10-31-2019; Runaway/Shocking Retaliatory Discharge Verdict; Shawn Biery on Trying to Make Sense of When You Need to Actually Provide Funding for Future Medical Care at Settlement; New IL WC Arbs

Synopsis: Runaway and Shocking Retaliatory Discharge Verdict—What Do You Learn From It?

Editor’s comment: Dean Foods was ordered to pay more than $3 million in punitive damages as a result of a retaliatory discharge lawsuit filed by former employee/Plaintiff Jankowski, who alleged retaliation and discrimination against the milk processing facility.

According to a news release from the Wheaton-based Coffey Law Office, which represents Jankowski, a jury found Defendant Dean Foods retaliated against Jankowski by refusing to recall him back to work from August 2014 up until his termination after Jankowski had suffered an injury on the job and then refused work that exceeded his medical restrictions and filed a workers’ compensation claims.

A jury also found Oct. 16 that Dean Foods discriminated against Jankowski in violation of the Americans with Disabilities Act by failing to engage in an “interactive process” required by the ADA and failing to accommodate his disability by refusing to return him to work in one of the open positions he claimed he was capable of performing.

“The jury heard extensive evidence that Dean Foods’ management employees created inaccurate, staged photos and misleading documents to cover up their violations of the ADA and Illinois law,” according to the release.

Jankowski alleged his supervisors forced him to perform a job that required him to haul around 480 pounds up an incline despite having a doctor’s note not to do so. He claimed these tasks caused serious reinjury. According to court records, when he hauled the heavy weight up the incline Jankowski suffered another injury resulting in a disability after he began working with Dean Foods. He subsequently underwent surgery about August 2013 and tried to return to work with restrictions on or about August 2014, but Dean Foods management allegedly never offered him a position.

Dean Foods argued that it had no obligation to accommodate Jankowski’s permanent restrictions by making a light-duty position available to him on a permanent or indefinite basis when he returned in 2014.

The judgment was entered against Dean Foods – and its wholly owned subsidiary, Dean Dairy Holdings LLC, in the amount of $3,316,443.

Plaintiff firm’s release crowed “The jury also sent a powerful message to Dean Foods, and employers generally with a $3 million punitive damages award.” “Such awards are intended to punish and deter when evidence of willful and wanton or reckless misconduct is presented.”

What Can We Learn From This Stunning Ruling?

Well, for one thing, risk managers have to note the description of the civil claim above appears to be a workers’ comp matter. If Claimant wasn’t happy about coming back to work at too hard a job, that issue would be best resolved at the IWCC. It would appear Claimant may have resolved that issue to something less than his full satisfaction to then go after the employer in U.S. District Court.

Second, if you aren’t aware of the “interactive process” mentioned above when you are considering bringing any worker back to work, take a look at this quote from the EEOC’s website:

Interactive Process:  The interactive process refers to an information-gathering  approach used by an employer with the employee to evaluate a request for accommodation.  It is intended to be a flexible approach that centers on the communication between an employer and the individual requesting reasonable accommodation, but may (and often does) involve obtaining relevant information from a supervisor and an individual's health care provider.  This process begins upon receipt of an oral or written request for reasonable accommodation.  The person who will decide whether to grant or deny a reasonable accommodation (at EEOC it is the Disability Program Manager (DPM)) engages in a discussion with the requestor and other relevant individuals (e.g., a supervisor, a requestor's health care provider) to collect whatever information is necessary to make an informed decision about whether the requestor is covered as an individual with a disability and, if so, what reasonable accommodation(s) will effectively eliminate the barrier identified by the requestor and permit an equal opportunity to apply for a job, to perform a job or to gain access to the workplace, or to enjoy access to the benefits and privileges of employment.

Whenever you have a worker who is claiming they need any accommodation or all the treating and evaluating doctors are providing anything short of a full duty release, start to think of the interactive process as the best path to return to work. 

Even if you are terminating a worker for “no call, no show,” if there is any hint of a work restriction in the medical chart, the defense team at KCB&A and I recommend you send a letter and/or call the worker to seek their attendance at an interactive process meeting to discuss what is happening and what can be done about it. If they refuse to show up, you are on record with having tried everything you can to have the “horse drink water” without success.

