HR That Works Blog

In the latest development in the continuing saga that is COBRA administration, late on Thursday, April 15th, Congress passed H.R. 4851, the Continuing Extension Act of 2010, and President Obama signed the measure into law later that same day.  The Extension Act extends the eligibility period for the COBRA continuation premium subsidy through May 31, 2010. The Act also includes extended election procedures for those employees who were involuntarily terminated during the window between March 31, 2010 and April 15, 2010, and requires plan administrators to send new notices.
 
As of the date of this writing, DOL had only published a statement from Assistant Secretary Phyllis Borzi about the extension and had updated the general COBRA premium fact sheet on its website. 
 
The good news is that this latest Extension Act really doesn’t seem to have changed anything drastically; we’re just dealing with a rehashed plot-line where you know the story: an extended deadline for the termination and loss of coverage dates, and notice requirements to make sure we get that word out to all qualified beneficiaries who may be eligible for the subsidy. (Do remember that we still have that change from the last law extending the subsidy where qualified beneficiaries may be eligible for the subsidy if they suffered a reduction in hours followed by an involuntary termination; this new Extension Act made no change to that wrinkle in subsidized COBRA, however.) 
 
While we know you all like to send out your COBRA notices very promptly – we regularly see them done concurrently with the termination – we recommend taking advantage of the actual notice time-periods in effect while we wait and see what the DOL provides in the way of new model notices. As you know, employers have 30 days to notify their plan administrator of an employee termination, and the plan administrator – even if it’s the employer – then has 14 days to send notice to qualified beneficiaries. Therefore, there really is no current rush to send out notices for post-March 31 terminations. 
 
We recommend that you closely track all of your terminations that occur following March 31, 2010 and administratively prepare yourself to rapidly send out notices once we (hopefully) receive guidance from DOL. If you have a third-party administrator, while there may not be an obvious reason not to go ahead and provide notice of the qualifying event to your administrator, doing so would require that your Administrator send out the COBRA notice within 14 days. It’s unlikely we will have the new model notices from DOL by that time. Therefore, take a little time before you notify your Administrator. 
 
If you are self-administered, diary those terminations for approximately 40 days so that you can have a comfort-level with the “wait and see” approach and know that you won’t miss the important deadline for sending out your COBRA notice. If all goes according to plan, we should have new DOL model notices before that time and you can rest easy knowing that the notice you send will be compliant with the Extension Act. 
 
If we get to the point where notices must be sent and we still don’t have new model notices from DOL, then you can go ahead and provide the current COBRA notices to terminated employees and provide a cover letter advising them that the President recently signed a bill extending coverage under the COBRA subsidy program to involuntary terminations occurring between March 31, 2010 and May 31, 2010, and that they should substitute “May 31, 2010″ for all references to “March 31, 2010″ shown on the notice.
 
This notice provided courtesy of Worklaw Network member Lehr, Middlebrooks and Vreeland (www.lehrmiddlebrooks.com).

Note: You can find the COBRA forms and info on HR That Works under Document Management/Termination section. Additional info can be found on the DOL website at http://www.dol.gov/ebsa/cobra.html

The IRS has issued form W-11 to use when employing someone under the HIRE Act. To view the form and learn more about the law go to http://www.irs.gov/newsroom/article/0,,id=221036,00.html.

On April 15, 2010, President Obama signed into law the Continuing Extension Act of 2010 (HR 4851), once again extending the COBRA subsidy eligibility period under ARRA, through May 31, 2010. The law takes immediate effect and is retroactive to April 1, 2010. 

The law makes the following changes:

• New Sunset Date:  The COBRA subsidy eligibility period (for Qualifying Events on or after September 1, 2008) now ends on May 31, 2010. This period had expired on March 31, 2010. As a refresher, the subsidy is a 65 percent discount off the regular COBRA premium for up to 15 months. Only Assistance Eligible Individuals (AEIs) qualify for the subsidy.
• Eligible Qualifying Events:  As before, two types of Qualifying Events are subsidy eligible. The first one is an involuntary termination of employment. The second one is a reduction in hours followed by an involuntary termination of employment if that involuntary termination occurs on or after March 2, 2010, and on or before May 31, 2010.

The new law does not change the length of the COBRA maximum coverage period. It is still based on the original reduction in hours Qualifying Event date. Also, the subsidy period (up to 15 months) is unchanged.  Watch for the updated info at http://www.dol.gov/ebsa/cobra.html.

Here are the rules for employers in black and white, excerpted from the Act.

 

Sec. 311: Health Coverage Participation Requirements

 

An employer meets the requirements of this section if such employer does all of the following:

 

• Offer Of Coverage—The employer offers each employee individual and family coverage under a qualified health benefits plan (or under a current employment-based health plan (within the meaning of section 102(b))) in accordance with section 312.
  
