Can we document only FMLA absences of 10 days or more?

Q. Our organization has not been tracking FMLA leaves. In the past, FMLA is only discussed after an employee exhausts all sick, vacation and personal leave time. Going forward, we would like to verify and document absences of more than 10 days (after determining that the absence is due to a FMLA eligible event) even when the employee does not request it. When we become aware of an extended absence, we will notify the employee that they are using FMLA leave concurrently with their paid time as of the date of the notification. Is this procedure compliant with FMLA regulations and a best practice? – Kathryn, New York