Pennsylvania Labor and Employment Lawyer & Attorney : McNees Wallace & Nurick Law Firm : Human Resources, Workplace and Business Law : Harrisburg, Lancaster, Allentown, Lehigh

It’s no secret that the FLSA is anachronistic, but now it’s ruining the planet too. The 40-hour week divided into 5 consecutive workdays is a product of the FLSA, which was enacted in 1938. During the last 70 years, we have been consuming energy by commuting to work and operating facilities all the while pumping green house gasses into the atmosphere for an extra day a week.

Aaron Newton makes this brilliant observation in his post on The 4 Day Work Week:

The notion of our standard work week here in America has remained largely the same since 1938. That was the year the Fair Labor Standards Act was passed, standardizing the eight hour work day and the 40 hour work week. Each Monday, Tuesday, Wednesday, Thursday and Friday workers all over the country wake up, get dressed, eat breakfast and go to work. But the notion that the majority of the workforce should keep these hours is based on nothing more than an idea put forth but the Federal government almost 70 years ago. To be sure it was an improvement in the lives of many Americans who were at the time forced to work 10+ hours a day, sometimes 6 days of the week. So a 40 hour work week was seen as an upgrade in the lives of many of U.S. citizens. 8 is a nice round number; one third of each 24 hour day. In theory it leaves 8 hours for sleep and 8 hours for other activities like eating, bathing, raising children and enjoying life. But the notion that we should work for 5 of these days in a row before taking 2 for ourselves is, as best I can tell, rather arbitrary.

Mr. Newton then goes on to offer Sixteen Reason Why this is an Idea Whose Time has Come. This post is a “must read” for HR Professionals whose businesses may be evaluating the 4-day workweek option and looking for supporting reasons. The key downsides to the four-day week are losses in employee productivity and customer service. Comments challenging the 4-day workweek appear at the Oil Drum, which reprinted Newton’s post.

We have also outlined some legal limitations on the four-day concept in previous posts as it continues to garner a lot of media attention:

Four-Day Work Week Wave is Coming and Energy Expenses And Gas Prices Motivate Employers To Move To Four Day Workweek: What Are The Legal Issues?

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Most Pennsylvania employers and their counsel are familiar with the overtime compensation requirements and the exemptions from these requirements established by the federal Fair Labor Standards Act ("FLSA"). The exemptions, such as the bona fide executive, professional, and administrative employee exemptions, define when employers may lawfully treat certain employees as exempt from the FLSA's overtime compensation requirements. 

Fewer Pennsylvania employers are aware that the Pennsylvania Minimum Wage Act of 1968 ("PMWA"), a state law, also creates a statutory right to overtime compensation and, like the FLSA, includes exemptions to these requirements. At one time, the state overtime requirements and exemptions generally mirrored the FLSA. More recently, however, the federal and state rules on overtime compensation and exempt status have diverged in numerous areas. Compliance with the FLSA requirements no longer ensures compliance with the state PMWA.

For example, the federal Small Business Job Protection Act of 1996 codified prior U.S. Department of Labor interpretations and included an exemption for computer employees. To qualify for the computer professional exemption, the employee must be employed as a computer systems analyst, computer programmer, software engineer, or other similarly skilled worker in the computer field and must have a primary duty of

(a)             the application of systems analysis techniques and procedures, including consulting with users, to determine hardware, software, or system functional specifications;

(b)             the design, development, documentation, analysis, creation, testing, or modification of computer systems or programs, including prototypes, based on and related to user or system design specifications;

(c)             the design, documentation, testing, creation, or modification of computer programs related to machine operating systems; or

(d)            a combination of the aforementioned duties, the performance of which requires the same level of skills.

The PMWA and its regulations contain no companion to the federal computer professional exemption. Thus, an otherwise exempt computer professional still may be entitled to overtime compensation under the state law. If an employer has a computer professional that meets the federal exemption, the employer should examine whether the employee also qualifies for another white-collar exemption, such as the administrative or professional exemption, that also is recognized by state law. However, Pennsylvania’s white-collar exemptions require that the exempt employee be paid on a Salary Basis; while the federal computer employee exemption allows for payment on an hourly basis if the rate exceeds $27.63 per hour. If the employee in question would not qualify for any other exemption, the employer may be liable for unpaid overtime compensation under the PMWA.

