Rl1 #1022709-v1-marsh interplay

Understanding the Interplay between the ADA, FMLA
and Workers’ Compensation
© 2012 Fox Rothschild
Understanding the Interplay between the
ADA, FMLA and Workers’ Compensation
How to Minimize Litigation Risks and Reduce
Insurance Costs
Presented by
Christina A. Stoneburner
April 19, 2012
Valpak 1

FMLA BASICS
Provides eligible employees with up to 12
weeks of unpaid leave for qualifying reasons
(or 26 weeks to care for a covered
servicemember) in a 12-month period
Benefit continuation
Generally, right to reinstatement
Valpak 2

Covered Employer
COVERED EMPLOYER §825.104, 825.105
- Employs 50 or more employees
- For 20 or more calendar weeks in the current or
preceding year
- Foreign employees are not counted
Valpak 3

Eligible Employee
ELIGIBLE EMPLOYEE §825.110
- 12-Month Service Requirement
12 months need not be consecutive
Separate periods of employment counted if the
break in service does not exceed 7 years
– Breaks in excess of 7 years:
» National Guard or Reserve military service; or
» Written agreement re: intention to rehire
» May consider prior employment outside gap if do so
for all employees with similar breaks
Valpak 4

Eligible Employee
ELIGIBLE EMPLOYEE (cont’d):
- 1250 hours worked in 12-months
immediately preceding request for leave
Valpak 5

Eligible Employee
ELIGIBLE EMPLOYEE (CONT.)
- Employed at a worksite where 50 or more
employees employed within 75 miles of worksite
Employee’s work site for purposes of 50 employee/75 mile
rule is the site to which the employee reports to work or, if
none, from which the employee’s work is assigned
(§825.111)
Valpak 6

Calculation of Leave Period
CALCULATION OF THE 12-MONTH LEAVE PERIOD:
the calendar year (January - December).
a fixed leave year
a "rolling" 12-month period measured backward from
the date of any FMLA leave usage
the 12-month period measured forward from the date
of the first FMLA leave usage
Valpak 7

MILITARY CAREGIVER MEDICAL LEAVE 12-
MONTH LEAVE PERIOD:
Is always on a rolling forward basis
- Even if employer uses some other method for
calculating the leave period for other family,
medical, and military family leave
Valpak 8

Ineligible Employee Becomes
Eligible
If employee initially on non-FMLA leave, and
becomes eligible for FMLA leave, rest of leave
is FMLA leave (§825.110)
Valpak 9

Leave Entitlements Under the FMLA
Leave is covered under the FMLA (§825.112):
- To care for their newborn child and for the adoption or foster
placement of a child (“family leave”);
- For the serious health condition of their spouse, minor (child
under 18) or disabled child, step-parent, foster parent or parent
(“family leave”); or
- For their own serious health condition, including pregnancy
and on-the-job illness or injury, which makes them unable to
perform at least one of the essential functions of their position
(“medical leave”).
Valpak 10

Leave Entitlements Under the FMLA
COVERED LEAVE UNDER THE FMLA (CONT.):
- For any qualifying emergency arising out of the fact that a spouse,
son, daughter or parent is on active duty or has been notified of an
impending call to active duty status, in support of a contingency
operation (referred to as “military family leave”)
- To provide care for a spouse, son, daughter, parent, or nearest blood
relative who is a covered servicemember and who needs medical
treatment, recuperation or therapy, is otherwise in out-patient status
or is otherwise on the temporary disability retired list for a serious
illness or injury incurred in the line of duty (referred to as “military
caregiver medical leave” ).
Valpak 11

Continuation of Benefits During
Leave
Group health plan §825.209
- The same benefits under the same circumstances as before
leave was taken
- If the Employer changes the health plan for all employees
while an employee is on FMLA leave, must be allowed to enroll
as if not on leave
- Employee must still pay employee’s share of health insurance
premiums
Valpak 12

Reinstatement Rights
§825.214
Generally, employee is entitled to
reinstatement to the same position or to
an equivalent position with equivalent
benefits, pay, and other terms and
conditions of employment
Valpak 13

Transfer to Alternative Position if
Intermittent or Reduced Schedule
§825.204
- Require temporary transfer to available, alternative
position
Only if leave is foreseeable based on planned medical treatment
for employee, family member, or covered servicemember or
Where employer agrees to permit intermittent or reduced
schedule leave for birth of child or placement for adoption or
foster care
Valpak 14

Transfer to Alternative Position
§825.204
- Employee must be qualified for the position,
- Position must better accommodate recurring periods of leave, and
- Pay the same with the same benefits.
No requirement of equivalent duties.
- Reinstate to the same or equivalent position held when left (may not
require employee to take more leave than requires)
Valpak 15