• Contribution Towards Coverage—If an employee accepts such offer of coverage, the employer makes timely contributions towards such coverage in accordance with section 312.
  
• Contribution In Lieu Of Coverage—Beginning with Y2, if an employee declines such offer but otherwise obtains coverage in an Exchange participating health benefits plan (other than by reason of being covered by family coverage as a spouse or dependent of the primary insured), the employer shall make a timely contribution to the Health Insurance Exchange with respect to each such employee in accordance with section 313.
  

 

Sec. 312: Employer Responsibility to Contribute Towards Employee and Dependent Coverage

 

• In General—An employer meets the requirements of this section with respect to an employee if the following requirements are met:
  
  • Offering Of Coverage—The employer offers the coverage described in section 311 either through an Exchange-participating health benefits plan or other than through such a plan.
    
  • Employer Required Contribution—The employer timely pays to the issuer of such coverage an amount not less than the employer required contribution specified in subsection (b) for such coverage.
    
  • Provision Of Information—The employer provides the Health Choices Commissioner, the Secretary of Labor, the Secretary of Health and Human Services, and the Secretary of the Treasury, as applicable, with such information as the Commissioner may require to ascertain compliance with the requirements of this section.
    
  • Autoenrollment Of Employees—The employer provides for autoenrollment of the employee in accordance with subsection (c).
    

     

• Reduction Of Employee Premiums Through Minimum Employer Contribution—
  

1. Full-Time Employees—The minimum employer contribution described in this subsection for coverage of a full-time employee (and, if any, the employee’s spouse and qualifying children (as defined in section 152(c) of the Internal Revenue Code of 1986) under a qualified health benefits plan (or current employment-based health plan) is equal to:
   
   1. in case of individual coverage, not less than 72.5 percent of the applicable premium (as defined in section 4980B(f)(4) of such Code, subject to paragraph (2)) of the lowest cost plan offered by the employer that is a qualified health benefits plan (or is such current employment-based health plan); and
      
   2. in the case of family coverage which includes coverage of such spouse and children, not less 65 percent of such applicable premium of such lowest cost plan.
      
2. Applicable Premium For Exchange Coverage.—In this subtitle, the amount of the applicable premium of the lowest cost plan with respect to coverage of an employee under an Exchange-participating health benefits plan is the reference premium amount under section 243(c) for individual coverage (or, if elected, family coverage) for the premium rating area in which the individual or family resides.
   
3. Minimum Employer Contribution For Employees Other Than Full-Time Employees.—In the case of coverage for an employee who is not a full-time employee, the amount of the minimum employer contribution under this subsection shall be a proportion (as determined in accordance with rules of the Health Choices Commissioner, the Secretary of Labor, the Secretary of Health and Human Services, and the Secretary of the Treasury, as applicable) of the minimum employer contribution under this subsection with respect to a full-time employee that reflects the proportion of:
   
   1. the average weekly hours of employment of the employee by the employer, to
      
   2. the minimum weekly hours specified by the Commissioner for an employee to be a full-time employee.
      
4. Salary Reductions Not Treated As Employer Contributions—For purposes of this section, any contribution on behalf of an employee with respect to which there is a corresponding reduction in the compensation of the employee shall not be treated as an amount paid by the employer.
   

    

• Automatic Enrollment For Employer Sponsored Health Benefits—
  

1. In General—The requirement of this subsection with respect to an employer and an employee is that the employer automatically enroll such employee into the employment-based health benefits plan for individual coverage under the plan option with the lowest applicable employee premium.
   
2. Opt-Out—In no case may an employer automatically enroll an employee in a plan under paragraph (1) if such employee makes an affirmative election to opt out of such plan or to elect coverage under an employment-based health benefits plan offered by such employer. An employer shall provide an employee with a 30-day period to make such an affirmative election before the employer may automatically enroll the employee in such a plan.
   
3. Notice Requirements—
   
   1. In General—Each employer described in paragraph (1) who automatically enrolls an employee into a plan as described in such paragraph shall provide the employees, within a reasonable period before the beginning of each plan year (or, in the case of new employees, within a reasonable period before the end of the enrollment period for such a new employee), written notice of the employees’ rights and obligations relating to the automatic enrollment requirement under such paragraph. Such notice must be comprehensive and understood by the average employee to whom the automatic enrollment requirement applies.
      
   2. Inclusion Of Specific Information—The written notice under subparagraph (A) must explain an employee’s right to opt out of being automatically enrolled in a plan and in the case that more than one level of benefits or employee premium level is offered by the employer involved, the notice must explain which level of benefits and employee premium level the employee will be automatically enrolled in the absence of an affirmative election by the employee.
      

