Essentials of Human Resources for School Leaders November 30 2016 By Barbara A Ruga and Kara T Rozin Complexity of School HR Public schools are a highly regulated employer Same laws as private sector employers ID: 578436
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MASPAEssentials of Human Resourcesfor School LeadersNovember 30, 2016ByBarbara A. Ruga and Kara T. RozinSlide2
Complexity of School HRPublic schools are a highly regulated employerSame laws as private sector employersNon-discrimination and anti-harassment, FLSA, FMLA, etc.ERKA, Payment of Wage and Fringe Benefits ActAffordable Care Act (but maybe not for long?)Same laws as other Michigan public sector employersPERA, PFHICA, OMA, FOIA , Right To Work
Special laws applicable only to school employers
PERA’s
prohibition against dues deductionsspecial penalties in event of unlawful strikeMichigan Revised School CodeSections 1248 and 1249Michigan Teachers’ Tenure Act 2011 Public Act 54Multiple bargaining units and non-union and/or “meet and confer” groups
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Not For the Faint of HeartStaying CurrentContract changes, individualand collectiveLawsRegulationsPending legislationManaging RelationshipsParents and StudentsSuperintendent and BoardUnions and EmployeesYour departmentLegal CounselIndustry GroupsVendors of contracted services
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Keeping Up With Timelines
Hiring
Start of School
Statutory Timelines affecting evaluations, non-renewals
Managing transportation personnel
Responding to
FOIA
requests
Graduation and other year end activities
And You Work In a Fishbowl!with your employer changing with local electionSlide4
Our Agenda Potpourri of Hot Issues and Best PracticesHiring to Firing4
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The Hiring ProcessDo you ask the right questions?ever been allowed to resign in lieu of dischargeever resign before investigation completedhad your contract non-renewedtenure charges filed and then withdrawnreasons for frequent job changeslisten for code responses from prior supervisorask whether you should make a FOIA requestask whether there is a resignation agreementMake a FOIA request to one or more prior employers.5
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Need for Job AccommodationsUpdate job descriptionsInclude requirement of regular and consistent attendance as an essential functionInclude any physical movement requirements in addition to lifting Include need for physical restraint of students as neededAsk for demonstration of essential functionsPresent hypothetical scenariosAsk if can perform essential functions with or without accommodationAsk if ever disciplined for poor attendance or abuse of leaveAsk total number of days absent, not number of sick daysCannot ask about number of children but may ask if there is any reason cannot consistently be punctual and regularly attend work per the District’s established work scheduleSocial media search?Pros and Cons6
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Governing EEOC Laws – ADA Three main rules under the ADA:An employer may not ask questions about disability or require medical examinations until after it makes a conditional job offer to the applicant.After making a job offer (but before the person starts working), an employer may ask disability-related questions and conduct medical examinations as long as it does so for all individuals entering the same job category.With respect to employees, an employer may ask questions about disability or require medical examinations only if doing so is
job-related and consistent with business
necessity
.An employer can ask whether an applicant can perform a job function Example: Can you lift 25 lbs?
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Recent Cases After several bad hires, ABC District pays for an expensive applicant testing program which it requires all applicants for its Data Analyst position take. After one year, 300 applicants take the test. Of the 300, 150 are over the age of 40, and 150 are under the age of 40. Based in part on those tests, jobs offers were made to 50 employees; 5 from the 40 and over group, and 45 from the 40 and under group. Does ABC District have any liability? No, because ABC issued the test to all applicants for the same position. No, because there is no evidence that the test was discriminatory. Yes, because the test had a disparate impact on applicants over 40.
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Legal Background Title VII, the Americans with Disabilities Act, and the Age Discrimination in Employment Act prohibit the use of discriminatory employment tests and selection procedures.There has been an increase in employment testing due in part to post 9-11 security concerns as well as concerns about workplace violence, safety, and liability. In addition, the large-scale adoption of online job applications has motivated employers to seek efficient ways to screen large numbers of online applicants in a non-subjective way.
The number of discrimination charges raising issues of employment testing, and exclusions based on criminal background checks, credit reports, and other selection procedures continues to
increase
.
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Recent Cases September 26, 2016: The U.S. Department of Labor filed a lawsuit charging that Palantir Technologies, a Palo Alto technology company, discriminated systematically against Asian job applicants in its hiring process and selection procedures.August 24, 2015: Target Corporation paid $2.8 Million to resolve EEOC discrimination finding. The EEOC found Target used three employment assessments that disproportionately screened out applicants for exempt-level professional positions based on race and sex.
