that runs through both exceptions: the donor escapes tax but gets no deduction, and the recipient pays tax on money they are receiving during the worst month of their year. That second part deserves a mention in the policy, because a recipient who expects the full headline value will be short.

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The Three Structures

Three arrangements get called leave donation, and they behave differently enough that picking the wrong one is a real error.

Medical emergency planThe one most small businesses actually want

Covers a serious medical condition of the employee or a family member requiring a prolonged absence

Donor is not taxed. Recipient is taxed on what they receive, as ordinary wages

Requires a written plan, and the recipient must exhaust their own paid leave first

Grounded in Revenue Ruling 90-29, the foundational IRS authority for this structure

Major disaster planNarrower than it sounds, and event-specific

Requires a disaster declared by the President under the Stafford Act, not just a bad local event

Donor is not taxed. Recipient is taxed as wages unless the payments separately qualify as disaster relief

Bank-based only: the donor cannot name a specific recipient

Annual donations capped at what the employee normally accrues in a year

Leave-based charitable donationEmployees give up leave, you write a check to a charity

The employer converts forgone leave into a cash payment to a qualifying charity

Under specific disaster-related IRS notices, the donor is not taxed and it stays off their W-2

The donor gets no charitable deduction. The employer deducts it as a business expense

Available only when the IRS has issued a notice for a particular event, not as a standing program

The third structure answers a question employees ask more often than employers expect: can I donate my PTO to charity? The honest answer is that a route exists but it is not a standing program. The IRS issues notices enabling leave-based donations for particular disasters, and outside those windows an employee simply forgoing leave while you write a check has no special treatment.

Worth flagging in every structure: the donor never gets a charitable deduction. Not in the medical emergency plan, not in the disaster plan, and not in the charitable structure where the employer takes the business deduction instead. People assume otherwise, and it is a kindness to say so before they donate.

Value Transfers, Not Hours

Here is the mechanic that surprises nearly everyone, including employers who have already launched a program. When leave moves between employees at different pay rates, what transfers is the dollar value, not the hour count. The figures below come from an IRS private letter ruling describing an actual employer's plan.

What actually transfers: value, not hours

This is the IRS's own worked example, from a private letter ruling describing a real employer's plan. It surprises almost everyone the first time they see it.

Donor's hourly rate$15.00

Hours surrendered by the donor8 hours

Value transferred (8 x $15.00)$120.00

Recipient's hourly rate$10.00

Hours the recipient actually receives ($120 / $10.00)12 hours

Eight donated hours became twelve received hours, because the recipient is paid at their own rate. Run it the other way and eight hours from a lower-paid donor becomes fewer hours for a higher-paid recipient. Tell people this before they donate, because "I gave a day and they only got half a day" is a genuinely upsetting surprise.

The direction that causes friction is the reverse case. A donor earning $18 who gives eight hours transfers $144, which for a recipient earning $24 buys six hours rather than eight. The donor gave a full day and the recipient received three quarters of one. Nothing went wrong, but it feels like something did.

Say this in the policy and say it again when someone offers to donate. It costs one sentence and it prevents the only conversation in this entire program that makes a generous person feel cheated.

Who Gets Taxed, In Each Case

Four scenarios cover essentially every situation a small employer will encounter. Two work and two do not.

Qualifying medical emergency plan

DonorNot taxed on the surrendered leave. No deduction either

RecipientTaxed as ordinary W-2 wages at their own pay rate

Qualifying major disaster plan

DonorNot taxed on the deposited leave. No deduction either

RecipientTaxed as wages, unless the payments separately qualify as disaster relief

Informal transfer with no written plan

DonorTaxed on the cash value of the leave they gave away, as wages

RecipientReceives the pay. May also face tax consequences depending on the facts

Written plan that covers events beyond the two exceptions

DonorTaxed. Broadening the plan is what breaks it, even with everything in writing

RecipientDepends on the facts, and the IRS has declined to rule generally on this

The fourth row is the one worth studying, because it is the trap that catches thoughtful employers rather than careless ones. Writing a policy is necessary but not sufficient. A carefully drafted plan covering general hardship, financial difficulty, or bereavement alongside medical emergencies is a well-intentioned document that does not qualify, and the donors bear the cost of that.