 

 

Sec. 313. Employer Contributions In Lieu Of Coverage

 

• In General—A contribution is made in accordance with this section with respect to an employee if such contribution is equal to an amount equal to 8 percent of the average wages paid by the employer during the period of enrollment (determined by taking into account all employees of the employer and in such manner as the Commissioner provides, including rules providing for the appropriate aggregation of related employers). Any such contribution—
  

1. shall be paid to the Health Choices Commissioner for deposit into the Health Insurance Exchange Trust Fund, and
   
2. shall not be applied against the premium of the employee under the Exchange-participating health benefits plan in which the employee is enrolled.
   

    

• Special Rules For Small Employers—
  

1. In General—In the case of any employer who is a small employer for any calendar year, subsection (a) shall be applied by substituting the applicable percentage determined in accordance with the following table for “8 percent”:
   

 

 

1. Small Employer—For purposes of this subsection, the term “small employer” means any employer for any calendar year if the annual payroll of such employer for the preceding calendar year does not exceed $400,000.
   
2. Annual Payroll—For purposes of this paragraph, the term “annual payroll” means, with respect to any employer for any calendar year, the aggregate wages paid by the employer during such calendar year.
   
3. Aggregation Rules—Related employers and predecessors shall be treated as a single employer for purposes of this subsection.
   

NPR did a great three-part series on the workplace. To listen to or read it go to http://www.npr.org/templates/story/story.php?storyId=124611210. Perhaps of most interest to me were the posts generated by working moms and others http://www.npr.org/templates/story/storyComments.php?storyId=124616719.

One of our Worklaw Partners, Lehr, Middlebrooks and Vreeland (www.lehrmiddlebrooks.com) produces an excellent newsletter. March’s newsletter discusses the recent Obama appointments to the NLRB. This is an important read for all employers, not just those already unionized. One more reason to attend the Webinar: Union Organizing and the New National Labor Relations Board: What You Need to Know to Be Prepared on May 11th at 2:00PM EST (11:00AM PST) with ­­­­­­­­­­­­­­­­­­­­­­­­­­John Simmons of Kiesewetter Wise (another www.Worklaw.com firm).

“The more you lose yourself in something bigger than yourself, the more energy you will have.” - Norman Vincent Peale  

This issue discusses:

• Editor’s Column: Positive Discipline
• It’s April—Have You Updated Your Posters and Employee Handbook?
• Avoid Hiring Discrimination Claims
• Presenting For Results
• Workplace Violations in Low-Wage Labor Markets
• Mixed Motives
• Executives Can Be the Greatest Risk
• Rude Boys
• Sex Stereotyping
• Keeping Complaints Confidential

We have also provided you with the Form of the Month

Editor’s Column: Positive Discipline

I recently finished the Positive Discipline for Parents course by Jane Nelsen. I would recommend this program to any parent. I’ve already raised two sons who are great young men at 29 and 31. Now I’m blessed with an eight year-old and I remain motivated to be a great parent. 

Having “been there and done that” just isn’t good enough. Odds are, by listening to the discipline course and applying it, I’ll become that much better. 

Much of the course centers on leadership and discipline. We’re instructed to be “kind, but firm,” to focus on encouragement and engagement rather than punishment or reward. Finally, we learn how to deal with poor behavior: How to react – or more importantly, how not to react – to create promises, mutual agendas, and consequences.  

Here’s a fact: There’s no substitute for continually improving yourself as a parent, executive, manager, or employee!  

I know every one of you is running 75 miles per hour. Trust me, I run pretty hard too, but I’ve learned that when I take care of myself and feed my body, mind, and spirit, I become a far more energetic, effective, and likeable person. 

In the end, the greatest discipline must be to doing my best, all the time. 

It’s April—Have You Updated Your Posters and Employee Handbook? 

At the beginning of the year, we recommended that you get your new all-in-one posters from the Compliance Store for only $19.95 (under Links in HR That Works), as well as updating your employee handbook – especially EEO, ADA, and FMLA provisions. While we’re on the subject of employee handbooks, look at the handbook we did for the San Gabriel YMCA. We ran a contest through eLance challenging top graphics people to bring the handbook to life. Summer Bonne of Washington State won the contest. To see the first 20 pages of the handbook, click here. If you’re an HR That Works member, go to the Employee Handbook page, where you can find out how much Summer will charge for bringing your handbook to life. 

Avoid Hiring Discrimination Claims

To help protect yourself against discrimination claims in the hiring process, we recommend that employers answer these questions developed by the California Case Analysis Manual: 

Discrimination 

Did the respondent fail to select the complainant because of the complainant’s protected status (race, sex, etc.)?  