One of Target's pre-employment assessments violated the ADA.
Target committed record-keeping violations by failing to maintain records sufficient to assess the impact of its hiring procedures.
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“Ban the Box” Legislation: What Employers Need to KnowEmployers in most Ban-the-Box states must consider a job candidate’s qualifications first before conducting a targeted screening process and an individualized assessment of the candidate’s criminal history.Even if an employer is not in a Ban-the-Box state (e.g., Michigan employers), it is still subject to Title VII of the Civil Rights Act of 1964 and state discrimination laws (e.g., Michigan Elliott-Larsen Civil Rights Act).What does this mean? Even though individuals with a criminal record are not part of a protected class, an applicant can still claim illegal discrimination based upon a policy’s disparate impact (i.e., neutral policy that disproportionately impacts based on a protected category).
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Employers should: Avoid stigmatizing application language such as “ex-offenders” or “ex-felons.” Avoid blanket exclusions and instead include an equal opportunity statement on applications – It is beneficial to indicate that a record will not automatically disqualify a job candidate, unless there is a specific legal exclusion.Ensure that any rejection is based on legitimate and relevant results.If an applicant is rejected because of a criminal record, provide the applicant with written notice and, due to discrepancies in reporting, offer the applicant the chance to verify or challenge the information.
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Employer Best PracticesSlide13
Documentation At HireCPI Training of Support StaffDocument receipt of handbooks, rulesDistrict expectationsResponsibility for reading Board PoliciesRules for recording time workedSchool Policy BooksReporting absencesDepartment Rules and ProceduresOptions About Union Membership and Dues13
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Training Checklist
Anti-harassment
Non-discrimination
Grievance procedures
Identity of Civil Rights Compliance Officer(s) &
Title IX Coordinator(s)
Note: need to repeat throughout the year and communicate in different ways
May 2016
EEOC
Task Force ReportSlide14
Right To Work IssuesUnion role during orientation of new hiresWhen is representative requiredWeingarten: at request of employee, during an investigatory interview that could lead to disciplineas required by collective bargaining agreement; applies to non-membersevaluations are not disciplinary, however, meeting informing of dismissal should include union representativeNo employer obligation to inform of right to representative, unless required by contractPROHIBITED SUBJECT (Ionia Public Schools, Feb 2016), as to teachersOption to remove or retain or modify contract language , as to teachers
Practical options
Arrange for representative to be there
Begin investigatory interview and ask employee if want representativeConduct investigatory interview without mentioning right to rep unless employee asksTrain supervisors and department headsRequire union representatives to follow contract language on right to meet with employees during work time; prior notice, etc.14
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Related Right To Work IssuesDemands for detailed bargaining unit employee informationIf already covered in CBA, perhaps can limit scope of response to what has been negotiatedGrant request; grant it in part, deny it in partInform bargaining unit employees of request and seek consent to disclose personal home, telephone, email, other contact informationObject to request; offer to negotiate with designated bargaining representativeMeetings with Bargaining Unit EmployeesTo Share Information – may not want to delegate to unionCaution: Union only has to invite members to its meetingsOnly members in good standing may vote at contract ratificationUnion Obligated to represent B.U.E. if contract issueBut discipline is a prohibited subjectAdvise about contract enforcement or file grievance
Not obligated to represent in tenure case or other litigation
N
ot obligated to meet with employee’s lawyer or family members15
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Union Representative’s RightsIn City of Saline, MERC Case No. C14 B-021 (January 19, 2016), MERC answered under what circumstances an employer may deny a union representative from participating in an investigatory interview.Saline’s Police Department was interviewing the sergeant as part of an investigation into allegations the sergeant was having sex with a lower-ranked Department employee who he supervised.At the beginning of the interview the Chief advised union rep that he was to act as an observer not a participant.
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No Weingarten ViolationMERC held the Department did not violate the sergeant’s Weingarten rights.MERC relied on City of Oak Park, 1995 MERC Lab Op 576, which held an employer has the right during the interview to have its questions answered by the interviewee without interruption by the representative.
