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Employee Lawsuits

$10 Million Awarded by North Carolina Jury to White Male Executive Is Costly Reminder to Employers That Efforts to Diversify Must Be Lawful

Employers of all sizes and in all industries are striving to bring diversity to their workforces, including at the management level. Employers would be well-served, however, not to lose sight of the fact that Title VII of the Civil Rights Act of 1964, which governs discrimination in employment, protects all employees from discrimination on the basis of their race (or other protected classification)—including white males. A North Carolina jury sent this message loudly and clearly in a recently decided case. Novant Health is a Winston-Salem-based network of clinics and medical centers. A white male former Senior Vice President of Marketing and Communications claimed that he was discriminated against when he was replaced by a black woman and a white woman as part of his employer’s diversity efforts. Racial discrimination claims by white employees, and gender discrimination claims by male employees, often are referred to colloquially (and somewhat dismissively) as “reverse” discrimination claims because the civil rights laws were enacted at a time when women and minorities primarily were suffering from discrimination. Nevertheless, the laws themselves are written in neutral terms—they prohibit employers from discriminating against any applicant or employee “because of” race, gender, or other immutable characteristics. Therefore, if an employer fires an employee “because of” his white race and male gender, then the employer has violated the discrimination laws. That is precisely the conclusion that the North Carolina jury reached in the case brought against Novant Health. The price tag for this violation was not cheap. The jury awarded the white male management employee $10 million. Employers should not be lulled into a false belief that because replacing a white employee with a non-white employee or a male executive with a female executive may bring them closer to their goal of increasing diversity, they are immune from a Title VII employment discrimination claim. Ultimately, if the replaced male or white employee can prove that they would not have been terminated but for their race or gender, they can successfully pursue a Title VII discrimination claim, potentially with very expensive consequences to the well-meaning employer. The lesson should be an obvious one, but in today’s cultural climate it bears repeating. Employers should make employment decisions based on merit, and they should apply objective standards relating to qualifications and performance. Employment decisions should not be based on an individual’s immutable classifications protected by law—which means neither deciding against nor in favor of any candidate or employee based on their race, sex, sexual orientation, or other protected classification. If you are an employer that is planning a personnel decision and are concerned that it may result in exposure to an employment discrimination claim, or if you have received an EEOC charge or have been sued for alleged employment discrimination, the experienced lawyers at Luchansky Law are ready to help. We can be reached at (410) 522-1020 or at www.employmentattorneymd.com.

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Joseph Wolf Nov 5 No Comments
COVID-19

Employer Alert: OSHA Rules on COVID-19 Vaccine Mandates

On September 9, 2021, President Biden directed the Occupational Safety and Health Administration (OSHA) to develop a rule to increase the number of workers who have received a COVID-19 vaccination.  Consistent with that direction, OSHA developed an Emergency Temporary Standard which would apply to employers with more than 100 employees.  On November 4, 2021, OSHA issued its final rule, requiring that all employees of employers with 100 or more employees either be vaccinated or be tested on a weekly basis and to have a negative test before coming to work. Here are the three critical components of OSHA’s new rule: First, all covered employers must ensure that their employees have received the shots to be fully vaccinated by January 4, 2021.  After January 4, 2021, all employees who have not received the necessary shots must produce a verified negative test on at least a weekly basis.  Any employee who tests positive must be removed from the workplace.  Please note that the OSHA rule does not require that the employer pay for the test. Second, all covered employers are required to provide paid leave, up to four hours per dose, for any unvaccinated employee to get vaccinated and, if needed, reasonable paid sick leave to recover from side effects.  If an employee has available sick leave, employers may require that employees use that time to cover those absences. Finally, all unvaccinated employees are required to wear a face mask while in the workplace starting December 5, 2021. As a practical matter, this means that all covered employers will need to determine the vaccination status of their employees prior to December 5, 2021 or require mandatory masking. For covered employers who have not yet implemented a vaccinate-or-test mandate, now is the time to prepare to implement a policy so that you will be prepared to comply with the rule. While the rule permits a testing option, covered employers can choose whether they want to have a mandatory vaccination policy, with testing as the accommodation for employees with religious and medical exemptions. For employees who are subject to weekly testing, the regulations dictate what kind of tests will be accepted for employees subject to weekly testing. Your policy will also need to address who will pay for the weekly test, as well as such practical matters as who in the organization will be responsible for ensuring that employees are complying with the weekly testing policies. Finally, you will need to designate an employee to handle requests for religious or medical accommodations and decide what kind of screening the company will do to ensure that requests for religious accommodations are legitimate. The OSHA rulemaking also requires that employers develop a written policy addressing these issues. Please note that, beyond questions about vaccination status, other medical inquiries by employers and businesses are still governed by the Americans with Disabilities Act.  If you have questions about how to comply with the rulemaking or for assisting in preparing a written policy, please contact one of our attorneys at (410) 522-1020 to set up an appointment to discuss how your policies can be structured to meet your company’s goals.