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As the effective date of Pennsylvania’s Clean Indoor Air Act approaches, businesses may wish to seize the opportunity to create a comprehensive tobacco-free workplace program including wellness initiatives. The no smoking law applies to all indoor work areas and permits an employer to completely prohibit smoking on its property. However, legal and employee relations considerations suggest an integrated approach to workplace smoking.

Smoking-related business cost are well documented. The Center for Disease Control has the following statistics on smoking:

• For 1997–2001, cigarette smoking was estimated to be responsible for $167 billion in annual health-related economic losses in the United States ($75 billion in direct medical costs, and $92 billion in lost productivity), or about $3,561 per adult smoker.
• An estimated, 20.8% of all adults (45.3 million people) smoke cigarettes in the United States.
• Among current U.S. adult smokers, 70% report that they want to quit completely. In 2006, an estimated 19.2 million (44.2%) adult smokers had stopped smoking for at least 1 day during the preceding 12 months because they were trying to quit.

Design of an effective wellness program to address smoking can take many forms and requires collaboration between insurance brokers, benefit providers and legal advisors in light of limitations placed on certain aspects of their design including HIPAA's Nondiscrimination Requirements.    HIPAA regulations affect the design of wellness programs that take into account "health factors" when providing incentives under the program. Programs such as the following that do not take into account a participant's health factors when a reward is given or withheld for participation by an employee or beneficiary:

• Health Assessments
• Diagnostic testing that does not take into account test results
• Preventive care encouragement incentives such as waivers of co-pays or deductibles
• Smoking cessation programs so long as the benefit is received regardless of whether the employee quits smoking
• Health education seminars
• Gym membership reimbursement

Wellness programs that give rewards for healthy conduct or that penalize unhealthy activities (like smoking) must meet all of the five following standards:

• Limited Reward:       All rewards offered under the program must not exceed 20% of the cost of coverage (total amount of employee and employer contribution). The reward can be in the form of a discount or rebate of premium or contribution; waiver of deductible, copayment or coinsurance; or the value of a benefit provided under the plan.
• Reasonably Designed to Promote Health or Prevent Disease:    The plan must have a reasonable chance of improving health or preventing disease in a way that is not overly burdensome.
• No More that Annual Qualification for Award:    Individuals eligible to participate must be given the opportunity to qualify at least once a year.
• Uniform Reward Availability for "Similarly Situated" Individuals: The reward must be available to all similarly situated individuals and there must be a reasonable alternative for receiving the reward for any individual for whom it is unreasonably difficult due to a medical condition or for whom it is medically inadvisable to attempt to obtain the applicable standard. Physician verification may be required.
• Plan Material must Describe all Terms:     The plan must describe all terms of the program and the availability of a reasonable alternative. The following language may be used to satisfy the alternative:

"If it is unreasonably difficult due to a medical condition for you to achieve the standards for the reward under this program, or if it is medically inadvisable for you to attempt to achieve the standards for the reward under this program, call us at            and we will work with you to develop another way to qualify for the reward."

Business initiatives to regulate off duty conduct have some legal risk. However, courts have so far rejected smoker’s claims of disability based upon nicotine addiction.

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Most hiring decisions are predicated in some part on subjective criteria. Let’s take for example, “Attitude and communication skills” which are on the top the hiring criteria for Phil Gerbyshak at Slacker Manager’s based on his post 5 Must Have Skills. Undoubtedly these traits were assessed by one or more members of the Phil’s hiring team based on how the candidates presented themselves at the interview. This hiring approach is universally practiced by companies across the country and loathed by government enforcement agencies.

The EEOC and OFCCP have initiatives targeting an employer’s selection process. The EEOC announced its focus on employment testing and screening resulting in a fact sheet Employment Tests and Selection Procedures. Likewise, OFCCP has a program targeting Systemic Discrimination, which examines criteria used in the hiring process. Subjective criteria are scrutinized because of the fear that they will be manipulated for a discriminatory purpose.

Courts examining subjective hiring criteria have not outright prohibited their use, but have cautioned against their advancement because they are “easily fabricated”. Recently in Wingate v. Gage County School District, the Eighth Circuit Court of Appeals ruled that an employer’s use of subjective criteria did not create an inference of age discrimination when objective criteria were also utilized to make the employment decision.