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CautionsHowever, City of Saline may be limited by its facts:The union representative and employee were given a list of charges prior to the interview.The union representative was given an opportunity to ask questions at the end of the interview and make a statement to the employer.Best Practice is to advise union representative that he or she cannot answer for the
employee:
Union representative should be allowed to ask clarifying
questions.Union representative and employee should be allowed a private caucus upon request.
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HOT TOPICSDURING EMPLOYMENT RELATIONSHIPSlide20
RetaliationWhich are forms of “protected” complaints/activityA teacher makes a complaint about graffiti in the bathroom that includes a derogatory term toward women. The teacher does not allege a hostile work environment or sex discrimination. A bus driver is interviewed as part of another bus driver’s racial harassment complaint. The interviewed bus driver provides a statement which corroborates the complaining bus driver’s allegations.A female administrator complains that she was passed over for a promotion in favor of a male administrator because of her sex. The district had a legitimate business reason for selecting the male administrator for the promotion. AllAll except (C)
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EEOC Guidance on RetaliationNew Guidance and Q & A issued August 2016 A retaliation claim challenging action taken because of EEO-related activity has three elementsProtected activity: "participation" in an EEO process or "opposition" to discriminationMaterially adverse action taken by the employer
R
equisite
level of causal connection between the protected activity and the materially adverse actionEEOC interprets “opposition” as having an “expansive definition” “Adverse action”
now includes any activity that could be reasonably likely to deter protected activity even if it has no tangible
impact Casual connection can be established by “but for” causation.
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Retaliation – Best Practices Adopt written retaliation policies that prohibit retaliation and provide for reporting of employee concerns about retaliation.Train supervisors and employees on your policy and instruct them how to ensure that discipline and performance evaluations of employees are motivated by legitimate, non-retaliatory reasons.Inform employees of your zero-tolerance policy when
responding to an employee's allegations of underlying
EEO
violations. Assign a designated individual, such as an HR representative or in-house counsel, to review proposed employment decisions to ensure they are based on legitimate non-discriminatory, non-retaliatory reasons.
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Retaliation – Best Practices Do not ignore complaints.Investigate complaints – considering scope, investigators, timeliness.Remember, sloppy administration negatively affects credibility.Isolate decision makers, if possible.Make certain work records and performance evaluations
are
conducted on time and contain current, factual
information.Be consistent in the application of policies and the imposition of discipline.Discipline is retaliatory only if it is taken because the employee
complained.
Periodically monitor the treatment of employees that have engaged in protected activity.
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Image / Religious AccommodationFatima is Muslim and wears a headscarf in accordance with her religious beliefs. She applies for a central office position at the District. Based on the District’s dress code policy, the District does not allow any headgear. Fatima never tells the District she wears the scarf because of her beliefs and never asks for an accommodation. The District believes Fatima wears her headscarf for religious reasons, but does not hire her because it does not want to make any exceptions to its dress code policy.
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Was the District Wrong in Failing to Hire Fatima?No. The District did not know for certain if Fatima wore her headscarf for religious reasons and Fatima did not ask for an accommodation. Yes. The District was obligated to ask Fatima about her headscarf because she wore it at the interview.Yes
. Once the District suspected Fatima wore her headscarf for religious reasons, it was required to make an exception for her as a religious accommodation in the absence of undue hardship.
Yes
, because of (B) and (C) above.
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Religious Discrimination Title VII prohibits employers from discriminating against applicants and employees because of their religion (or lack of religious belief) in hiring, firing, or any other terms and conditions of employment.Imposes a duty to reasonably accommodate the religious beliefs and practices of applicants and employees, unless doing so would cause more than a minimal burden on the operation of the employer's business.Religious accommodations can include
Adjustments
to the work environment that will allow the employee to practice his religion. Flexible scheduling, voluntary shift substitutions or swaps, job reassignments
lateral transfers, and exceptions to dress or grooming rules are examples of accommodating an employee's religious beliefs.
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Pregnancy / Light DutyPeggy is a maintenance employee for the District. The District requires maintenance employees to lift, push, pull, and otherwise manipulate items weighing up to 50 lbs. Peggy became pregnant and her doctor imposed lifting restrictions. Peggy could not lift more than 20 lbs. during the first 20 weeks of her pregnancy or more than 10 lbs. for the balance of her pregnancy. In the CBA, the District’s light duty policy reflects it will accommodate the following employees with light duty: (1) employees injured on the job; and (2) those with a disability under the ADA. Peggy was told she could not return to work because she could not satisfy the lifting requirement and did not qualify for light duty. When she asked the District to accommodate her disability, she was told she was “too much of a liability’” and could not return until she was no longer pregnant.