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Luchansky Law Team Nov 5 No Comments
Employee Agreements

The Latest on President Biden’s Executive Order to Promote Competition in the American Economy

Nearly four months ago, President Biden issued an executive order in which he urged the Federal Trade Commission to explore enacting rules to curtail the use of non-competes and other agreements that impede worker mobility. In the days and weeks that followed, there were myriad articles and blog posts published by employment lawyers (present company included), constitutional scholars, and HR gurus examining the legality of the federal government regulating employee/employer contracts and what effect the promulgation of a regulation severely limiting or even banning non-competition agreements would have on the business world. Today, nearly four months later, the FTC has not taken any action, and there is virtually no “buzz” about the issue. It is possible that the Biden Administration has been distracted by other more pressing issues, such as Afghanistan, a bogged-down supply chain, efforts to pass infrastructure and spending bills, or curbing parental interaction with school boards. It is also possible, and one can only hope, that cooler heads have prevailed, recognizing that, as discussed in one of our previous posts, (1) many states were already on their way toward either restricting the use of non-competes or banning them altogether to protect vulnerable employees who lack the bargaining power to resist or refuse them or (2) that a federal regulation like the one urged by the President would face a strong constitutional challenge. For now, the use and enforceability of non-competes are still governed by state law. In Maryland, this means that, preferably, employers should make sure that non-competes are signed before employment begins. If an employer wants an employee to sign an agreement while already employed, the agreement should specifically identify the consideration the employee is getting in exchange for signing the agreement. In Maryland (though not in some other states), this can be something as basic as “in consideration for continued employment.” In Maryland, non-competes signed by employees earning less than $31,200 a year or $15.00 an hour are unenforceable. Employers also should be careful not to overreach with regard to the geographical scope of the non-compete. Courts will balance the employer’s legitimate interest in protecting against an employee trying to capitalize on relationships developed with the employer’s customers during his or her employment against placing an overly burdensome restriction on the employee’s ability to work. Courts also will make sure that any restriction is limited to a reasonable time period. Maryland courts generally enforce two-year restrictions but rarely have enforced three-year restrictions. Non-competes also should not restrict an employee from working for a former or potential future competitor of the employer. It remains to be seen when, or even if, the FTC will attempt to implement President Biden’s executive order. In the meantime, Luchansky Law’s attorneys will be monitoring developments closely and are available to explain how existing state laws and potentially any new regulations affect your company’s non-compete agreements. We can be reached at (410) 522-1020 or at www.employmentattorneymd.com.

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Joseph Wolf Nov 4 No Comments
religious exemptions vaccine mandates
COVID-19