When Employee is Not Entitled to
Reinstatement
§825.216
Employee would not have been employed even if not on leave
- Employee would have been laid off
- Position eliminated due to permanent restructuring
Be cautious restructuring is not seen as excuse to interfere with FMLA
rights
Employee does not return fitness-for-duty certification
“Key Employee”
Valpak 16

Key Employee Defined
§825.217, 825.218
Salaried employee who is among highest paid 10% of employees
employed within 75 miles of worksite
Denial of reinstatement only if to prevent “substantial and grievous
economic injury to operations of employer”
Must notify employee at outset of leave if designated as key
employee and potential consequences for reinstatement
Valpak 17

Reinstatement From Light Duty
PROTECTION FOR EMPLOYEES WHO
ASSERT FMLA RIGHTS §825.220
Voluntary acceptance of a light duty assignment
– Not waiver of restoration right
– Right to restoration ends at the end of the applicable 12-month
FMLA leave year.
Valpak 18

Employer Notice Requirements
§825.300: General Notice (combined poster
and policy requirements):
Explain Act & complaint procedures
Post in conspicuous place
– Electronic posting sufficient
Must also provide in employee handbooks or other
written guidance
Valpak 19

§825.300: Eligibility Notice:
Notify employee within 5 business days of request or
knowledge of need for FMLA-qualifying leave
If ineligible employee, provide at least one reason why
Notice may be oral or written
Valpak 20

§825.300: Rights & Responsibilities Notice
Written notice: expectations & consequences
Each time the Eligibility Notice is provided
Examples of information included:
– Whether the leave may be designated FMLA leave
– Applicable 12-month period
– Certification requirement
– The right to substitute paid leave
– Premium payments and consequences of failure to pay and/or return
– Key employee status
Valpak 21

§825.300: Designation Notice:
Written notice within 5 business days (absent extenuating
circumstances)
Amount of leave—if know, # of hours/days/weeks
Leave that does not qualify
Any fitness-for-duty requirements
Valpak 22

General Rule
§ 825.305
- Notice of certification requirement
Request within 5 business days of notice of need for leave
- Employee must provide the certification within 15 calendar days
- Complete and sufficient requirement—notify of problems in writing
7 calendar days to cure deficiencies, unless not practicable
- Certification each subsequent leave year for conditions lasting beyond
a single leave year.
Valpak 23

Fitness for Duty Certifications
§ 825.312
- Require certification that can return to work
Only for condition that caused need for FMLA leave
- Address employee’s ability to perform the essential functions of the
job
List of essential functions of job and notice that assessment will be
required must be provided in the designation notice
- Can require fitness for duty certification for each continuous leave
- Every 30 days if reasonable for intermittent and reduced schedule
leave
15 days to provide certification under the every 30 days rule
Valpak 24

Americans with Disabilities Act
The ADA prohibits employers from discriminating
against qualified individuals with disabilities in all terms
and conditions of employment. The statute requires
employers to reasonably accommodate disabled
employees who are otherwise qualified for their
positions. Disability is defined under the ADA as:
- a physical or mental impairment that substantially limits one or
more major life activities;
- a record of such an impairment; or
- being regarded or perceived as having such an impairment.
Valpak 25

Types of Accommodations
Leave
Transfers
Modified Work Schedules
Reduced Work Schedules
Light Duty
Valpak 26

Essential Functions
Under the ADA, an employer is not
required to remove an “essential function”
as an accommodation
- Job descriptions should realistically list
essential functions
Valpak 27

Interactive Process
Employers are required to have a
conversation about possible
accommodations
- Employers do not have to grant specific
accommodation requested by employee
- Request from employees need not be formal
Valpak 28

Undue Hardship
Employer does not have to grant
accommodation if doing so would cause
undue hardship, which may include:
- Cost
- Overall company financial resources
- Availability of other employees to cover
Valpak 29

Direct Threat
Employer also can deny accommodation
or terminate if employee is direct threat to
him/herself or others
- Be careful that this is not based on
assumptions or prejudices
Valpak 30

Workers’ Compensation
There is no guarantee of leave under the
statute
- Employees may be entitled to medical
coverage;
- Weekly benefits
- Permanency awards.
Valpak 31

Light Duty Programs
Employers are not Obligated to Create a
Light Duty Position as an
Accommodation
- Employers may choose to have a light duty
program that only applies to Workers’
Compensation injuries
Valpak 32