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Was the District Required to Offer Peggy Light Duty Work?No, Peggy’s lifting restrictions were temporary and not a disability under the ADA.No, the District had a neutral light duty policy which did not extend to pregnant employees.No, because of (A) and (B) above.
Yes
, if Peggy can show the District accommodates most non-pregnant employees while failing to accommodate pregnant employees, significantly burdening pregnant workers.
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Pregnancy Discrimination Pregnancy discrimination involves treating a woman (an applicant or employee) unfavorably because of pregnancy, childbirth, or a medical condition related to pregnancy or childbirth.The Pregnancy Discrimination Act (PDA) of 1978 amended Title VII to make employment discrimination on the basis of pregnancy, childbirth or related medical conditions constitute sex discrimination under Title VII.Practical Implication: (PDA) forbids discrimination based on pregnancy when it comes to any aspect of employment, including hiring, firing, pay, job assignments, promotions, layoff, training, fringe benefits, such as leave and health insurance, and any other term or condition of
employment.
State
Level protections are also in place regarding pregnancy discrimination.
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Pregnancy Discrimination Young v. UPS Pregnant delivery person Policy provided light duty to worker’s comp, ADA, and DOT suspensions Held: Should have allowed her light duty unless significant burden June 2015: Enforcement Guidance on Pregnancy Discrimination and Related Issues Highlights
Cannot discriminate
Cannot subject to increased scrutiny and harsher discipline
Cannot force person to take leave Protected status includes was pregnant / might get pregnant / fertility treatments / abortion
Lactation / breast feeding
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Pregnancy Accommodations Belle, your full-time payroll clerk of the past five years, is pregnant. She has had some complications and is temporarily suffering from gestational diabetes because of her pregnancy. One of the symptoms of gestational diabetes is nausea and vomiting. Belle has been late for work three times because of these symptoms. Belle told her supervisor about her condition, and asked if she could work from home on the days she becomes sick. While inconvenient, most of Belle’s work could be performed at home. Belle’s supervisor believes Belle is using her pregnancy as an excuse to come in late and get out of work. As a result, he refuses to allow her to work from home and writes her up every time she is late and uses gestational diabetes as her excuse.When the HR Director reviews Belle’s file during her annual review, she is terminated for violating District policy regarding excessive tardiness. The HR Director is aware that the District has terminated other employees for similar issues.
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Did the District Violate the FMLAand/or ADA?No, because the ultimate decision to terminate Belle came from the HR Director, who properly based the decision on information in Belle’s personnel file which was unrelated to any disability.Yes, because the supervisor failed to accommodate Belle and wrote her up for being tardy.
No
, because Belle’s requested accommodation was unreasonable.
Yes, because the complications from her pregnancy qualify as a serious health condition under the
FMLA.
Both (B) & (D).