The Latest on Religious Exemptions to COVID-19 Vaccine Mandates

Many employers are being inundated with employee requests for religious exemptions to vaccine mandates. Employers who are evaluating religious exemption requests must take a nuanced approach or risk violating federal anti-discrimination statutes, such as Title VII and the ADA. Those employers hoping for clear-cut answers from the EEOC are likely to be disappointed, as the updated EEOC guidance issued on October 25, 2021, related to religious exemptions leaves more questions than answers. There is good news, however, as employers can utilize the following four steps to help avoid costly litigation:1. The first step an employer should take regarding religious exemption requests is to have a clearly defined policy for submitting such requests. This policy should be communicated to employees as soon as the policy has been implemented. Prior to implementation, supervisors and management should be trained on the specific duties they have in said policy. It is important that supervisors and managers are trained to begin applying the policy based upon any communication from an employee expressing they object to the employer’s vaccine mandate. Since federal anti-discrimination statutes do not contain any “magic words” that must be used, supervisors and managers should be prepared to direct employees to the exemption policy should an employee express a desire for an exemption in any form. 2. The second step is to have a dialogue with the employee. This dialogue must be part of the aforementioned exemption request policy. During the dialogue, the employer should assume that the religious belief is sincerely held. However, the EEOC guidance indicates that the employer should be on the lookout for the following items that would undermine the employee’s credibility: if the employee’s past and present actions are wholly inconsistent with the professed belief; if the employee is seeking a “particularly desirable” accommodation that is likely for non-religious reasons; if the timing of the request is suspicious; and if the employer has other reason to believe that the request is for a non-religious reason. Another item that can either support or undermine an employee’s position that they object to vaccines as part of a sincerely held religious belief is their past stance on vaccines. For example, have they gotten other vaccines since they’ve turned 18, such as the flu vaccine? 3. The third step is the employer’s evaluation of reasonable accommodation. The analysis is whether a reasonable accommodation that allows the employee to perform the essential functions of their position exists and whether the employer can implement that without undue hardship. When exploring reasonable accommodations, the employer should consider all possible accommodations, not just the one proposed by the employee. Federal anti-discrimination statutes entitle employees to a reasonable accommodation (if one exists) but do not require the employer to choose the employee’s preferred accommodation. Remote work, a private work area, masking, and alternative schedules are just a few examples of possible accommodations. If the employer selects a different accommodation, it should be transparent about its rationale. 4. Finally, the employer should be flexible to the changing nature of the COVID-19 pandemic. For example, if an employer has concerns about continuing a religious exemption due to an increase of cases in its area, it should re-engage in the second and third steps of its policy with the employee to find an accommodation that is more suitable to the changed circumstances than the current accommodation. As you can see, handling religious exemption requests requires diligence, nuance, and flexibility. We here at Luchansky Law are constantly monitoring EEOC guidance, and other official guidance, related to the forthcoming OSHA vaccine mandate enforcement. If you and your business would like assistance in creating a vaccine mandate, a religious exemption policy, or assistance evaluating a pending religious exemption request, give us a call at (410) 522-1020 to schedule a consultation.

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Luchansky Law Team Nov 2 No Comments
COVID-19

Does Back to School Mean Back to Work or Quarantining?

Prior to the pandemic, for most employers, children going back to school was a cause forcelebration. With children on a regular routine, working parents’ availability became moreroutine and, outside of holiday periods with school closures, fewer vacations were scheduled. For business owners, this created a level of predictability for scheduling, which was desirable forobvious reasons. Unfortunately, since the pandemic, predictable employee scheduling has beena near impossibility. This year, even with schools mostly returning to normal schedules, thepossibility of exposure-related quarantines for students continues to complicate schedulingdecisions. Further complicating the issue is the uncertainty around whether any paid leavemandates apply to absences due to childcare issues created by school-mandated quarantines. For employers who voluntarily opted into the additional paid sick and family leave forCOVID-related illnesses under the American Rescue Plan Act, those illnesses would have been covered under that law until September 30, 2021. The amounts paid to employees for paid leavewould be also eligible for the tax credits provided under the law. However, starting October 1, 2021,the issue is more complicated as the tax credits provided under the American Rescue Plan Actended. For most employers, this means that the entitlement to additional paid leave would haveended, leaving employees with limited legal protections. Other than the optional extension of paid sick and family leave under the AmericanRescue Plan Act, most leave mandates under Maryland and federal law are limited to caring forfamily members suffering from an actual illness, injury, or disability. At first blush, none of themappear to mandate that employers provide leave, whether paid or unpaid, to employees unable towork due to childcare needs caused by a child’s mandatory quarantine from school. As a result,employers will retain a lot of discretion in how they will formulate their policies and proceduresrelated to leave to care for a child who is unable to attend school because they have been exposedto another student who has tested positive with COVID-19. In practice, though, employers will needto be careful when implementing and applying a policy related to leave and discipline foremployees unable to work due to childcare issues since unequal or uneven enforcement of suchrules can be an immediate source of liability for employers. For example, if certain employeesor classes of employees are provided with differing levels of leave or there is a perception thatcertain employees are being treated more harshly in response to requests for time off, employersmay still face charges or claims of unlawful discrimination. If you have questions about how to implement or enforce a leave policy for employeeswho are unable to work due to a child’s quarantine from school, please contact one of ourattorneys at (410) 522-1020 to set up an appointment to discuss how your policies can bestructured to meet your company’s goals.