If you want to help people with situations outside the two exceptions, and there are good reasons to want that, do it through a mechanism designed for the purpose: paid bereavement leave, an emergency fund, a pay advance, or simply granting additional paid leave. Do not route it through leave donation and assume the tax treatment follows.

Should a Small Business Offer This?

Sometimes, and the honest answer at very small sizes is often no. This is the section every vendor guide skips, because the reasons against are structural rather than administrative.

Pros

It costs the employer almost nothing directly, since the leave was already accrued and owed

It gives a team a real way to help a colleague, which matters more culturally than most benefits

It reduces the pressure on you to make an expensive discretionary decision under emotional circumstances

The written plan gives you a consistent answer to a request that is otherwise decided case by case

For employers in payout states, using accrued leave rather than banking it is not a bad outcome

Cons

Below roughly ten people, a single request needs most of the team to contribute, which erodes voluntariness

It only works if someone has surplus leave, which is rare on teams that already take their time off

The tax rules are narrow and the penalty for getting them wrong lands on the generous person

You will inevitably know why someone needs leave, which creates a confidentiality obligation

Peer pressure is genuinely hard to prevent once a colleague's need becomes known

The voluntariness problem deserves more weight than it usually gets. On a team of eight, everyone knows who donated and who did not. The program can quietly become a test of who cares about a colleague, which is the opposite of what you intended and something the policy cannot fully fix.

The other structural issue is supply. Leave donation assumes a pool of people carrying more PTO than they will use. If your team takes their time off, which you should want, the bank may simply be empty when someone needs it, and an empty bank is worse than no program because it raised an expectation you cannot meet.

One angle that cuts the other way for employers in payout states: leave sitting on the books is a liability you will eventually settle in cash, as the PTO payout guide covers. Leave that gets donated and used is leave that leaves the balance sheet doing something useful, which is a small point in favor rather than a reason on its own.

Four Questions Before You Start

Work through these in order before writing anything. The first one is the one people skip, and it is the one that matters most today.

Is someone asking right now, in the middle of an emergency?Then a formal program is probably not your answer today, because a qualifying plan has to exist in writing before the event. Consider unpaid leave, an advance against future accrual, or a direct payment instead, and build the program afterwards.

Do you have enough people for donations to be meaningful?Below about ten employees, one person's emergency needs a large share of the team to contribute, which makes participation feel less than voluntary. Above thirty, a leave bank starts working the way it is supposed to.

Are you in a state where accrued PTO is earned wages?Then donated leave is someone giving away a legally protected asset, and your policy needs to be careful about voluntariness, records, and what happens to unused donations.

Will you scope it strictly to medical emergencies?This is the version with the clearest IRS authority behind it and the version most small businesses want. Broadening it to cover general hardship is precisely what moves the tax bill onto the donor.

If you are reading this because someone asked yesterday, question one is your answer. A qualifying plan has to exist before the event, which means the program cannot solve today's problem. What you can do today is help through another route, and then build the program properly so you are ready next time. Being ready next time is genuinely the point.

What worked for me

The thing I underestimated was the peer pressure problem, and it showed up in a way I did not anticipate. Someone had a serious family situation, a colleague offered leave without being asked, and within a day two other people had also offered. That looks like a team rallying, and partly it was. But one of them told me later they had felt obliged once they knew others had done it, and that they could not really afford the time. Nothing bad happened, but I had created a situation where declining was visible. What I would do differently is route donations through a bank with no announcement of who gave what, and say explicitly in the policy that managers do not solicit donations. The anonymity is not bureaucratic caution; it is what keeps the gesture voluntary.

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Setting Up the Program

For a business with five to fifty people and nobody doing HR full time, this is the whole implementation. It is one afternoon plus a review.