If you let a worker with restrictions drift away without some documentation of efforts to be “interactive,” you might later face the sort of gigantic liability of the employer that is outlined above.

General Release/Resignations Should Forestall Such Litigation

If you are settling a claim for a worker who

• Has any hint of work restrictions in the medical chart and

• Is leaving your employ at the time of WC settlement,

I strongly recommend you consider getting a coincidental release/resignation signed and paid for at the time of the WC settlement. This is an intricate matter and I am able to help you in detail with my R/R form and suggestions on best possible outcomes.

I appreciate your thoughts and comments. Please post them on our award-winning blog.

Synopsis: Trying to Make Sense of When You Need to Actually Provide Funding for Future Medical Care at Settlement by Shawn R. Biery, J.D.

Editor’s comment: To some extent, it seems that there has become a steady drumbeat for seeking a formal MSA analysis in almost every file and we have several clients in the last 90 days make the same point—they feel like they are being “sold” on something that really is just lining someone else’s pocket and delaying their settlement.

While the need to protect Medicare’s interests in any settlement is paramount, it is almost as if the simplicity of answering the question is too simple and it causes fearmongering leading to resources being wasted rather than just a simple verification.

In most cases where there is a release from care, it really can be as simple as “there is no future medical concern” since care has ended and the issue has been resolved.  Future medical funding simply isn’t needed because of the end of care—so when you look at your claims ending via settlement, the one overriding factor always is whether there is a specific anticipated need for future medical.  If there is no future medical component, there is no other factor to consider other than defining how you reached that conclusion.  At that point, the best practice should be to memorialize your effort to consider Medicare’s interests and identify the reason there is no future medical—it can be as simple as the last treating note which indicates MMI with no future visit.

In other cases, maybe it isn’t as simple—maybe the MD suggests MMI will be reached in one year,  but no future visit is noted. That would be something to either clarify with the MD or provide some value for the single future visit. Or maybe there is a pin in the ring finger which could possibly need to come out one day—in that case, some research to verify the cost of that procedure and inclusion of a value in the contract may be appropriate.

Or sometimes, there are significant recommendations—knee replacements, future surgeries, the dreaded spinal cord stimulator. In those cases, there is specifically a future concern and the interests of Medicare need to have been taken into consideration with some amount for future medical. At that point, it makes sense to seek a valuation to decide if funding future medical, or leaving medical rights open to IWCC jurisdiction is a viable avenue for settlement completion. We generally suggest you reserve the future right to set a value aside for medical even if you are leaving medical open.

Medicare has some guidance on how they handle future medical but they don’t really have a specific directive on “what do we do if there is no need for future medical”—because they don’t concern themselves once there is no future medical need.

CMS has a pretty good page which tells you about the process without any marketing angle. That page is here--https://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Workers-Compensation-Medicare-Set-Aside-Arrangements/WCMSA-Overview.html  

They also have a memo about how to determine what is reasonable (they have several memos linked to the main page)—but again, this assumes there will be future medical.

https://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Workers-Compensation-Medicare-Set-Aside-Arrangements/Downloads/determiningwcmsareasonable.pdf

The review thresholds are just thresholds for when CMS will review.  Not a guide to whether you actual need an MSA—again, whether you need future medical is dependent on a specific anticipated need for future medical. 

If you think there is a need, then you can see if Medicare would review your proposal. MSA SUBMISSION IS NOT REQUIRED BY STATUTE and is voluntary, but usually recommended if appropriate.

When you If you choose to submit a WCMSA for review, CMS requires that you comply with its established policies and procedures.  CMS will only review WCMSA proposals that meet the following criteria:

•                    The claimant is a Medicare beneficiary and the total settlement amount is greater than $25,000.00; or

•                    The claimant has a reasonable expectation of Medicare enrollment within 30 months of the settlement date and the anticipated total settlement amount for future medical expenses and disability/lost wages over the life or duration of the settlement agreement is expected to be greater than $250,000.00

For more information on Review Thresholds, please see Section 8.1 (Review Thresholds) of the WCMSA Reference Guide available in the Downloads section found at the bottom of this page— https://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Workers-Compensation-Medicare-Set-Aside-Arrangements/WCMSA-Overview.html

Please also remember that Conditional payments are different than an MSA. In a nutshell, those are past payments already made by Medicare which should have been made by the primary payer (in WC, that would be the self-insured company TPA or the insurer) if the claimant is a Medicare beneficiary.  If you have someone who is a Medicare beneficiary, there should always be a conditional payment check—and we always suggest efforts to resolve any conditional payment issue directly with CMS, since giving the money to the claimant doesn’t protect anyone if the claimant does not pay back the conditional payment.  Conditional payments can also be disputed and we have had multiple occasions of success in arguing that payments listed as conditional payments are not related.

