Absence PTO Plan based on Union code: without accrual shall make employee to consume absence

Summary:

Is it possible to allow employee to consume absences without accrual if the employee LOS is less than 1 year and deduct the same after their first accrual on completion of their service of 1 year.???

If yes, kindly suggest.

Content (required):

Requirement: Front loaded annual (01/01 - MM/DD) accrual plan.

1) Accruals:

• 0 hours for those with LOS less than 1 year.
• 144 hours for those with LOS greater than or equal to 1 year and less than 5 years.
• 184 hours for those with LOS greater than 5 years.

2) Ceiling:

• 256 when LOS greater than or equal to 1 year and less than 5 years.
• 322 when LOS greater than 5 years.