fmla intermittent leave: preventing abuse while mitigating...

FMLA Intermittent Leave: Preventing Abuse

While Mitigating Interference or Retaliation ClaimsCreating Effective Leave and Transfer Policies, Challenging Medical Certification,

Leveraging Defense Theories

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TUESDAY, MAY 12, 2020

Presenting a live 90-minute webinar with interactive Q&A

Angelo M. Filippi, Partner, Kelley Kronenberg, Ft. Lauderdale, Fla.

Ryan T. Neumeyer, Member, McDonald Hopkins, Cleveland

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754-200-7968HARSH ARORA ESQ. – PARTNERAngelo M. Filippi - Partner 754-200-7968

TUESDAY, MAY 12, 20201 PM EASTERNANGELO M. FIL IPPI , ESQ.

FMLA Intermittent Leave: Preventing Abuse While Mitigating Interference or Retaliation

ClaimsCreating Effective Leave and Transfer Policies, Challenging

Medical Certification, Leveraging Defense Theories

HARSH ARORA ESQ. – PARTNER 754-200-7968HARSH ARORA ESQ. – PARTNER 754-200-7968Angelo M. Filippi - Partner 754-200-7968

Employer Coverage - § 825.104

• Private sector employers with 50 or moreemployees

• Public Agencies

• Public and private elementary and secondaryschools

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Employee Eligibility - § 825.110

• Employed by covered employer

• Worked at least 12 months

• Have at least 1,250 hours of service during the 12 months before leave begins

• Employed at a work site with 50 employees within 75 miles

7


Qualifying Leave Reasons - §825.112

Eligible employees may take FMLA leave:• For the birth or placement of a child for adoption or foster care

• To care for a spouse, son, daughter, or parent with a serious health condition

• For their own serious health condition

• Military Family Leave

◦ Because of a qualifying reason arising out of the covered active dutystatus of a military member who is the employee’s spouse, son,daughter, or parent (qualifying exigency leave)

◦ To care for a covered service member with a serious injury or illnesswhen the employee is the spouse, son, daughter, parent, or next of kinof the covered service member (military caregiver leave)z

8


Qualifying Family Members - §825.122

• Parent - A biological, adoptive, step or foster father ormother, or someone who stood in loco parentis to theemployee when the employee was a son or daughter. Parentfor FMLA purposes does not include in-laws.

• Spouse - A husband or wife as defined or recognized in thestate where the employee was married and includesindividuals in a same-sex marriage or common law marriage.

• Son or Daughter - For leave other than military family leave, abiological, adopted, or foster child, a stepchild, a legal ward,or a child of a person standing in loco parentis who is eitherunder 18 years of age, or 18 or older and incapable of self-care because of a mental or physical disability.

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Qualifying Leave Reasons –For the Birth or Placement of a Child - § 825.120-121

• Both the mother and father are entitled to FMLA leave for thebirth or placement of the child and/or to be with the healthychild after the birth or placement (bonding time)

• Employees may take FMLA leave before the actual birth, placement or adoption

• Leave must be completed by the end of the 12-month periodbeginning on the date of the birth or placement

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Qualifying Leave Reasons –Serious Health Condition - § 825.113

Illness, injury, impairment or physical or mental condition involving:

• Inpatient Care, or

• Continuing Treatment by a Health Care Provider

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Serious Health Condition –Inpatient Care § 825.114

• An overnight stay in a hospital, hospice, or residential medical facility

• Includes any related incapacity or subsequent treatment

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Serious Health Condition –Continuing Treatment § 825.115

Continuing Treatment by a Health Care Provider• Incapacity Plus Treatment

• Pregnancy

• Chronic Conditions

• Permanent/Long-term Conditions

• Absence to Receive Multiple Treatments

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Continuing Treatment by a Health Care Provider § 825.115

Incapacity Plus Treatment:• Incapacity of more than three consecutive, full calendar days that involves either:

◦ Treatment two times by HCP (first in-person visit within seven days, both visits within 30 days of first day of incapacity)