The biggest take away for anyone with questions is,  if there is a concern over the medical payment issues related to Medicaid or Medicare, I always suggest you review the file to either document a specific release from care or consider covering potential future costs or leaving medical open wherein the IWCC retains jurisdiction over any determination of medical charges or repayment requests which may arise in the future from any other governmental entity.

Each case should be examined separately, and we are always here to take a look and give you our thoughts. This article was written by Shawn R. Biery and you can reach Shawn at sbiery@keefe-law.com for any questions.

Synopsis: New IL WC Arbitrator Appointments

Editor’s comment: On Friday October 25, 2019, Governor Pritzker appointed Linda Jean Cantrell and Christopher A. Harris as Arbitrators of the Illinois Workers Compensation Commission. 

The following biographies come from the Governor's press release:

Linda Cantrell will serve as an Arbitrator on the Illinois Workers’ Compensation Commission. Cantrell worked as an attorney for Winters, Brewster, Crosby and Schaffer. She formerly worked as a legal secretary at Mertz Law Firm. Cantrell is a current member of the Missouri Bar Association, Williamson County Bar Association, Illinois Bar Foundation, Illinois Trial Lawyers Association and the Association of Trial Lawyers of America. She earned her Bachelor of Science from St. Louis University and Juris Doctor from the Southern Illinois School of Law.

Christopher Harris will serve as an Arbitrator on the Illinois Workers’ Compensation Commission.  Harris worked as managing attorney and owner of Shield Law Firm LLC and volunteers at the Cook County Arbitration Center. Previously, he served as general counsel at International Services, associate attorney at Archer Law Group and an attorney at his own firm Johnson and Harris. He is a member of the Illinois and Chicago Bar Associations as well as the Lakeview Chamber of Commerce. Harris earned his Bachelor of Arts in Political Science from the University of Illinois and his Juris Doctor from the University of Illinois College of Law.

10-17-2019; Trying to Make Sense of Where To Draw the Line—Understanding The “Traveling Employee” Concept in Workers’ Comp; Governor Pritzker Appoints Four to IL WC Advisory Board and more

Synopsis: Trying to Make Sense of Where To Draw the Line—Understanding The “Traveling Employee” Concept in Workers’ Comp.

Editor’s comment: To some extent, I feel the Petitioner’s Bar in Illinois and other states is always looking for a “gotcha” concept that renders any injury that can be in any way related to something to do with work as fully compensable. The closest concept to being a “gotcha” in work comp is the nebulous and ever-changing concept of the “traveling employee.” The concept is grounded in a sort of common sense—if your employer sends you to a strange and foreign place, let’s say Borneo, and you get injured from a risk in Borneo that is due to the strangeness and foreign-ness of that distant shore, you should be covered for it, even though that risk is from a common source, like eating breakfast. So if the food in Borneo makes you deathly ill, eating breakfast could be a work-related risk. Almost all risks to a “traveling employee” are work-related unless their actions are so far afield and unreasonable, they somehow lose that coverage to the Commission and Courts. Please always remember there is no definition or limitation of “traveling employee” in the IL WC Act. Whatever you do with the concept, you are making it up.

That said, when a worker “travels” or goes to places they are used to and visit regularly, that shouldn’t provide global “gotcha” coverage of all risks. In short, the “traveling employee” doctrine has been a political football in workers’ compensation law since WC legislation was first enacted in the U.S. in the early 1900s. Whether created by statute in some states or developed by common law decisions in IL, this odd doctrine sporadically increases the scope of an employer’s WC lia­bility and is an exception to the long-standing rule that injuries sustained while going to and coming from work are not compensable. The ratio­nale for the “coming and going” rule is an employee’s trip to and from work is the result of the employee’s personal decision about where to live, which is not a matter of strong con­cern for the employer.