The legal analyses of subjective hiring criteria revolve around theories of disparate treatment or disparate impact. The measure of compliance has its origin in the Uniform Guidelines on Employee Selection Procedures, which define interview questions as means of selection criteria and set forth the parameters for compliance.

The legal compliance for disparate treatment focuses on the following:

• Whether the subjective criteria are job related
• How they are measured
• Whether the criteria are uniformly applied

According to Section 30 the OFCCP Compliance Manual, employers that utilize subjective hiring criteria will be evaluated for disparate treatment based, in part, upon their use of “safeguards” in the hiring process:

Safeguards consist of efforts made by the contractor to limit the possibility of differential application of the selection criteria/processes. In other words, treating members of a minority group or women differently than others in the application/evaluation of the criteria/processes. An example of a uniformly applied subjective process with safeguards could be an interview where all persons who pass the required test are interviewed regardless of minority or sex status; all interviewers are professionally trained in interviewing; all persons interviewed are asked the same questions; responses are documented; and answers are all evaluated in the same manner.

The legal compliance hurdles for disparate impact have a slightly different focus. The EEOC describes this process as follows:

• If the selection procedure has a disparate impact based on race, color, religion, sex, or national origin, can the employer show that the selection procedure is job-related and consistent with business necessity? An employer can meet this standard by showing that it is necessary to the safe and efficient performance of the job. The challenged policy or practice should therefore be associated with the skills needed to perform the job successfully. In contrast to a general measurement of applicants’ or employees’ skills, the challenged policy or practice must evaluate an individual’s skills as related to the particular job in question.
• f the employer shows that the selection procedure is job-related and consistent with business necessity, can the person challenging the selection procedure demonstrate that there is a less discriminatory alternative available? For example, is another test available that would be equally effective in predicting job performance but would not disproportionately exclude the protected group?

Employers who want to assess attitude and communication skills should consider the following additions to their hiring procedures:

• Make attitude and communication skills an express criteria in job descriptions and summaries of minimum job requirements
• Describe its job relatedness and business justification
• Assess whether the criteria is creating an adverse impact
• Implement “safeguards” in the hiring process describe in OFCCP Guidance

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Traditional leave programs segregate time off into categories like vacation, sick time and personal time requiring HR professionals to track both the time off and the reason it is being taken. Sick time abuses are addressed by tightly monitoring the reasons for sickness-related absences and disciplining employees for excessive absenteeism. Many employers have decided to get away from policing the circumstances of an employee's absence by just creating a bank of paid time off that can be used for any reason. Once PTO is exhausted, time off is unpaid and subject to the attendance discipline policy. This certainly sounds like a great idea, but here are some practical and legal considerations in converting from a traditional sick pay program to a PTO plan:

Timing the Change Over to PTO:

Changes in leave policies should be coordinated with either the end of the leave year period or some other workplace change like moving to a four-day workweek. The obvious choice is converting to PTO bank at the end of the year, since most employers administer their time off programs on a calendar/fiscal year. For employers using anniversary date leave years, it is too difficult administratively to run dual programs, so they should pick a date and change over for everyone.

Effect on Four-Day Workweeks

Employers need to remember that a change in workweek from five eight days to four day ten hour days also affects time off policies. A handbook or CBA may describe time off (PTO, vacation, holidays, personal and sick time) in terms of “days”. However,

a workday, which used to be an 8-hour day, is now a 10-hour day. The 8-hour day was 20% or the workweek, but the 10-hour-workday is 25% of the workweek. If a day expands to 10 hours, employees are getting more time off and, as a result, the company is losing 5% productivity. If a day stays at 8 hours then employees can’t cover the whole day off. Converting the whole PTO bank to hours can address this situation. (see Energy Expenses And Gas Prices Motivate Employers To Move To Four Day Workweek: What Are The Legal Issues?)

Addressing the Perception of a "Take Away":

Converting to PTO means combining vacation, sick days, personal days, and other time off into one bank. Employers almost never credit the entire amount of sick time to PTO banks. Therefore, employers need to address the perception that employees are losing sick time. I have found that referring to the statistic mentioned in the prior posting (average 8 sick days, use 5) makes some sense. Based on this ratio, I convert 60% of sick days to PTO and couple it with an explanation about trade offs.