◦ Treatment one time by HCP (in-person visit within seven days of first day of incapacity), followed by a regimen of continuing treatment (e.g., prescription medication)

◦ Pregnancy Incapacity due to pregnancy or prenatal care

14


Continuing Treatment by a Health Care Provider § 825.115

Chronic Conditions:• Any period of incapacity or treatment due to a chronic serious health condition,

which is defined as a condition that:

◦ requires periodic visits (twice per year) to a health care provider for treatment

◦ continues over an extended period of time

◦ may cause episodic rather than continuing periods of incapacity

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Amount of Leave§ 825.200, 825.205 & 825.802

• Employee’s workweek is basis for entitlement

• Eligible employees may take up to 12 workweeks* of FMLA leave:

◦ for the birth or placement of a child for adoption or foster care;

◦ to care for a spouse, son, daughter, or parent with a serious health condition; and

◦ for the employee’s own serious health condition.

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Amount of LeaveIntermittent Leave § 825.202

• Employee is entitled to take intermittent or reduced schedule leave for:

◦ Employee’s or qualifying family member’s serious health condition when the leave is medically necessary

◦ Covered service member’s serious injury or illness when the leave is medically necessary

◦ A qualifying exigency arising out of a military member’s covered active duty status

• Leave to bond with a child after the birth or placement must be taken as a continuous block of leave unless the employer agrees to allow intermittent or reduced schedule leave

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12-Month Period - § 825.200

• Method determined by employer

• Calendar year

• Any fixed 12-month leave year

• A 12-month period measured forward

• A rolling 12-month period measured backward

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Substitution of Paid Leave - §825.207

• “Substitution” means paid leave provided by the employer runs concurrently with unpaid FMLA leave and normal terms and conditions of paid leave policy apply

• Employees may choose, or employers may require, the substitution of accrued paid leave for unpaid FMLA leave

• Employee remains entitled to unpaid FMLA if procedural requirements for employer’s paid leave are not met

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Employer Responsibilities –Provide General Notice § 825.300

• Employers must inform employees of FMLA:

◦ Post a General Notice, and

◦ Provide General Notice in employee handbook or, if no handbook, distribute to new employees upon hire

• Electronic posting and distribution permitted

• Languages other than English required where significant portion of workforce not literate in English

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Employer Responsibilities –Provide Notice of Eligibility § 825.300

• Within five business days of leave request (or knowledge that leave may be FMLA-qualifying)

• Eligibility determined on first instance of leave for qualifying reason in applicable 12-month leave year

• New notice for subsequent qualifying reason if eligibility status changes

• Provide a reason if employee is not eligible

• May be oral or in writing (optional WH-381)

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Employer Responsibilities –Provide Notice of Rights and Responsibilities § 825.300

• Provided when eligibility notice required

• Must be in writing (optional WH-381)

• Notice must include:

o Statement that leave may be counted as FMLA

o Applicable 12-month period for entitlement

o Certification requirements

o Substitution requirements

o Arrangements for premium payments (and potential employee

o Job restoration and maintenance of benefits rights

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Employer Responsibilities –Provide Notice of Designation§ 825.300• Within five business days of having enough

information to determine leave is FMLA-qualifying

• Once for each FMLA-qualifying reason per applicable 12-month period (additional notice if any changes in notice information)

• Include designation determination; substitution of paid leave; fitness for duty requirements

• Must be in writing (optional WH-382)

• If leave is determined not to be FMLA-qualifying, notice may be a simple written statement 23


Employer Responsibilities –Provide Notice of Designation §825.300 - .301

• Employer must notify employee of the amount of leave counted against entitlement, if known; may be payroll notation

• If amount of leave is unknown (e.g., unforeseeable leave), employer must inform employee of amount of leave designated upon request (no more often than 30 days)

• Retroactive designation permitted provided that failure to timely designate does not cause harm to employee