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Luchansky Law Team Oct 5 No Comments
Employee Agreements

Healthcare Employers: Don’t Learn About the FLSA “Learned Professional” Exemption the Hard Way

A widespread myth regarding the FLSA is that employees who are “on salary” do not need to be paid overtime. This misunderstanding of the law creates a significant risk that healthcare entities may be violating the law by failing to pay their employees overtime merely because they are salaried. While being paid on a salary basis is a requirement for a healthcare employee to be exempt from overtime, the employee’s duties must also qualify for one of the FLSA exemptions, which, for healthcare workers, is most often the “learned professional” exemption. In order to qualify for the learned professional exemption, an employee must be paid a minimum of $684 per week or $35,568 annually on a salary basis. In addition, the employee’s primary duty must be the performance of work requiring advanced knowledge in a field of science or learning, and the advanced knowledge must customarily be acquired through a prolonged course of instruction. Work requiring “advanced knowledge” is work that is predominantly intellectual in character and which requires the exercise of discretion and judgment. These requirements can be easily applied to some employees in a healthcare setting, such as a physician (generally exempt) on one hand, and a medical records clerk on the other (non-exempt). The exemptions applicability to other positions at a healthcare facility is not as clear-cut. Generally, a registered nurse, who must complete multiple years of training and education and is subject to examination by a state licensing board is exempt from overtime payment under the FLSA. Conversely, a licensed practical nurse or a medical aide would generally not be exempt from overtime even if paid on a salary basis. Nurse practitioners, who generally undergo a higher level of training than RNs, would generally be exempt if they are, in fact, practicing medicine. Similarly, physician assistants who have completed a four-year course of study including graduating from an accredited PA program and who have received commission certification, are generally exempt when actually practicing medicine. Medical technologists who have completed a total of four years of study including a year at an accredited medical technology school also may be exempt. However, the mere fact that an employee such as an x-ray technician or ultrasound technician is regularly involved in the use of medical technology is insufficient alone to meet the requirements of the exemption even if earning a salary. A registered dietitian working in a clinical setting who is responsible for counseling individuals with health problems, such as patients with diabetes or dialysis patients, would also generally be exempt from overtime if paid on a salary basis. If you are concerned that you may have incorrectly classified a healthcare worker as exempt from overtime, ask the following three questions: (1) Is the employee being paid a salary of at least $684 per week or $35,568 annually? (2) Is the employee performing a job for which they needed to complete a significant number of years of education and that is subject to oversight by a licensing board? (3) Is the employee permitted to exercise judgment and discretion in the performance of their job? If an employer cannot definitively answer “Yes” to each of these questions, there is a distinct possibility that they have misclassified the employee. Correctly applying the learned professional exemption can be challenging, while misapplying it can have significant and expensive consequences. If you own or are an administrator of a healthcare entity and need guidance as to how to classify employees, the lawyers at Luchansky Law are here to help. Call us at (410) 522-1020.

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Joseph Wolf Sep 16 No Comments
COVID-19

Unemployment Benefits Unavailable for Those Who Refuse to Comply with Employers’ Vaccine Mandates