Dealing with Accumulated Sick Time:

Some employers allow the accumulation of unused sick time as an incentive not to use it. (This practice drives accountants crazy). The accumulated time may be used in some of the following ways: to satisfy a waiting period for STD/LTD; as a pay out upon separation, typically at a reduced percentage (50%); or it is simply forfeited. Employers may seize the opportunity to clean up their balance sheet and pay out a portion of the accumulated time or convert it to PTO. This approach softens the blow of the perceived take away mentioned above. However, an employer's flexibility in dealing with accumulated sick time depends on its written policy and practice with regard to payouts. Be careful not to create a claim for unpaid fringe benefits under the Pennsylvania Wage Payment and Collection Law.

Exhausting PTO:

Employees who use all of their PTO are unpaid for additional absences and are subject to discipline under the attendance policy. Some traps for the unwary include: the prohibition on salary docking for exempt employees; additional unpaid leave as an accommodation under the ADA, and discrimination claims under the ADA.

Administering FMLA:

FMLA administration becomes more challenging in a PTO program since the employer is not necessarily aware of the reason for an absence. A serious health condition under the FMLA triggers an obligation to notify an employee of his or her FMLA rights and starts the counting of the time against the 12 weeks of leave. Employers must also address the concurrent use of PTO and FMLA leave in their policies.

Integrating STD and other Leave Programs:

Some sick leave policies were designed to integrate with the waiting period for STD benefits. A move to PTO creates a disconnect. The disconnect can be mitigated by allowing an employee with accumulated sick time to use it to satisfy the waiting period if he or she becomes eligible for STD benefits. Otherwise, PTO or unpaid time is used during the waiting period. Employers might address hardships by creating a PTO donation program where employees may donate unused PTO to a fellow worker who needs additional time.

Contesting Unemployment Claims:

 An employer's proof of willful misconduct to deny unemployment benefits will generally look at the incident that gave rise to the discharge. If the reason is a violation of employer's attendance policy, the employee can show that the violation was not his or her fault. An employee who is fired for excessive absences after "squandering" PTO, may still be eligible for unemployment if the absence that gave rise to termination was for a legitimate illness.

Drafting a Policy:

A written policy on PTO is strongly suggested and it should address at least the following areas:

• Accrual Basis or Award Basis
• Notice of Absence
• Unused PTO carryover or forfeiture
• Concurrent use of FMLA and PTO
• Consequences of Exhausting PTO
• Discipline/Discharge

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Nondiscrimination is a cornerstone of many CSR programs and a fundamental tenet of employment laws. However, for some, social responsibility and religion are inextricably intertwined creating a contradiction for CSR proponents. David W. Miller, Ph.D., Head of the Yale Center for Faith & Culture and professor of Business Ethics at Yale Divinity School and Yale School of Management, makes the following observation:

Many in the corporate world would rather not bring religion into the boardroom. Fair enough, especially if the purpose is to misuse religion for selfish or inappropriate purposes. But if advocates of CSR are interested in finding new allies in the quest to encourage businesses to become more ethical and attentive to their responsibilities to a wide range of stakeholders, they should think anew about the role of faith in the workplace.

CSR programs may benefit from the “faith-at-work” movement. Religion’s growing influence in business and government is reflected in faith-based and community initiatives like Bush’s Executive Order 13342 or Obama’s plans to “to build a ‘real’ partnership between faith-based organizations and the White House” if he becomes president.   Companies face challenges as the lines blur between CSR programs and religious practice at work.

For some “faith-friendly companies” , there isn't a distinction between social responsiblity and religious practice.   For example, in Lancaster County, Pennsylvania, there are businesses that are not on the cutting edge of technology, that aren’t familiar with the latest HR buzz words like outsourcing, SOX, etc., and that will never access the internet to read this or any other blog. Yet companies adopting this “business model” are substantial contributors to the local economy, take “going green” to a completely new level, and make social responsibility a way of life. 