24


Employee Responsibilities –Provide Certification § 825.305

• Medical Certification for serious health condition (optional WH-380-E and 380-F)

o Submit within fifteen calendar days

o Employer must identify any deficiency in writing and provide seven days to cure

o Annual certification may be required

o Employee responsible for any cost

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Employee Responsibilities –Provide Certification § 825.307

• Employer (not employee’s direct supervisor) may contact health care provider to:

◦ Authenticate: Verify that the information was completed and/or authorized by the health care provider; no additional information may be requested

◦ Clarify: Understand handwriting or meaning of a response; no additional information may be requested beyond what is required by the certification form

• Second and third opinions (at employer’s cost)

◦ If employer questions the validity of the complete certification, the employer may require a second opinion

◦ If the first and second opinions differ, employer may require a third opinion that is final and binding

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Employee Responsibilities –Provide Certification § 825.308 & .313

Recertification

• No more often than every 30 days and with an absence

o If the minimum duration on the certification is greater than 30 days, the employer must wait until the minimum duration expires

o In all cases, may request every six months with an absence

• More frequently than every 30 days if:

o the employee requests an extension of leave, or

o circumstances of the certification change significantly, or

o employer receives information that casts doubt on the reason for leave

Consequences of failing to provide certification

o Employer may deny FMLA until certification is received

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Employee Responsibilities –Provide Periodic Status Reports § 825.311

•Employee must respond to employer’s request for information about status and intent to return to work

28


Employee Responsibilities –Fitness-for-Duty Certification § 825.312

• For an employee’s own serious health condition, employers may require certification that the employee is able to resume work

o Employer must have a uniformly-applied policy or practice of requiring fitness-for-duty certification for all similarly-situated employees

• Not permitted for intermittent or reduced schedule leave unless reasonable safety concerns exist

• Employee responsible for any cost

29


FMLA Enforcement Mechanisms §825.400

• To enforce FMLA rights, employees may:

o File a complaint with Wage and Hour Division

o File a private lawsuit (Section 107(a))

• Action must be taken within two years after the last action which the employee contends was in violation of the Act, or three years if the violation was willful

30

Paid Sick Leave

Consider leave options under the FMLA and FFCRA, Emergency Paid Sick Leave (EPSL) or Emergency Family and Medical Leave Act (EFMLA), which remains

available through 12/31/20

EPSL

Multiple reasons for EPSL remain available upon return to work

Note: Employer may not require employee to use PTO first

EFMLA

EFMLA for child care remains available upon return to work – and usage may increase

Note: FFCRA regs provide that only available for one caregiver at a time

“Classic” FMLA

Employees who have coronavirus or are caring for a family member

Note: Employer may require standard FMLA medical certification

If FMLA exhausted, EPSL may still be used – if available

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Unemployment, Coronavirus and FMLA

FMLA and Coronavirus and living with someone at risk

FMLA, Coronavirusand being at risk

Paid Sick Leave

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Paid Sick Leave

The challengePatchwork stateand local paid sickand family leavelaws

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The issue(s):• Numerous laws• Many separate requirements• Policy concerns• Consistency

Paid Sick Leave

34

Paid Sick Leave

Meeting the Challenge• Analyze each jurisdiction

• Have separate policies in each jurisdiction or maintain one policy for all by providing additional benefits in certain jurisdictions

• Research local laws

35

Paid Sick Leave

States with paid sick or family leave:• Arizona

• California

• Maryland

• Michigan

• Minnesota

• New Jersey

• New York

• Oregon

• Rhode Island

• Vermont

• Washington

• Washington DC36

• Disability Insurance – Reserve the right to make changes to the plans at any time (benefits,

coverage, carriers, employee contributions, premiums, co-payments, deductibles) or eliminate entirely

– Policy should state that the employer is not a guarantor of coverage or benefits provided

• Paid Time Off – Most states and locales, an employee is required to pay fringe benefits to

an employee in accordance with the terms of a written contract or policy (e.g., employee handbook)

– Should state whether PTO is paid upon voluntary/involuntary termination of employment

– Should clearly explain how PTO is calculated and accrued (e.g., rolls over?)– Should state employer may approve/disapprove time off based upon

business needs.

