We are a small company based out of NY with location in RI and CA. We have 10 employees in NY, 14 in RI and 4 in CA. If I understand FMLA correctly we would not be required to offer it until our locations met the "50 employees within 75 mile radius" criteria. Is this accurate? I am revising the employee handbook and I want to replace the FMLA wording with just a straight request for leave so we are not bound to the FMLA guidelines.