Write the plan before anyone needs it

A plan created in response to a specific person's situation invites favoritism claims and may fail to qualify for the tax treatment. This step is not procedural fussiness, it is the load-bearing requirement.

Scope it narrowly to medical emergencies

Define a medical emergency as a condition of the employee or a family member requiring a prolonged absence after other paid leave is exhausted. Resist adding general hardship.

Set neutral eligibility and apply it uniformly

Service requirement, exhaustion of the recipient's own leave, a written application. The same criteria for everyone, with no discretion to favor senior or highly paid staff.

Run it as a bank, not person-to-person

Employees deposit hours, recipients apply to draw from the pool. This preserves anonymity, prevents popularity dynamics, and is required under the disaster rules.

Cap donations and require a retained balance

An annual limit plus a floor the donor must keep for themselves. Generosity in a crisis should not leave someone with no leave for their own needs three months later.

Decide how you will protect privacy

Communicate a general need for donated leave, never medical details. Whatever you learn in the application process stays confidential and stored accordingly.

Coordinate with payroll before the first allocation

Donated hours come out of one balance and are paid to another person at their rate, as taxable wages. Agree how that is coded before it happens rather than after.

Keep records

Donor and recipient identity, hours, dollar value, and dates. If anyone ever asks whether the plan was administered consistently, the records are the answer.

Policy Language You Can Adapt

Five clauses cover a leave donation program properly. The tax clause and the privacy clause are the two most commonly missing from small-business policies, and they are the two that prevent the worst outcomes.

Leave donation policy language you can adapt

Purpose and scope

The Company maintains a leave donation program allowing employees to voluntarily surrender accrued paid time off to a leave bank for the benefit of a coworker experiencing a medical emergency. A medical emergency means a medical condition of the employee or a family member that requires a prolonged absence from work and will result in a substantial loss of income because the employee has exhausted all other paid leave available.

Recipient eligibility

To receive donated leave, an employee must have completed [90] days of service, must be eligible to accrue paid time off, must have exhausted all of their own accrued paid leave, and must submit a written request describing the nature of the emergency and the expected duration of the absence. The Company will evaluate requests using the same criteria for every applicant.

Donation rules

Donations are voluntary and may not be solicited by managers. An employee may donate up to [40] hours in any calendar year, in minimum increments of [4] hours, and may not donate leave that would reduce their own remaining balance below [40] hours. Donations are made to the leave bank rather than to a named individual.

Tax treatment

Under a qualifying plan, an employee who donates leave does not include the donated amount in income and may not claim any charitable, expense, or loss deduction for it. Donated leave paid to a recipient is treated as the recipient's taxable wages, paid at the recipient's own regular rate of pay, and is reported on the recipient's Form W-2.

Privacy and unused leave

The Company will not disclose medical details to donors or to other employees. Requests will be communicated only as a general need for donated leave. Any donated leave that is not used will be returned to donors within a reasonable period. Donated leave has no cash value and will not be paid out to any employee in cash.

This is an illustrative starting point rather than legal or tax advice. Because the tax outcome depends on the plan qualifying, have the final version reviewed before you adopt it, particularly if you employ people in a state that treats accrued vacation as earned wages.

Put this in your employee handbook rather than in a standalone document that surfaces only when there is a crisis. A program nobody knows about until the moment it is needed will be read for the first time by people who are upset, which is the worst possible reading conditions.

The Compliance Traps

Beyond the tax question, five practical issues catch small employers, and none of them is obvious from the outside.

Issue	The trap	What to do
Timing of the plan	Creating the program in response to a specific person's need	Adopt the written plan in advance, as a standing policy
Nondiscrimination	Approving requests case by case, which tends to favor tenured or senior staff	Neutral written criteria, applied identically to every applicant
Privacy and the ADA	Sharing why someone needs leave in order to motivate donations	Communicate a general need only, and keep medical information confidential
FMLA interaction	Treating donated paid leave as extending the FMLA entitlement	Donated paid leave generally runs concurrently with FMLA rather than adding to it
State wage law	Ignoring that accrued vacation is earned wages in several states	Check your states, and make voluntariness and record-keeping explicit

One piece of good news to offset all that: leave sharing plans are generally not treated as ERISA welfare benefit plans, so there is normally no Form 5500 and no summary plan description obligation. Given how much else in benefits carries ERISA baggage, that is a meaningful simplification.