Paid Sick Leave

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Call-in

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Request information when employee calls-in• The employee must:

– Reference the qualifying reason or reference the need for “FMLA”

– Employees with FMLA-approved leave for multiple reasons/conditions, can be required to identify the specific reason/condition for which FMLA leave is being taken

– “I am sick” is not enough

Call-in

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Enforcing Call-in Requirements• An employee is required to comply with an employer’s

usual notice and procedural requirements for calling in absences and requesting leave, absent unusual circumstances. So:– If a call-in policy requires an employee to call in at least one

hour before the shift starts to report an absence and the employee fails to do so, the employer can discipline the employee

– But note, an employee who has been certified for continuous leave may generally not be required to call in daily

Call-in

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Multiple Caretakers• The employee does not need to be the only available caregiver

Visitation• Pure visitation does not constitute “caring for” sufficient to justify

FMLA. But, psychological care does justify FMLA. Tough line to

prove for employer

Vacationing with Sick Family Member • Is the employee providing care on the trip? “So long as the

employee provides ‘care’ to the family member, where the care

takes place has no bearing on whether the employee received

FMLA protection”

Tricky Questions

41

If your employee has sought FMLA leave for their child’s serious health condition and it is had been certified as such, the employee may take leave to attend the IEP meetings if such meetings are related to the serious health condition. According the DOL, an employer must offer FMLA when an employee requests FMLA leave or when the employer acquires knowledge that leave may be for a FMLA purpose. The employer must notify the employee of his or her eligibility to take leave, and inform the employee of his or her rights and responsibilities under FMLA.

Tricky Questions

42

Call-in

Track FMLA Used and Notify Employee of Usage

• Record all FMLA absences subtracting from the 12

weeks of FMLA the employee gets each year

• Employees should be told, in writing, whenever their

absences are being counted as FMLA

• Employees should be informed when FMLA is exhausted

• After the employee exhausts his or her 12 (or 26) weeks

of FMLA leave in the leave year, further absences are

treated as regular absences under the attendance

policy, subject to protection by the ADA and/or WC

laws. 43

Intermittent Leave Strategies

• Require employee to cure deficiencies. • Contact health-care provider if information looks

suspicious. • Request a second opinion when you encounter

conflicting information. • Re-certify if the leave exceeds frequency or duration. • Understand reason for FMLA when employee has

multiple approved FMLA.

44

Intermittent Leave Strategies

• Encourage employees to schedule treatments for medical conditions so as not to disrupt employer’s operations.

• Perfect attendance awards – such awards can be denied to employees who exercise FMLA leave (so long as other employees on non-FMLA leaves of absence also do not receive such bonuses).

• Temporary transfers – can transfer employees needing foreseeable FMLA leaves to alternate positions (pay and benefits must be the same, duties can differ). Can’t require light duty to avoid permitting employee to take FMLA leave

45

Investigations

Before we decide to terminate based on fraud:

• Conduct a thorough investigation (e.g., surveillance, talk

to co-workers),

• Review the medical documentation,

• In appropriate cases, have a medical expert review the

information; and

• Give the employee a chance to tell his/her side of the

story

46

Investigations

Before we decide to terminate based on fraud:

• Don’t Interfere or retaliate before you have the facts.

• Five W’s

• Investigate potential fraud, but don’t jump to

conclusions.

• Interview witnesses and the employee.

• Internet research is priceless. Facebook is very effective,

but don’t communicate with the employee.

• Surveillance in some cases.