Scenario
Meredith was hired on May 12, 2010. On Monday, April
4, 2011, Meredith was pulling boxes off a warehouse
shelf when the box fell on her. She is taken to the
emergency room. The following day Meredith faxes in
a doctor’s note that states she has a severe back
sprain and will need to be out of work the rest of the
week. Meredith has already used her sick leave for the
year.
- Is Meredith entitled to leave?
- Do you have to notify the Workers’ Compensation Carrier?
- Is Meredith entitled to Workers’ Compensation benefits?
Valpak 33

Scenario (cont.)
Meredith returns to work the following week. Meredith
works through April and then complains that she still
has significant back pain. Meredith brings in a doctor’s
note that indicates that Meredith has a ruptured disc in
her spine that is going to require surgery and then
extensive physical therapy. The note indicates that it is
expected that Meredith will need to be out of work for
at least 10 weeks.
- Is Meredith entitled to leave? Is the leave FMLA leave?
- Is Meredith entitled to WC benefits?
Valpak 34

Scenario (cont.)
Meredith has had the surgery and completed four
weeks of physical therapy. The WC doctor sends a
report that Meredith is cleared to return to work but she
cannot lift more than 20 pounds and cannot stand more
than 20 minutes at a time. The company has a light
duty program where it will transfer Meredith to a desk
job until her restrictions are lifted. Meredith refuses the
light duty position and asks for two more weeks leave.
- Can you terminate Meredith?
- Is Meredith entitled to WC benefits?
Valpak 35

Scenario (cont.)
After Meredith has exhausted her FMLA
leave, Meredith has a setback in physical
therapy and the doctor now indicates she
is unable to work at all and will require 4
more weeks leave.
- Do you have to give Meredith the leave?
Valpak 36

Scenario (cont.)
You have granted Meredith the additional
4 weeks leave. A few days before she is
scheduled to come back, Meredith’s
doctor indicates that she cannot return to
work and will be reevaluated in 30 days.’
- Now can you terminate Meredith?
Valpak 37

Scenario (cont.)
After Meredith has been out of work for a total
of 22 weeks, she is still unable to come back to
work. She is still receiving WC benefits. You
decide to terminate Meredith as you can no
longer accommodate her. The day after you
terminate Meredith, her union representative
files a grievance and demands that Meredith
be placed back at work because the company
is obligated to give her leave while she
receives benefits.
- Is the union right?
Valpak 38

Contact Information
973-994-7551
cstoneburner@foxrothschild.com
Valpak 39

Understanding the Interplay between the
ADA, FMLA and Workers' Compensation
How to Minimize Litigation Risks and Reduce
Insurance Costs
Presented by
April 19, 2012
and Workers' Compensation
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 40

FMLA BA ICS
Provides eligible employees with up to 12
weeks of unpaid leave for qualifying reasons
(or 26 weeks to care for a covered
servicemember) in a 12-month period
■ Benefit continuation
Generally, right to reinstatement
Understanding the Interplay between the ADA,FMLA
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 41

Covered Employer
COVERED EMPLOYER §825.10 , 825.105
- Employs 50 or more employees
- For 20 or more calendar weeks in the current or
preceding year
- Foreign employees are not counted
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 42

Eligible Employee
ELIGIBLE EMPLOYEE §825.110
- 12-Month Service Requirement
12 months need not be consecutive
Separate periods of employment counted if the
break in service does not exceed 7 years
Breaks in excess of 7 years
» National Guard or Reserve military service; or
» Written agreement re: intention to rehire
May consider prior employment outside gap if do so
for all employees with similar breaks
»
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 43

Eligible Employee
ELIGIBLE EMPLOYEE (cont'd)
- 1250 hours worked in 12-months
immediately preceding request for leave
Fox Rothschild LLP
ATTORNEYS AT LAW
1 1 ■ ■
Valpak 44

Eligible Employee
ELIGIBLE EMPLOYEE (CONT.)
Employed at a worksite where 50 or more
employees employed within 75 miles of worksite
Employee's work site for purposes of 50 employee/75 mile
rule is the site to which the employee reports to work or, if
none, from which the employee's work is assigned
(§825.111)
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 45

CALCULATION OF THE 12-MONTH LEAVE PERIOD
the calendar year (January - December)
a fixed leave year
a rolling" " 12-month period measured backward from
the date of any FMLA leave usage
the 12-month period measured forward from the date
of the first FMLA leave usage
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 46

MILITARY CAREGIVER MEDICAL LEAVE 12-
MONTH LEAVE PERIOD
■ Is always on a rolling forward basis
Even if employer uses some other method for
calculating the leave period for other family ,
medical, and military family leave
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 47

