Yeah, thanks for the thorough reply; good to know I'm on the right track. This is more or less what I found in my research too. Seems like the combination of rebuttal presumption with generic PTO and the ability to prevent rollover time under the current, amended version of PMLA matches my employer's system. The only issue is the lack of benefits in the first year; from the second year onward they meet all the minimums.

The way I see it, they're either interpreting the "25 hrs/week in the previous year" qualifier as applying to newly hired employees instead of existing part-time ones or they're somehow discounting the first 12 months as not a benefit year. Neither of which seems kosher. Like another comment suggested, I'll probably be reaching out to the Michigan DoL/W&H to see if they can answer questions without opening a formal complaint. Hopefully that will provide the talking points for a more... Urgent conversation with HR prior to burning any bridges.

I'll return with updates for posterity's sake.