While it appears the intent of the “traveling employee” doctrine is to cover employees who due to the nature of their employment traveled and stayed away from home overnight, the doctrine has expanded in some states to cover circumstances when the work takes an employee away from the primary work premises for varied reasons and for shorter durations. The doctrine is of par­ticular importance today because many jobs involve employee travel, not only as a part of the job, as with a traveling sales­man or over-the-road truck driver, but also between various company facilities and between job sites. The latter may involve employees hired out of a union hall for a specific job at a far-away location or home health-care workers who leave home, travel from patient to patient, and never truly have a “base of employment.” As I outline below, magically making all such workers into “traveling employees” can be very, very expensive.

Insurance carriers, TPA’s and employers have difficulty with the “trav­eling employee” doctrine because it not only expands the situations that will be con­sidered “in the course of” employment, but also may be ruled to dramatically lower accident compensability. While terminology varies from state to state, the “nontravel­ing employee” generally has to prove an injury “arose out of” the employment. This usually means an employee must prove that he or she faced a risk at the time of an accident greater than the risks faced by the general public and are “unique” to the workplace. This com­pensability standard, however, is almost missing for a worker who is termed a “traveling employee.” Most states require a traveling employee only to prove the risk leading to an accident was “reasonably foreseeable.” Other states adopt a continuous employ­ment doctrine for a traveling employee, which finds virtually any activity an employee undertakes while traveling to be compensable unless there is a clear deviation from expected work activity. In fact, this altered compensability standard in most states can equate to “gotcha” strict lia­bility unless a claimant is deemed to be on a purely personal deviation and away from any vestige of work. For the trav­eling employee, traditional compensabil­ity analysis is ended, and most every injury or disease that occurs while the travel contin­ues is deemed compensable.

While this reduced burden of compen­sability worked well for employees facing unusual risks while traveling to strange and foreign places, particularly those traveling away from their homes and offices on overnight trips, liberal expansion of the traveling employee doctrine to workers who have only incidental travel as part of their duties is challenging for employers, insurance carriers and TPA’s. As work has become more mobile, many jobs include at least some inci­dental travel throughout the course of a workday. As the traveling employee doc­trine is expanded to include more of these work settings, workers’ compensation might end up covering broad portions of the work­ing population even when there is little, if any, connection between an injury and the employment.

One example I always draw that I don’t feel creates a “traveling employee” is our great Illinois WC Arbitrators. Many of them are assigned to three different hearing sites, by rule. They go to the three hearing sites with great regularity and eat at the same restaurants and park in the same parking spaces. They do not face risks that anyone would feel unusual. If an Arbitrator were traveling from their home to one of their hearing sites and got into a one-car accident that would typically not be compensable other than for a “traveling employee,” I would be hard-pressed to feel an Arbitrator would be covered, as they aren’t traveling overnight or to a truly “foreign” place.

Three Illinois decisions provide insight into what constitutes unreasonable actions and resulted in denial for workers who argued they were “traveling employees.” In Howell Tractor & Equip. Co. v. Illinois Industrial Comm’n, issued in 1980, the Appellate Court held an employee’s conduct in walking or staggering back to a motel alone in an unfa­miliar town after drinking at a tavern con­stituted unreasonable personal action. In Humphrey v. Illinois Industrial Comm’n, issued in 1979, the Appellate Court upheld denial of compensation when an employee was injured while returning to his motel after partying on a work day. Finally, in U. S. Industries v. Illinois Industrial Comm’n., issued in 1968, an employee injured on a midnight pleasure drive in unfamiliar, mountainous terrain was held to be engaged in unreason­able activity and benefits were denied.

Dramatic Expansion of the “Traveling Employee” Doctrine is a Business Buster

Please understand the concept of global coverage of anything a human does isn’t what workers’ comp is for—WC insurance costs are virtually limitless, as there are no “caps” on some WC benefits, like lifetime medical care. If a lawyer or Arbitrator or truck driver is provided global coverage of any risk of injury or disease they encounter due to routine and ordinary travel that we all make as part of work or religion or education or any activity, you are wildly increasing workers’ comp coverage and costs. In some way, you have to keep the nexus between work and injury/illness to make sense of the WC coverage concept. In the IL Supreme Court’s famous ruling in a case called Venture-Newberg-Perini, et. als., we think they drew a line in the sand to confirm not all workers who are in movement reach the standard needed to become “traveling employees.”