Ineligible Employee Becomes
f employee initially on non-FMLA leave, an.
•ecomes eligible for FMLA leave, rest of leave
is FMLA leave (§825.110)
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 48

Leave Entitlements Under the FM LA
Leave is covered under the FMLA (§825.11 2)
- To care for their newborn child and for the adoption or foster
placement of a child ("family leave") ,
- For the serious health condition of their , minor (child
step-parent, foster parent or parentunder 18) or disabled child,
("family leave") ; or
- For their own serious health condition , including pregnancy
and on-the-job illness or injury, which makes them unable to
perform at least one of the essential functions of their position
("medical leave")
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 49

Leave Entitlements Under the FM LA
*COVERED LEAVE UNDER THE FMLA (CONT.)
son, daughter or parent is on active duty or has been notified of an
For any qualifying emergency arising out of the fact that a spouse ,
operation (referred to as military family
p
l
port
")
impending call to active duty status, in su of a contingency
" eave
= To provide care for a spouse, son, daughter,dparent,
relative who is a covered servicemember
or nearest blood
who needs medical
treatment, recuperation or therapy, is otherwise in out-patient status
disability retired list for a seriousor is otherwise on the temporary
illness or injury incurred in the line of duty (referred to as "military
caregiver medical leave" ).
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 50

Continuation of Benefits During
Group health plan §825.209
Leave
The same benefits under the same circumstances as before
leave was taken
o If the Employer changes the health plan for all employees
while an employee is on FMLA leave, must be allowed to enroll
as if not on leave
o Employee must still pay employee's share of health insurance
premiums
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 51

Reinstatement Rights
§825.214
Generally, employee is entitled to
reinstatement to the sameposition or to
an equivalent position with equivalent
pay and other terms and,
conditions of employment
Fox Rothschild LLP
Valpak 52

Transfer to Alternative Position if
Intermittent or Reduced Schedule
§825.204
- Require temporary transfer to available, alternative
position
Only if leave is foreseeable based on planned medical treatment
for employee, family member, or covered servicemember or
Where employer agrees to permit intermittent or reduced
schedule leave for birth of child or placement for adoption or
foster care
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 53

Transfer to Alternative Position
§825.204
o Employee must be qualified for the position,
Position must better accommodate recurring periods of leave, and
Pay the same with the same benefits
o
No requirement of equivalent duties.
o Reinstate to the same or equivalent position held when left (may not
require employee to take more leave than requires)
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 54

When Employee is Not Entitled to
§825.216
Reinstatement
Employee would not have been employed even if not on leave
Employee would have been laid off
Position eliminated due to permanent restructuring=
Be cautious restructuring is not seen as excuse to interfere with FMLA
rights
Employee does not return fitness-for-duty certification
"Key Employee"
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 55

Key Employee efined
§825.217, 825.218
Salaried employee who is among highest paid 10% of employees
employed within 75 miles of worksite
Denial of reinstatement only if to prevent substantial and grievous"
economic injury to operations of employer
Must notify employee at outset of leave if designated as key
employee and potential consequences for reinstatement
"
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 56

Reinstatement From Light Duty
PROTECTION FOR EMPLOYEES WHO
ASSERT FMLA RIGHTS §825.220
Voluntary acceptance of a light duty assignment
Not waiver of restoration right
Right to restoration ends at the end of the applicable 12-month
FMLA leave year.
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 57

Employer Notice ments
§825.300 General Notice (combinedposter
andpolicy requirements) .
Explain Act & complaint procedures
Post in conspicuous place
Electronic posting sufficient
Must also provide in employee handbooks or other
written guidance
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 58

§825.300 .Eligibility Notice
Notify employee within 5 business days of request or
knowledge of need for FMLA-qualifying leave
If ineligible employee, provide at least one reason why
Notice may be oral or written
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 59

§825.300: Rights & Responsibilities Notice
Written notice: expectations & consequences
Each time the igibility Notice is provided
Examples of information included
Whether the leave may be designated FMLA leave
Applicable 12-month period
Certification requirement
—
The right to substitute paid leave
Premium payments and consequences of failure to pay and/or return
Key employee status—
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 60

§825.300 Designation Notice •
Written notice within 5 business days (absent extenuating
circumstances)
Amount of leave if know, # of hours/days/weeks
Leave that does not qualify
Any fitness-for-duty requirements
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 61

eneral Rule
§ 825.305
Notice of certification requirement
Request within 5 business days of notice of need for leave
Employee must provide the certification within 15 calendar days
Complete and sufficient requirement notify of problems in writing
7 calendar days to cure deficiencies, unless not practicable
Certification each subsequent leave year for conditions lasting beyond
a single leave year.
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 62