The state wage law row is the one to check first if you have people in more than one state. Where accrued vacation is treated as earned wages, an employee donating leave is giving away a legally protected asset, and your documentation of the voluntary election matters correspondingly more. The state-by-state picture sits in the PTO laws by state guide.

What Employees Ask

Four questions come up every time, and having the answers ready saves a lot of individual explaining.

Do I get a tax break for donating? No. Under a qualifying plan you are not taxed on the leave you give, which is the benefit, but you cannot claim a charitable, expense, or loss deduction for it. Donating leave is not the same as donating money to charity, tax-wise.

Will the person know it was me? Under a bank-based program, no, and that is deliberate. Donations go into a pool and are allocated by the employer, which protects both the donor and the recipient from an awkward personal obligation.

What if they do not use it all? Unused donated leave is returned to donors within a reasonable period. It is not kept by the company and it is not paid out in cash to anyone.

Is the leave I receive tax-free? No. Donated leave paid to you is ordinary taxable wages at your own rate of pay, and it appears on your W-2 like any other pay. Worth knowing in advance, because the net amount will be lower than the gross figure you were told about.

Where Employers Get This Wrong

Six failure patterns, and the first two account for most of the real damage.

The Recurring Failures

Allowing an informal transfer with no written plan, which taxes the donor on leave they gave away. Writing a plan that is too broad, covering general hardship alongside medical emergencies, which disqualifies the whole thing. Creating the program after a specific person needs it, which invites favoritism claims and may not qualify. Sharing medical details to encourage donations. Letting managers solicit donations, which quietly converts voluntary into expected. And never telling people that value transfers rather than hours, so a donor discovers the difference at the worst moment.

The second failure is the one worth guarding against most actively, because it comes from a good instinct. Every employer writing this policy wants to help the person whose house flooded, whose parent died, or who is going through a divorce. Those are real needs and they deserve support, just not through this mechanism. Keep the leave donation plan narrow, and meet the other needs another way.

Key Takeaways

PTO donation lets employees give accrued paid time off to a coworker in serious need. No law requires it, so the program is entirely voluntary for the employer.

Outside a qualifying plan, the assignment-of-income doctrine taxes the donor on the value of leave they gave away, with no deduction available.

Two IRS exceptions flip that: a written medical emergency plan under Revenue Ruling 90-29, and a written major disaster plan under Notice 2006-59.

Under both exceptions the donor is untaxed and the recipient is taxed on what they receive as ordinary W-2 wages at their own pay rate.

The donor never gets a charitable deduction, in any structure. People assume otherwise and should be told before they donate.

The plan must exist in writing before any qualifying event. A program created for a specific person may fail to qualify and invites favoritism claims.

Breadth disqualifies. A plan covering general hardship alongside medical emergencies falls outside both exceptions, and the IRS has said so on those facts.

Value transfers, not hours. Eight hours from a $15 donor becomes twelve hours for a $10 recipient, and fewer hours when the rates run the other way.

Below roughly ten employees, one request needs most of the team to contribute, which makes participation hard to keep genuinely voluntary.

Leave sharing plans are generally not ERISA welfare plans, but FMLA concurrency, ADA confidentiality, and state wage law all still apply.

Frequently Asked Questions

What is PTO donation?

PTO donation, also called leave sharing or a leave donation program, is an arrangement that lets employees give some of their accrued paid time off to a coworker who has run out and faces a serious need. The employer runs the program, usually through a leave bank rather than person-to-person transfers. Because donated leave is compensation someone already earned, the tax treatment is not intuitive: it is only tax-free to the donor if the program fits one of two narrow IRS exceptions, and outside those exceptions the donor is taxed on leave they gave away.