We feel the defense team at KCB&A can help you understand how the IWCC and courts will draw that important line. If you have questions about a specific “traveling employee” claim, send a reply.

We appreciate your thoughts and comments. Please post them on our award-winning blog.

Synopsis: Governor Pritzker Appoints Four to IL WC Advisory Board.

Editor’s comment: We hope they actually “advise” someone unlike prior boards that wear the blue ribbons and do little to nothing.

Mark Denzler will serve on the Workers' Compensation Advisory Board. Mr. Denzler currently serves as the President and CEO of the Illinois Manufacturers' Association representing nearly 4,000 facilities across the state. Prior to joining the IMA, he worked as a Public Affairs Specialist for State Farm Insurance and worked in the Illinois General Assembly. Denzler is a current member of the IL Workers' Compensation Advisory Board, having been appointed by the two previous administrations. He earned his undergraduate degree from Illinois Wesleyan University and graduate degree from the University of Illinois-Springfield.

Karen Harris will serve on the Workers' Compensation Advisory Board. Ms. Harris currently serves as Senior Vice President and General Counsel of the Illinois Health and Hospital Association, a trade association representing over 200 hospitals and 50 health systems. In addition, she is the current Executive Director of the Illinois Association of Healthcare Attorneys. Prior to joining IHA, Harris was a Partner in the Health Care Practice Group of Saul, Ewing, Arnstein & Lehr LLP. Additionally, she served as Regional General Counsel at Aetna U.S. Healthcare, Inc. Harris earned honors in 2018 as a Chicago Business Journal Women of Influence honoree and in 2017 as one of the most influential minority lawyers in Chicago by Crain's Business Journal. Harris earned her Bachelor of Arts from Princeton University and Juris Doctor from Harvard Law School.

Mark Prince will serve on the Workers' Compensation Advisory Board. Mr. Prince has been a self-employed attorney in Illinois for 31 years. He has spent his career representing southern Illinoisans who have been injured on the job or by the negligence of others. Previously, Prince served as President of the Illinois Trial Lawyers Association and is a current member of the Executive Committee. Prince has been awarded two Trial Lawyer Excellence Awards from the Chicago Verdict Reporter and has served on the Workers' Compensation Advisory Board in the past. He earned his Bachelor of Science from Sangamon State University and a Juris Doctor from Southern Illinois University School of Law. 

Dave Weaver will serve on the Workers' Compensation Advisory Board. Mr. Weaver currently serves as the Directing Business Representative of the District 9, International Association of Machinists and Aerospace Workers Union, and President of the Illinois State Council of Machinists. Previously, Weaver has worked as a Business Representative with District 9, International Association of Machinists and Aerospace Workers Union, until being appointed Assistant Business Director. In addition, Weaver served the AFL-CIO as Labor Liaison with United Way of Greater St. Louis, Illinois Division and as Illinois Vice-President. Weaver began his career as a Machinist as an Apprentice Mechanic and a Journeyman Mechanic in Belleville, Illinois.

We appreciate your thoughts and comments. Please post them on our award-winning blog.

10-10-2019; Pancake House Fall-Down Denied; The Other Half of Our Marijuana in the Workplace Presentation and more

Synopsis: Pancake House Fall Down Denied by IL Appellate Court.

Editor’s comment: In a mildly surprising but legally well-founded ruling, a unanimous ruling from the IL Appellate Court, WC Division considered facts about a worker who suffered somewhat severe injuries prior to getting to work.

In Walker Brothers, Inc. v. Illinois Workers' Compensation Comm'n, (issued September 13, 2019), the IL WC Commission awarded Claimant medical, temporary total disability (TTD), and permanent partial disability (PPD) benefits. Claimant was seriously injured when he had parked his car and was walking, heading to work, and fell on ice in a retail store parking lot not owned nor maintained by his employer.

The worker and other restaurant employees were allowed to park in the other lot because the restaurant parking lot was felt to be too small for customers, vendors and employees. The Appellate Court ruling by Justice Holdridge noted there was no evidence that the employer controlled or maintained the other retail store’s parking lot. The parking lot where the worker fell was not part of a route “going to or coming from” that was required by the employer.

Basically, Claimant was on his way to work but hadn’t gotten close enough to be able to make a valid IL WC claim for his unfortunate injuries. 