■ § 825.312
Require certification that can return to work
Only for condition that caused need for FMLA leave
o Address employee's ability to perform the essential functions of the
job
List of essential functions of job and notice that assessment will be
o
required must be provided in the designation notice
Can require fitness for duty certification for each continuous leave
Every 30 days if reasonable for intermittent and reduced schedule
leave
o
15 days to provide certification under the every 30 days rule
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 63

Americans with isabilities Act
The ADA prohibits employers from discriminating
against alified individuals with disabilities in all terms
and conditions of employment The statute requires
employers to reasonably accommodate disabled
employees who are otherwise qualified for their
positions. Disability is defined under the ADA as
- a physical or mental impairment that substantially limits one or
more major life activities;
a record of such an impairment; or
- being regarded or perceived as having such an impairment.
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 64

Types of Accommodations
Leave
Transfers
Modified Work Schedules
Reduced Work Schedules
Light Duty
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 65

ssential Functions
required to remove an
Under the ADA , an employer is not
"essential function "
as an accommodation
- Job descriptions should realistically list
essential functions
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 66

Interactive Process
Employers are required to have a
conversation aboutpossible
accommodations
- Employers do not have to grant specific
accommodation requested by employee
- Request from employees need not be formal
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 67

Undue Hardship
Employer does not have to grant
accommodation if doing so would cause
undue hardship
-
, which may include
Cost
- Overall company financial resources
. Availability of other employees to cover
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 68

Direct Threat
Employer also can deny accommodation
or terminate if employee is direct threat to
him/herself or others
- Be careful that this is not based on
assumptions or prejudices
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 69

Workers' Compensation
There is noguarantee of leave under the
statute
Employees may be entitled to medical
coverage ,
- Weekly benefits
Permanency awards
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 70

Employers are not Obligated to Create a
Light Duty Position as an
Accommodation
- Employers may choose to have a light duty
program that only applies to Workers '
Compensation injuries
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 71

Scenario
Meredith was hired on May 12, 2010. On Monday, April
4, 2011 Meredith was pulling boxes off a warehouse
shelf when the box fell on her. She is taken to the
emergency room
a doctor's note that states she has a severe back
sprain and will need to be out of work the rest of the
week. Meredith has already used her sick leave for the
The following day Meredith faxes in
year
Is Meredith entitled to leave?
Do you have to notify the Workers' Compensation Carrier?
Is Meredith entitled to Workers' Compensation benefits?
-
-
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 72

cenario (cont )
Meredith returns to work the following week. Meredith
works through April and then complains that she still
has significant back pain Meredith brings in a doctor's
note that indicates that Meredith has a ruptured disc in
her spine that is going to require surgery and then
extensive physical therapy The note indicates that it is
expected that Meredith will need to be out of work for
at least 10 weeks
© Is Meredith entitled to leave? Is the leave FMLA leave?
o Is Meredith entitled to WC benefits?
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 73

cenario (cont )
Meredith has had the surgery and completed four
weeks of physical therapy The WC doctor sends a
report that Meredith is cleared to return to work but she
cannot lift more than 20 pounds and cannot stand more
than 20 minutes at a time. The company has a light
duty program where it will transfer Meredith to a desk
job until her restrictions are lifted Meredith refuses the
light duty position and asks for two more weeks leave
Can you terminate Meredith?
o Is Meredith entitled to WC benefits?
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 74

cenario (cont )
After Meredith has exhausted her FMLA
leave, Meredith has a setback in physical
therapy and the doctor now indicates she
is unable to work at all and will require 4
more weeks leave
Do you have to give Meredith the leave?
Fox Rothschild LLP
Valpak 75

cenario (cont )
You havegranted Meredith the additional
4 weeks leave A few days before she is
scheduled to come back, Merediths'
doctor indicates that she cannot return to
work and will be reevaluated in 30 days '
Now can you terminate Meredith?
Fox Rothschild LLP
Valpak 76

cenario (cont )
After Meredith has been out of work for a total
work
of 22 weeks she is still unable to come back to
She is still receiving WC benefits
,
You
decide to terminate Meredith as you can no
longer accommodate her. The day after you
terminate Meredith
files a grievance and demands that Meredith
, her union representative
be placed back at work because the company
is obligated to give her leave while she
receives benefits
Is the union right?
Understanding the Interplay between the ADA ,FMLA
0 2012 Fox Rothschild
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 77

Contact Information
973-994-7551
cstoneburner • foxrothschild.com
Fox Rothschild LLP
ATTORNEYS AT LAW
Valpak 78

Rl1 #1022709-v1-marsh interplay

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