Due to the alarming spread of the COVID-19 Delta variant among the unvaccinated, coupled with FDA approval of the Pfizer-BioNTech Vaccine, many private employers have implemented vaccine mandates. These mandates are permissible, so long as precautions are taken to comply with various anti-discrimination laws. A less obvious implication of these vaccination mandates is that employees who are discharged for failure to comply with a vaccine mandate will likely be barred from receiving unemployment insurance benefits. As the name suggests, unemployment insurance provides benefit payments should the former employee (the “claimant”) become unemployed. These benefit payments are charged to the former employer who is then required to pay a percentage back to the State, akin to an insurance deductible. However, as with any insurance, there are conditions. The most important one is that the claimant must be out of work through no fault of their own. One common way that claimants find themselves on the wrong side of a benefits determination is by being discharged for violating their former employer’s policies and/or procedures. Such discharge is classified as either simple misconduct or gross misconduct. Claimants who were discharged for misconduct or gross misconduct by their former employer are ineligible to receive benefits and this is where the vaccination mandates are implicated. An employee who is discharged for refusal to comply with a vaccination mandate, absent a proper ADA or Title VII accommodation, is guilty of either simple misconduct or gross misconduct, the same way they would be if their discharge were for violation of another policy, such as drug testing or attendance. For cases of simple misconduct, the claimant may only be ineligible for benefits during a penalty period, which is measured in weeks. Simple misconduct cases have an element of reasonable excuse for the violation of the employer’s policy or procedure. However, in Maryland, the Department of Labor requires the claimant to put forth evidence of such mitigating factors regarding their refusal prior to issuing a finding of simple misconduct. The penalty period can range anywhere from 4 weeks to 26 weeks, depending upon how convincing the Department of Labor finds the mitigating factors. Gross misconduct, on the other hand, requires a showing of willfulness or a wanton disregard for the employer’s policies. This is where most claimants who would be discharged for vaccination policy violations would find themselves. Most employees who are refusing vaccination mandates have no mitigating factors; they simply do not want to be vaccinated. Gross misconduct is an absolute bar to unemployment benefits until the claimant is reemployed and earns at least 25 times the amount of their original weekly benefit amount. For an employer to successfully block a claim for benefits filed by a former employee discharged for violating the vaccination policy, the employer will need to ensure its vaccination policy is clear, communicated to the employees, and is uniformly applied. At Luchansky Law, we are well-versed in assisting employers with crafting mandatory vaccination policies as well as defending improper unemployment benefits claims. If your business would like assistance with either creating a vaccination policy or contesting an unemployment insurance claim related to its vaccination policy, give us a call at (410) 522-1020 to schedule a consultation.

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Luchansky Law Team Sep 15 No Comments
COVID-19

No, HIPAA Does Not Prevent Employers from Asking About Vaccination Status

As businesses have begun mandating vaccinations for employees and customers, many have heard a common response, in one form or another, “You can’t ask me that because of HIPAA.”  In written form, these responses often invoke the protection of HIPPA, which is not a law.  (These responses often echo the statements of certain elected officials, who presumably should know better.)  Due to the myriad laws affecting both the type and timing of questions that may be asked of employees and customers, this statement gives many businesses pause as they seek guidance as to whether some other new law affecting their operations has been enacted without their knowledge.  Fortunately, for nearly every business, subject to some specific exceptions, the response is that, no, HIPAA does not prevent you from asking your employees or customers about their vaccination status. Why do so many people make this mistake?  The Health Insurance Portability and Accountability Act (HIPAA) was enacted, among other reasons, to regulate the flow of healthcare information and address how personally identifiable information and protected health information (“PHI”) are maintained by the healthcare and healthcare insurance industries should be protected from fraud and theft.  The HIPAA Privacy Rule limits the uses and disclosures of PHI required for treatment, payment, or healthcare operations.  As a result, the HIPAA Privacy Rule only applies to healthcare providers, health plans, and the business affiliates that they contract with in connection with treatment, payment, or healthcare operations.  However, due to misunderstandings around the scope of the law, many have taken the HIPAA Privacy Rule to mean that no one may ask questions related to an individual’s medical conditions.  That is simply not true.  By its express terms, HIPAA does not apply to questions about medical conditions from private citizens, businesses, or the media.  If an employer asks an employee to provide proof that they have been vaccinated consistent with a workplace mandate, that is not a HIPAA violation.  The United States Department of Health and Human Services (“HHS”), which enforces HIPAA, has provided explicit guidance to that effect.  While an employee may refuse to provide information about their vaccination status to their employer, nothing in HIPAA prevents that employer from then terminating that employee if they have enacted an otherwise valid vaccination mandate. Please note that, beyond questions about vaccination status, other medical inquiries by employers and businesses are still governed by the Americans with Disabilities Act.  If you have questions about how to implement a vaccine mandate or the types of questions your business can ask its employees, please contact one of our attorneys at (410) 522-1020 to set up an appointment to discuss how your policies can be structured to meet your company’s goals.