47

Fraud

Surveillance – Factors to Consider

• Type of medical condition

• Length of absence

• Costs

• Use only in egregious cases of possible fraud

• Social networking sites

48

Fraud

Terminating an employee based on “honest belief

of fraud”• In general, employer can terminate based on honest belief

employee is committing fraud

• Tillman v. Ohio Bell (6th Cir. 2013): Plaintiff has been on

intermittent leave for back condition for several years. Employer

noticed most absences occurred on Fridays, Mondays, and days

surrounding holidays. Employer hired investigator who observed

the employee doing errands, working in his yard, bending, lifting

pieces of wood. Employer’s doctor watched video and concluded

the employee’s activities were inconsistent with his alleged FMLA

condition. Court upheld termination based on employer’s honest

belief the employee was able to work. 49

Fraud


of fraud”• Seeger v. Cincinnati Bell Telephone Co., LLC (6th Cir. 2012):

Employee on FMLA, unable to perform any work. Four co-workers

reported seeing the employee at Oktoberfest. Employer

terminated the employee for fraud. Court upheld the termination,

noting the “key inquiry” is whether the employer made a

“reasonably informed and considered decision . . . The

determinative question is not whether (the employee) actually

committed fraud, but whether (the employer) reasonably and

honestly believed that he did.”

50

Fraud


of fraud”• Hamm v. Nestle USA (N.D. III 2013): Employee requested floating

holiday, which was denied. Employee then requested FMLA to take

his father to the doctor. Employer investigated and found the

employee had not taken his father to the doctor. Co-workers

reported the employee had previously used FMLA days to play

golf, go to breakfast. Court upheld termination, determining

employer had honest belief there had been FMLA abuse.

51

• Courts have concluded that the employer's policy, where it considered all vacations taken by employees during periods of FMLA leave as improper, was not reasonable.

• An employer may not treat the fact that an employee went on vacation during FMLA leave, by itself, as being impermissible.

• A vacation may or may not be consistent with medical leave depending on whether the employee's conduct while on vacation is consistent with the basis for the medical leave.

• Only when an employer is in receipt of information regarding an employee's conduct while on vacation may it consider inconsistencies between such conduct and the claimed reason for leave when evaluating whether leave has been properly or improperly used.

• For these purposes, it is irrelevant whether the employee is recovering at home or on vacation and that the employee's recovery could take place in a warm climate as well as in a Cleveland winter.

• Just because someone can’t work due to a medical condition doesn’t mean they are unable to do anything else

Fraud

52


Statute of Limitations

• A civil complaint for a violation of the FMLA must be filed within two years of the “last event constituting the alleged violation,” or within three years if the violation is willful. 29 U.S.C. § 2617(c)(1)-(2).

• A violation is willful if the employer knew or showed reckless disregard for whether its conduct was prohibited by the law. Some states have shorter limitation periods for their state leave laws, and therefore counsel should check the applicable state statute.

53


Intangibles

• One of the first issues any attorney representing a party in FMLA litigation should consider is the jury appeal of the case.

• An employee who is fired or otherwise suffers an adverse action for taking medical leave or leave to care for a sick loved one can present an especially sympathetic case.

54


Potential Issues

• Common reasons for defense judgments include situations in which:

• (1) the employee was seeking the leave in reaction to impending discipline;

• (2) the employee had chronic attendance problems and seemingly used any excuseto avoid working; and/or

• (3) the employee (or his family member) did not actually have a serious healthcondition or give notice of same, and therefore the leave at issue did not qualify forFMLA protection.

• If the employer can document or otherwise prove any one of these points – especially that theemployee was a malingerer or outright fraud – the employer stands a great chance of obtainingsummary judgment or a defense verdict at trial.

55


Defendants

• Plaintiff must establish that he works at a worksite where the employer employs at least 50 employees within 75 miles. 29 U.S.C. § 2611(2)(B)(ii).

• When the count is close, the regulations and case law provide guidance for determining whether the employer is covered. Claims also may be brought against responsible individuals.

56


Reinstatement

• Potential Strategy – Would only recommend when risk is high. Employer can cap exposure by offering reinstatement. In most cases, employee is unable or unwilling to return to work for the employer. Thus, the offer of reinstatement not only caps wage loss damages, it can also undermine the employee’s claim of loss and/or a willingness to return to work. Employers should only make such an offer in good faith, and if it is willing to take the chance that the employee accepts the offer and returns to work.

• Employers should communicate that employee will not be retaliated against if he or she accepts the offer to return to work. Employee could argue that an offer of reinstatement is an admission of liability.