Amish businesses have no corporate policy on social responsibility, but these businesses make the same sorts of contributions to community and environment that Starbucks reports in its mission statement on corporate responsibility. The Amish community lives off-the-grid and takes care of one another. Typically using windmills to pump water and a horse and buggy for their daily commute, they have no need to purchase Renewable Energy Credits to meet environmental goals. They have no health insurance; do not participate in government programs like social security and welfare. If someone needs help, the community provides it. Businesses may close so employees may engage in social service like a barn raising for family in the community.

Extreme for modern businesses…yes. However, there may be take-aways for any business evaluating a CSR program:

• Initiatives may need to be “systemic”
• Keep them simple
• Emphasize community
• Reject Hochmut (pride, arrogance, haughtiness) and Value Demut (humility)

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On May 21, 2008, President Bush signed into law the Genetic Information Nondiscrimination Act of 2008 ("GINA"). GINA amends three employment-related laws including: (1) Title VII of the Civil Rights Act (Title VII); (2) the Employee Retirement Insurance Security Act (ERISA); and (3) the Fair Labor Standards Act (FLSA). While most of the provisions will become effective in 2009, it is important for employers to be familiar with GINA's basic concepts and provisions to better prepare for the Act's implementation.

Why GINA?

At the time of GINA's passage, thirty-five states had laws relating to discrimination in employment based on genetic information. Pennsylvania does not. As the state laws vary, one of Congress's goals in enacting GINA is to provide for an umbrella federal provision applicable to all persons in the U.S. GINA does not preempt state laws that provide more protection for genetic information. Notably, this law is responsive to many efforts in the medical community to personalize medical care, such that diagnosis and treatment plans would be tailor made for each patient based on his or her genetic make up.

What Is "Genetic Information" Under GINA?

Under GINA, “genetic information” is broadly defined to include information about: (1) an individual's genetic tests, (2) the genetic tests of the individual's family members, and (3) the manifestation of a disease or disorder in a family member. “Family member” is defined to include an individual’s spouse or dependent child by birth or adoption, and certain other relatives of such individual, individual’s spouse or dependent child. “Genetic information” does not include information about the sex or age of any individual.

How Does GINA Amend Title VII?

The GINA amendments to Title VII are effective November 21, 2009. Specifically, GINA:

1.            Makes it an unfair employment practice for employers, employment agencies and others to discriminate against individuals based on “genetic information” in hiring, firing and other terms and conditions of employment; and

2.            Makes it unlawful to limit, segregate, or classify employees in any way that would deprive or tend to deprive the employee of employment opportunities or otherwise adversely affect the status of the employee because of genetic information.

            Notably, GINA provides that the Equal Employment Opportunity Commission has one year to issue implementing regulations and that an individual’s rights and remedies under GINA are analogous to those provided under Title VII; except no disparate impact claims are available under GINA.

Moreover, GINA generally prohibits employers from requesting, requiring or purchasing genetic information except under specific circumstances, such as for genetic services offered by the employer and for purposes of complying with the Family and Medical Leave Act (FMLA). Like the Americans with Disabilities Act, GINA provides that to the extent an employer has genetic information, the employer must keep the information confidential. GINA is dissimilar from the ADA, however, because GINA prohibits discrimination based on the possibility of contracting a disease per family history or testing, whereas the ADA prohibits discrimination based on current/past/perceived disability.

How Does GINA Amend ERISA?

GINA's amendments to ERISA are effective May 21, 2009. Under GINA, an ERISA-covered group health plan cannot:

• Request, require or purchase genetic information for underwriting purposes or in advance of an individual's enrollment;
• Adjust premiums or contribution amounts of the group based on genetic information; or
• Request or require an individual or family member to undergo a genetic test except in limited situations specifically allowed buy GINA.

Under GINA's amendments to ERISA, a group health plan's noncompliance may present significant liability for both the plan and its sponsor. Participants or beneficiaries will be able to sue noncompliant group health plans for damages and equitable relief. If the participant or beneficiary can show an alleged violation would result in irreparable harm to the individual's health, the participant or beneficiary may not have to exhaust the typical administrative remedies before suing in court.

            How Does GINA Amend HIPAA?

How Does GINA Amend The FLSA?