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Luchansky Law Team Sep 7 No Comments
Reasonable Accommodations under the ADA

Wal-Mart Ordered to Pay Over $125 Million to Former Disabled Employee

Wal-Mart has been hit with over a $125 million dollar jury verdict in a lawsuit filed against it by the EEOC. A Wisconsin jury found that Wal-Mart was in violation of the Americans with Disabilities Act (“ADA”) when it discriminated against an employee with Down Syndrome and ultimately terminated her. Further, Wal-Mart was found to have discriminated against that same employee by refusing to rehire her because of her disability. The bulk of this award was punitive damages as Wal-Mart’s conduct was found by the jury to be particularly heinous. The EEOC filed a suit against Wal-Mart on behalf of Mario Spaeth, an employee of that store from 1999 to 2015. Spaeth has Down Syndrome and worked in the store part-time. As a result of Wal-Mart’s computerized scheduler, Spaeth’s schedule was abruptly changed in 2014because of a shift in customer demand. Because of her disability, this schedule change presented significant challenges for her, and her supervisors began writing her up for attendance issues. In response, Spaeth’s sister and legal guardian requested a reasonable accommodation for Spaeth in the form of returning her to her previous schedule. Wal-Mart refused, continued writing up Spaeth for attendance, and ultimately terminated her. In their termination letter, Wal-Mart noted that Spaeth would be eligible for rehire. However, Wal-Mart refused to rehire Spaeth when she reapplied because she requested the accommodation that she only be scheduled during certain hours because of her disability.  During the trial, EEOC attorneys introduced Spaeth’s 16 years’ worth of positive performance reviews prior to the schedule change, that the store which employed Spaeth had over 300 employees, and the termination letter which noted she was eligible for rehire. Dozens of the store employees would have been able to switch shifts with Spaeth at no cost to Wal-Mart and Spaeth had already demonstrated she could perform the essential functions of her job during the shift she requested. Ultimately the jury determined that Wal-Mart’s conduct was a failure to provide reasonable accommodation under the ADA. Additionally, the jury found that its conduct was willful, necessitating punitive damages. Spaeth was awarded $150,000 in compensatory damages and $125 Million in punitive damages. A spokesperson for Wal-Mart notes that the amount of the punitive damages will be reduced to the maximum allowed under the ADA which is $300,000. This verdict sends a strong message to businesses: ADA compliance is not something to be taken lightly and violations will be punished, severely. At Luchansky Law, our attorneys are well-versed in federal anti-discrimination laws, including the ADA. If your business would like assistance responding to requests for accommodation under the ADA for either an applicant or employee, give us a call at (410) 522-1020 to schedule a consultation.

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Luchansky Law Team Sep 6 No Comments
COVID-19

FDA Full Authorization Leads to More Employer Mandates

On August 23, 2021, the FDA granted full approval to the Pfizer-BioNTech COVID-19 Vaccine, which had previously been authorized under an emergency use authorization.  Although some private employers had begun implementing vaccine mandates for employees under the EUA, particularly in the health care field, many had signaled that they were waiting for a vaccine to receive full approval prior to making vaccines mandatory.  Following the full approval of the Pfizer vaccine, many more private and government employers, including CVS, Chevron, and McDonald’s, have begun to implement vaccine mandates.  For those employers considering making vaccines mandatory, there are a number of practical considerations to address, from whether a mandate is advisable to the practical components of the policy. First, from a practical standpoint, many industries have been shaken up by what has been coined, “The Great Resignation.”  If your business is struggling to recruit and retain employees, a mandatory vaccination policy may create some initial upheaval in your workforce.  Second, how critical are in-person interactions to your business operations?  Employers intending to continue remote work for the foreseeable future may feel less urgency to mandate vaccines, while those requiring in-person attendance may feel more acute pressure to require vaccines, both to ensure that their customers feel safe and to ensure that their operations will not be shut down due to possible exposure. Beyond the considerations about whether to implement a mandatory vaccination policy, businesses must also decide what their policy will include.  Will vaccinations be mandatory, full stop, with exceptions only for religious and medical exemptions?  Will employees be permitted to opt-out, subject to mask-wearing and weekly testing requirements?  If so, what kind of tests will be accepted for employees subject to weekly testing?  Who will be responsible for ensuring that employees are complying with the weekly testing policies?  How long will employees have until they are required to be fully vaccinated?  All of these questions should be answered in any vaccination policy. Please note that, beyond questions about vaccination status, other medical inquiries by employers and businesses are still governed by the Americans with Disabilities Act.  If you have questions about how to implement a vaccine mandate or the types of questions your business can ask its employees, please contact one of our attorneys at (410) 522-1020 to set up an appointment to discuss how your policies can be structured to meet your company’s goals.

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Luchansky Law Team Sep 3 No Comments

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