57


Serious Health Conditions

• Does the employee truly have a “serious health condition” thatqualifies for FMLA leave? Not all “conditions” that relate to physical ormental health qualify as serious health conditions.

• For example, in Stroder v. United Parcel Serv. Inc., 123 DLR A-3(M.D.N.C. June 10, 2010), the court held that a mother employee’srequest for FMLA leave to care for her son, who needed speech therapyand behavioral care, did not qualify as protected leave because herson’s condition did not constitute a serious health condition. Theemployee lacked evidence that the condition incapacitated her son,required continuing treatment by a health-care provider, ornecessitated absences during the employee’s work schedule.

58


Ragsdale (Interference Claims)

• In Ragsdale v. Wolverine World Wide, Inc., 535 U.S. 81, 88 (2002), an employee’s leave maystill count as FMLA-covered, even if the employer’s designation and notice is retroactive, ifthe employer’s lapse did not prejudice or harm the employee. Thus, a violation of theregulatory notice obligations is not actionable unless the employee can show that he hasbeen prejudiced by the violation.

59


Notice Issues

• Question whether the employee gave the employer sufficient notice of his need for FMLA.

• When the need for FMLA is foreseeable, the employee must provide the employer with at least 30days notice before the date the leave is to begin, or as soon as practicable if such notice is notfeasible. 29 C.F.R. § 825.302(a).

• The employee does not need to expressly assert rights under the FMLA, but must express the needfor leave because of a serious health condition. The critical question in determining whether anemployee has given notice is whether the employee, orally or in writing, gave the employersufficient information such that the employer was on notice that he is requesting time off for aserious health condition.

60


Certification Issues

• Did the employee cooperate with requests to provide a medical certification or othernecessary information to make a determination as to FMLA coverage.

61


Leave Policies

• Was the adverse employment action based, in whole or in part, onFMLA-protected absences? If so, then the Act likely has been violated.But using absences not connected to the FMLA serious health conditionto terminate will not result in liability. Thus, an employer can defeat aclaim if it can show that the same decision would have been made evenif the FMLA-protected absences were used, where such absences werenot counted to justify termination.

62


Layoffs

• FMLA regulations provide that theemployer has “the burden of proving thatan employee would have been laid offduring the FMLA leave period and,therefore, would not be entitled torestoration.” 29 C.F.R. § 825.216(a)(1).Despite this regulation, the circuit courtsare split on the issue of who bears theburden of proof. (there is a split in thecircuits as to whether the employer bearsthe burden of proof)

63


Wheels of Termination

• Disciplinary actions came first (even if termination comeslater).

• Obtain admission from the employee that pre-FMLAdisciplinary warnings existed which led to termination.

64


Comparators

• Treatment of comparators is commonly cited by both plaintiffs and defendants on the issue ofcausation and/or pretext. The plaintiff will seek out evidence of disparate treatment ofsimilarly situated persons, and/or discrimination against others who took sick leave or FMLAleave. The defense, in contrast, can often cite repeated approvals of FMLA leave for theplaintiff or other employees to disprove claims that it discriminates against employees whotake FMLA leave.

65


Other Claims

• Employees also may be able to bring state tort claims, such as intentional infliction ofemotional distress.

• Discrimination laws also may be applicable, including those that protect employees based ondisability, pregnancy, gender and family status.

• Finally, plaintiffs’ counsel should consider workers compensation claims, including potentialretaliation claims. The positions taken by the parties in such claims may contradict orundermine any position taken in the FMLA litigation.

66

HARSH ARORA ESQ. – PARTNER 754-200-7968HARSH ARORA ESQ. – PARTNER 754-200-7968HARSH ARORA ESQ. – PARTNER 754-200-7968Angelo M. Filippi - Partner 754-200-7968

THANK YOU FOR YOUR TIME

ANGELO FILIPPI

A F I L I P P I @ K EL L E Y K RON E N B ERG.CO M

RYAN NEUMEYER

R N EUM EYER @ M CDON ALDHOPK INS .COM67

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