In addition to creating an entirely new protected trait, GINA also contained amendments to the child labor provisions of the FLSA. The amendments to the FLSA are effective as of May 21, 2008. Specifically, the amendments (1) increase the penalty for child labor violations by $1,000 per violation and (2) raise potential employer liability to $50,000 where a violation causes the death or serious injury of a minor.  This amount can be doubled for repeat or willful violations.

How To Prepare For GINA?

Although not currently effective, it is recommended that employers take a proactive position on preparing their enterprises for GINA. Some things to consider include:

·        Revising EEO and Anti-Harassment Policies to include "genetic information."

·        Monitoring your group healthcare plan to assure that it will be in compliance, afterall GINA provides for plan sponsor liability.

·        Creating a policy to flag genetic information provided for FMLA leave v. genetic information provided for other forms of leave. As of now, it appears that only FMLA leave situations fit within the leave exception to GINA.

·        Create a policy wherein genetic information is stored in the same manner as all medical documents submitted for ADA purposes (i.e. confidentially).

·        Stay Tuned to What the Agencies Issue During The Next Year!

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Most state workers in Utah are shifting to 4-day week with announcement of the 'Working 4 Utah' initiative, extending state government service hours from 7 a.m. to 6 p.m., Monday through Thursday beginning the first week of August. State administrative offices will be closed on Fridays but essential public services will remain open that already run on extended hours and during the weekends. Utah Governor Jon Huntsman stated that

As we go forward with this initiative, we will conserve energy, save money, improve our air quality, and enhance customer service…. We live in a dynamic, ever-changing environment, and it's crucial that we take a serious look at how we can adapt and maintain our state's unparalleled quality of life.

 Working 4 Utah cost saving analysis examined the impact of moving from five 8-hour days to four 10-hour days in terms of Reduction in Energy use for Government Buildings; Fuel Savings from less Commuting; Employee Financial Savings; and Emission Reductions.

Workforce Management notes that the Gas Price Could Revolutionize U.S. Workplace.  We have posted on Energy Expenses And Gas Prices Motivate Employers To Move To Four Day Workweek: What Are The Legal Issues? and FLSA causes Global Warming:  Sixteen other Reasons to Consider a 4-day Work Week.   Several Pennsylvania Counties and municipalities are mulling four day workweeks, including Berks County, Centre County, York County, and BEA School District.  But, Warren County has reportedly rejected the idea.  Give us your thoughts on the subject:

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“Small Employer” minimum wage increases to $7.15 per hour effective July 1, 2008 

All employers in Pennsylvania must pay the state’s minimum wage of $7.15 per hour based on the expiration of the Small Employer exemption. Previously, an employer who had an employee complement composed of the equivalent of 10 or less full-time employees had a lower minimum wage rate of $6.65 per hour until July 1, 2008.

Pennsylvania's Training Wage Increases to $6.55 per hour effective July 24, 2008

Pennsylvania’s training wages is scheduled to increase from $5.85 to $6.55 effective July 24, 2008. The training wage is no longer allowed after July 23, 2009. A 60-day training wage may be paid to employees under 20 years old effective January 1, 2007. This wage matches the current federal minimum wage. Eligible employees may be paid the training wage up to the day before the employee’s 20th birthday. On and after the employee's 20th birthday, pay must be raised to the regular Pennsylvania minimum wage even if the 60-day period has not expired.

The 60-day period starts on the first day of work. The 60-day period is counted as consecutive days on the calendar, not as days worked or business days. A break in employment (e.g. vacation, school year, etc.) does not affect the calculation of the 60-day period of eligibility and does not allow the employer to “restart” the 60-day period.

A youth under 20 may be paid the training wage for up to 60 consecutive calendar days after initial employment with any employer, not just the first employer. The fact that an eligible youth may be employed at the same time by more than one employer (unrelated to each other) does not affect either employer’s right to pay the training wage.   An employee may be “initially employed” only once by any one employer even if there are breaks in employment.

Employers must notify these employees at the time of hire of this wage and their right to receive the regular Pennsylvania minimum wage after 60 calendar days. Current employees may not be displaced, have their hours reduced or have their wages or employment benefits reduced to allow hiring of persons eligible for the training wage. Employers do not have to meet any training requirements to pay an eligible youth this training wage.

Pennsylvania’s Mandatory Minimum Wage Poster

FAQ on Pennsylvania Minimum Wage

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