Evidence of record indicated the employer had no designated employee parking lot. Further, pursuant to an “informal agreement with” the adjoining store, some employees parked in the parking lot where the fall took place “across the street and down half a block.” However, the employer did not pay the nearby business for use or maintenance of the lot. There was also evidence the employer’s employees were allowed to use only the section of parking spots furthest away from the retailer’s entryway and the Walker Bros. employees do not receive any priority over the retailer’s customers. A rep from the employer explained the employer’s employees have other options for parking, such as side street parking that required no payment or permit, and not all of the employer’s employees parked in the retailer’s parking lot.

For all those reasons, the unanimous Appellate Court reversed the IL WC Commission panel and held the injuries suffered did not arise out of or in course of his employment with the employer. Please note the worker might have been able to bring a common law claim for inadequate maintenance of the lot by its owner.

Synopsis: More on Marijuana in Your Workplace from Gene Keefe and Matt Ignoffo.

Editor’s comment: This is the other half of our presentation highlights. If you want a presentation/webinar on the topic, send a reply.

How to Best Deal With Marijuana in the Workplace—DON’T.

• We have clients across the U.S. asking about the optimal approach to marijuana in their work sites

• We recommend an easy approach to this issue—start now and forever ban marijuana in your workplace

• Make all workers aware you won’t tolerate impaired work activities, as it is dangerous to be impaired at any job, any place.

• All states we are aware of allow you to legally stop the use or impairment from marijuana in your work sites

• If you don’t act before you get a medical marijuana user asking about it and you block that user and then start to ban its use, you are almost certainly looking at a discrimination action

Illinois is the Eleventh State to Legalize Marijuana and Our New Law is Clearly Contradictory

• On June 25, 2019, Governor Pritzker signed into effect House Bill 1438—the Cannabis Regulation and Tax Act (“CRTA”).

• The CRTA, which is set to take effect on January 1, 2020, leaves open questions for employers, but there are a few important features with which Illinois employers should quickly become familiar.

Prohibitions on Disciplining or Discharging Employees for Off-Duty Consumption—But You Should Be Able to Discipline Impaired Workers

• The CRTA differs from many state laws legalizing recreational marijuana in that it explicitly protects an employee’s right to consume marijuana during off-duty hours. To me, that is just odd.

• By contrast, in some states that have legalized recreational consumption, employers remain free to adopt and enforce policies prohibiting employees from using marijuana both on and off-the-job.

Illinois Still Protects Employers and Allows Them to Punish Users Who are Impaired

• The CRTA will amend Illinois’s Right to Privacy in the Workplace Act, which prevents employers from disciplining or discharging employees for using “lawful products off the premises of the employer during nonworking hours.”

• The CRTA will define the previously undefined phrase “lawful products” to mean “products…legal under state law.”

• This is a noteworthy change because marijuana is still illegal at the federal level.

• By defining “lawful products” to mean those products that are legal at a state level, the CRTA appears to prevent employers from disciplining or discharging employees for recreationally using marijuana during off-duty hours. Notably however, federally regulated employers, such as those subject to federal DOT regulation, are carved out from this exemption.

Employers May Continue Drug Testing and Prohibit Working Under the Influence

• Under the CRTA, employers retain the ability to adopt and enforce “reasonable zero tolerance or drug free workplace policies, or employment policies concerning drug testing, smoking, consumption, storage, or use of cannabis in the workplace or while on call.”

• The only explicit restrictions on these policies are that employees will not be considered to be “on-call” unless they have had at least 24-hours’ notice, and drug policies must be “applied in a nondiscriminatory manner.”

Consider Melding Marijuana Impairment, Testing and Discipline to Opioid Bans

• You and everyone who might ever sit on a jury knows someone using either marijuana or opioids at work is impaired at a relatively significant level

• Under the theory of respondeat superior, employers are typically legally responsible for actions of their workers which they can “reasonably expect” the workers to do

• If your worker smashes into a school bus and injures lots of people and it is found you knew that worker was using marijuana or opioids with your knowledge and permission, the outcome could bankrupt your company

Our advice is ban marijuana and opioid use/impairment in your workplace—if you need our policy, let us know.

I appreciate your thoughts and comments. Please post them on our award-winning blog.