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Sub Shortage/AbsenteeismMulti-Faceted ApproachHow You Compensate Subscompetitive pay creative expansion of sub poolsretirees; 30 day rule once tenured, tenure re-attaches because cannot require any tenured employee to serve more than one probationary period in same districtperks for subs based on number of days subbingtell employees what you are doing to find and retain subsHow Your Staff Treats Subsviable sub plans, e.g.33
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Do We Want Employees To Work?Reduce opportunities for employees not to workSchool business – negotiate after school or summer PDNegotiate and enforce restrictions on use of personal daysreasonnumberwhen takenNegotiate and enforce narrowed use of sick daysearn sick days, versus available at beginning of yearnot to be used for routine appointments that can be scheduled outside the work dayLimit accumulation of unused sick days to LTD waiting periodBuy back accumulated sick days on a current basis?Tighten if not eliminate sick banks/buy short term disability insteadwaiting periods before sick bank kicks inreimburse bank for days used# sick days grows with years of service
limit use to employee
“serious
health condition”restricted number used for illness of immediate family, narrowly definedToo many days allowed each year?Cautious re PTO time34
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Other Contract IssuesRight to verify use of days.No, or very limited, approved “dock days;” if absent and unpaid, not approved unless ADA , FMLA or religious observance.No more than one year medical leave mandated by contract; if longer, must submit evidence that there is a reasonable likelihood the employee will return to work.No right to grieve when employer discretion determines additional leave days.Negotiated attendance incentive bonuses (excluding performance-based compensation for teachers which is a prohibited subject).35
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Special Tools – Teacher AttendanceTeacher evaluation Section 1248 criteria requires assessment of teacher attendanceresearch-based correlation with student achievementuse contract maximum as standard?use other standard, such as historical bargaining unit averagepermit a three year average to minimize adverse impact of anomaly, or exception in the event of an aberrant yearPerformance-based compensationStudent growth plus teacher
attendance
Section 1250
MRSC36
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Outside the Box?Employee recognition on a weekly or monthly basis to those who have perfect attendance?Board recognition?Monthly report to Board on absenteeism rates (i.e., use of days) and impact on cost of substitutes?37
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Suspected Impairment or Disabled EmployeesEmployees are treated differently from students when it comes to the impact of an employee’s disability on consequences for employee misconduct.Disabled students – disability may excuse misconduct if misconduct is a manifestation of the disability and may disallow or dilute disciplinary action.Disabled employees – disability does not excuse misconduct or interfere with employer’s right to discipline; employer has right to maintain its performance and conduct standards, subject to an obligation to accommodate. Make sure you inform employees of right to request accommodation.Train supervisors to refer these requests to HR or Central Office.
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Handling Requests for AccommodationCase-by-case determination based on presenting facts.If not able to grant request, engage in interactive dialogueWhat job functions cannot be performedWhat accommodations could help employee perform those functionsConsider a range of accommodationsDo not grant if causes undue hardship or may not be effective in helping employee to perform the job functions at an effective levelNo obligation to modify or eliminate essential functionsIf not able to perform the job, may reassign.If unable to perform job, may terminate employment.If teacher, placement on unrequested unpaid leave of absence per Tenure Act.File tenure charges based on inability to withstand the strains of teaching.39
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Common Implementation IssuesSupervisors who inquire if employee is sick or on medication, instead of responding to the performance or conduct issue.Seeking medical opinion on employee fitness rather than address employee performance or conduct issue.Handling employees suspected of at-work impairment.Interplay with FMLA.Job abandonment.40
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ADA & Leave Policies The District has a policy that provides for three months of leave in addition to FMLA leave. Following exhaustion of the three months, the employee is expected to return to work with no restrictions and a note from his/her physician notarizing such. The District has applied its “no restrictions” policy consistently in the past. Ariel, the District’s Payroll Clerk, was granted two months of medical leave for a disability. Prior to returning, she contacts Human Resources and requests an ergonomic chair, adjusted lighting in her office, and a part-time schedule for the next eight days. In response, the District politely informs her of its “no restrictions” policy and requires her to remain on leave until she is able to work full-time with no restrictions or accommodations.
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Did the District Violate the Law? No, because it has a consistent policy that it applies to all leaves.No, because it allows for an additional three months of leave.Yes, unless it can prove that her accommodation requests cause an undue hardship on the facility.Yes, because Ariel has a disability she has a right to her requested accommodations.
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ADA & Leave Policies According to the EEOC, an employer violates the ADA if it requires an employee with a disability to have no medical restrictions – i.e. "100%" healed or recovered - if the employee can perform her job with or without reasonable accommodation unless the employer can show providing the needed accommodations would cause an undue hardshipSimilarly, an employer violates the ADA if it claims an employee with medical restrictions poses a safety risk but it cannot show that the individual is a "direct threat." Direct threat is the ADA standard for determining whether an employee's disability poses a "significant risk of substantial harm" to self or to others. If an employee's disability poses a direct threat, an employer must consider whether reasonable accommodation will eliminate or diminish the direct threat.
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ADA & Leave Policies Lowe’s maintained a “no fault” leave policy which provided employees 180 days of leave (later changed to 240 days). After the 180 days, the employee was terminated. The policy failed to provide any exceptions. The EEOC filed a lawsuit claiming that the policy and Lowe’s treatment of its employees violated the ADA by failing to consider extended leave as an accommodation for disabled employees.According to the EEOC, the ADA requires that employer consider requests for leave as an accommodation regardless of any neutrally applied policy.On May 13, 2016, Lowe’s agreed to amend its maximum leave policy and pay $8.3 million to resolve the EEOC’s lawsuit.
