I kinda like it, but we need to make it clear once and for all. You get 12 minor league slots, and in the offseason cutdown, 20 major league slots. Two of those 32 offseason slots are flexible. It's really not that difficult.
The only thing I think would be worth changing would be to only enforce minor league size at the cutdowns. Hell, if we did that, we could even decide to move to just the one offseason cutdown.