Can you donate PTO to another employee?

Yes, if your employer runs a program that allows it, but there is no legal right to do so and no employer is required to offer one. The FLSA does not require paid time off at all, so leave donation programs are entirely voluntary on the employer's part. Where a program exists it is normally structured as a bank: employees deposit hours, and an employee with a qualifying need applies to receive them. Direct person-to-person designation is generally discouraged and is specifically not permitted under the major disaster rules.

Is donated PTO taxable?

It depends entirely on whether the program qualifies. Under a properly structured plan, the donor is not taxed on the leave they surrender and the recipient is taxed on what they receive as ordinary W-2 wages. Outside a qualifying plan, the assignment-of-income doctrine applies: income is taxed to the person who earned it, so the donor is taxed on the cash value of the leave they gave away and gets nothing for it. The donor never gets a charitable deduction in either case, which surprises people who assume donating leave works like donating money.

What are the two IRS exceptions for leave donation?

The first is a medical emergency plan under Revenue Ruling 90-29, covering a medical condition of the employee or a family member requiring a prolonged absence that will cause substantial income loss after other paid leave is exhausted. The second is a major disaster plan under Notice 2006-59, which requires a disaster declared by the President under the Stafford Act. In both cases the plan must be in writing, and in both cases the donor escapes tax while the recipient is taxed on what they receive as wages.

Can employees donate PTO to charity?

Not directly, but a related structure exists. Under a leave-based donation program, employees forgo leave and the employer makes a corresponding cash payment to a qualifying charity. Under IRS notices issued for specific disasters, the employee is not taxed on the forgone leave and it stays off their W-2, but the employee gets no charitable deduction. The employer deducts the payment as a business expense instead. Importantly, these notices are issued for particular events rather than creating a standing program you can run year-round.

Does my company have to allow PTO donation?

No. There is no federal requirement to provide paid time off at all, let alone to allow employees to transfer it, and no state mandates a leave donation program. It is entirely a voluntary employer decision. That said, once you do offer one, you take on real obligations: the plan must be in writing, eligibility criteria must be applied consistently rather than case by case, and you must handle medical information with appropriate confidentiality. A program run informally creates more exposure than not having one.

How much PTO can an employee donate?

Your policy sets the limit, within some structural constraints. Under a major disaster plan, the amount an employee donates in a year must not exceed the maximum leave they normally accrue during that year. For a medical emergency plan the guidance calls for reasonable limits rather than a fixed cap. As a practical matter, most small-business policies cap annual donations somewhere between 40 and 80 hours and require donors to retain a minimum balance of their own, so that generosity in a crisis does not leave someone with nothing for their own needs.

What happens to donated leave that is not used?

Under a qualifying major disaster plan, unused donated leave must be returned to the donors within a reasonable period, and returning it is good practice under a medical emergency plan too. Your policy should state this explicitly, along with the rule that donated leave has no cash value and will not be paid out. Both points prevent a predictable dispute: a donor who gave 24 hours for an emergency that resolved quickly will want to know what happened to the balance, and the answer should already be written down.

How do you set up a PTO donation program?

Put the plan in writing before any qualifying event occurs, since a program created in response to a specific person's situation invites favoritism claims and may not qualify for the tax treatment. Define the qualifying circumstances narrowly, set neutral eligibility criteria and apply them uniformly, require recipients to exhaust their own leave first, cap donations and require a minimum retained balance, keep medical details confidential, and coordinate with payroll on how donated hours are recorded and taxed. Then keep records of donations, allocations, and cash values.

Is a leave donation program subject to ERISA?

Leave sharing plans are generally not treated as ERISA welfare benefit plans, so there is normally no Form 5500 filing or summary plan description obligation attached to them. That is one of the few genuinely simple things about this topic. Other obligations still apply: donated leave that covers an FMLA-qualifying absence generally runs concurrently with FMLA leave rather than extending it, leave may be relevant as a reasonable accommodation under the ADA, and medical information gathered in the application process must be kept confidential.

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