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TERMINATIONMissed OpportunitiesSlide46
Missed Opportunities: Anticipate & CureI did not do itI did not know it was wrongThe discipline is too harshYou did not follow contract proceduresYou did not give me due processNo union repYou treated me differently than othersYou led me to believe it was okayDiscrimination!You just don’t like me!Rule unreasonable/no right to adopt rule
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Missed OpportunitiesTerminating probationary teachers for misconduct versus non-renewals for evaluative reasonsCross v Grosse Pointe Schools: the Tenure Act’s provisions providing school employers the right to terminate a probationary teacher at any time is not applicable to contract non-renewal for deficits in instructional practice.Nonetheless, a probationary teacher may engage in conduct reasons for termination during the year, which may lead to prompt dismissal under the Act.Grievance HandlingUse grievance meetings to determine basis for grievance.Discuss grievant’s arguments/defenses/witnesses/documentary support for grievance.If a just cause dismissal, ask which of 7 part just cause test was not met in the grievant’s opinion.If grievance about a prohibited subject, file an unfair labor practice.
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Missed Opportunities: DocumentationNotes in file are not that helpful!Confirm conversation with employee or other person.Use text; use email.Call your attorneys – we “ghost write” communications to your employees – help you articulate your rationale.Clarify District expectations via handbooks at district and school levels.Maintain up to date administrative regulations and guidelinesDon’t be over inclusive in such documents – e.g., there is no legal protection of employees against bullying, but employees are protected from harassment and discrimination based on protected legal categories.LAYOFF GUIDELINES FOR TEACHERS48
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Missed Opportunities: Red FlagsPrior conflict with supervisor recommending dismissalSupervisor recommending layoff prior to recommending dismissalPrior grievance or EEO charge against supervisor recommending dismissalWage and hour issues involving employee being recommended for dismissalHigh level of turnover in supervisor’s areaNot holding supervisors accountable for poor personnel decisions or missed timelines or evaluation steps49
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Missed Opportunities: Due ProcessDo give at least one opportunity to respond or explainDo give more than one opportunity if facts evolve or new facts emergeDo allow union representation where appropriateDo allow attorney if criminal charges pending or likely and no union repDo insist employee answer your questionsDo interview witnesses suggested by accused unless duplicativeDo not allow union representation as a matter of course for evaluations or witness interviewsDo not allow attorneys or family members to be present in addition to or in lieu of union representatives, as a matter of courseDo not be surprised at arbitration because you did not ask questions during the grievance processDo not ignore circumstantial evidence, if probative, it is legitimate evidence to considerDo not impose a higher burden of proof than preponderance of the evidence50
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Upcoming DeadlinesTeacher EvaluationsIdentify probationary teachers by tenure track, 2 or 5 yearsare there any probationary teachers on track for non-renewal?Identify tenured teachers by ratingwho is on IDPwho had three consecutive years of HE ratings and is on biennialwho had two consecutive years of E or HE ratings and only needs one observationAll IDPs should be in place; most important part is PD and instructional supportAt least one observation should be doneGet ready to conduct MYPRAdministrator Evaluations
Determine whether you have any administrators poised for contract non-renewals – February or March
Time limits in section 1229 measured from date of contract expiration
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Miscellaneous Observations Date StampsOMA closed session Not available for any “personnel matter”Must be specific reason identified within section 8(a) of the OMAFOIA requests for personnel filesDiscipline more than four years oldNotice to employee before disciplinary records disclosed52
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TakeawaysWhat will next four years bring?More or different complexity?Need for more supervisor training to build capacity on complexity of HR.Review and update handbooks and policies. Take strategic advantage of existing flexibility to enhance management rights.Maintain philosophy of due process and doing the right thing based on facts.Keep coming to MASPA!53
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Questions?©2016 Clark Hill PLC
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The content of this presentation is copyrighted by Clark Hill PLC.As with all legal issues, this presentation provides general principles only, and your attorney should be consulted for specific questions related to any and all principles contained herein, as applied to your individual situation(s).School law issues are complex and fact specific; when in doubt, consult with legal counsel.55
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Thank You!56Barbara A. Rugabruga@clarkhill.com(616) 608-1105205211231.3
©2016 Clark Hill PLC
Kara T. Rozin
krozin@clarkhill.com
(616) 608-1110