Relevant Questions: 

• Did the adverse action (failure to select) actually happen?
• Is the respondent’s claim that the complainant is less qualified than the person selected accurate?
• Is any other rebuttal asserted by the respondent valid?
• o Is the respondent’s reason for not selecting the complainant factually accurate?
• o How did the respondent treat others in a similar situation as the complainant?
• Does the respondent’s application of its pre-selection procedures to similarly situated persons indicate that the failure to select occurred because of the complainant’s protected status?
• Does the relevant statistical pattern indicate that the failure to select occurred because of the complainant’s protected status?
• Is there any direct evidence to link the failure to select to the complainant’s protected status?
• Is there any anecdotal evidence to link the failure to select to the complainant’s protected status?

 

Presenting For Results

Effective human resource or other executives must be able to communicate to an executive group, a prospective employee, or business partner. To make sure that you’re communicating effectively, follow these guidelines: 

• Tell a story. People love stories. Stories have a beginning, middle, and end.
• Don’t engage in death by PowerPoint. Too many presenters overwhelm their audience with far too much information in their PowerPoint. It’s called PowerPoint, not PowerParagraph. Don’t have more than three bullet points on any slide. Don’t use entire sentences, just a snapshot of the point to be made. Even better, see how just one picture can express many words. An excellent book to consider is Presentation Zen by Garr Reynolds.
• Begin logically and end emotionally. Move from the left side of the brain to the right side. Give people powerful information and the emotional “why” for applying it.
• Less is more. Sometimes it’s better to communicate from a single page of bullet points than from an extensive handout. You can always make more information available later on.
• Ask powerful questions. What can you ask that would be thought provoking? What questions keep your audience up at night? What questions will develop a rapport with your audience immediately?
• Get feedback regularly. Be sure that your audience understands your point. Do they agree with you? For example, after making a point, superstar presenter Tony Robbins will ask the audience to say “Ay” in unison to help reinforce the point just made.
• Wrap it up with action items. Identify the actions that you and your audience should take next. Give them a form or checklist to apply the information shared in your presentation.

Follow these presentation essentials and you too will do a great job of communication. 

To learn more about presentations, see our Form of the Month: Powerful Presentation Techniques.  

Workplace Violations in Low-Wage Labor Markets

An extensive survey of more than 4,000 low-wage workers in Los Angeles, Chicago, and New York City by the National Employment Law Project (NELP) reached these conclusions: 

• More than one in four workers surveyed (26%) were paid less than minimum wage.
• Among these workers, 16% were underpaid by more than one dollar per hour.
• More than three in four (76%) workers who worked overtime were not paid for their time. The average worker had put in 11 hours that were either underpaid or not paid at all.
• Women and foreign-born workers were victimized more than anyone else.
• The average wage theft was 15% of earnings.

Additional violation categories included: 

• Off-the-clock
• Meal breaks
• Pay stubs
• Illegal deductions
• Tips
• Illegal employer retaliation
• Workers Compensation violations 

It is hard to balance this economic suffering with the fact some executives are making tens of millions of dollars during a failing economy. You don’t have to be of any political persuasion to realize that something’s out of whack. Not only do these employers deprive good people of a fair day’s pay, they’re also at war with companies who strive to grow their business the right way; perhaps even going above the call and actually empowering their workers rather than oppressing them. If we can fight overseas to assure basic human rights, we should be able to do the same here. 

For more information on the survey, click here.

Mixed Motives

In an appeal from a Los Angeles County case, Wynona Harris alleged that the city of Santa Monica terminated her job as a bus driver because she was pregnant. The city submitted a wealth of evidence regarding the plaintiff’s poor performance on the job, including excessive absenteeism and tardiness. The legal issue involved is the “mixed motive” defense. The trial court refused to give an instruction that would have allowed the city to argue that it couldn’t be held liable because even if there were discrimination, Harris would have been fired anyway. In reviewing the jury instruction, the appellate court reversed the trial court and stated that the following instructions should apply: 

“If you find that the employer’s action, which is the subject of the plaintiff’s claim, was motivated by discriminatory and non-discriminatory reasons, the employer is not liable if the employer can establish by a preponderance of the evidence that its legitimate reason, standing alone, would induce it to make the same decision.” 

The court sent the case back to trial using the revised jury instruction; it’s up to the jury to determine whether the alleged reason for the plaintiff’s termination was legitimate or, in fact, a pretext for actual discrimination. 

To read the case, click here.

 

Executives Can Be the Greatest Risk

Having the wrong executive in the wrong spot might create a legal problem, as well as a business headache. In the California appellate case Align Technology v. Bao Tran, Align sued a former employee, attorney Bao Tran, for stealing their patents and starting a competing law firm. The suit alleged that Tran used confidential information to assist a startup competitor and fund an unauthorized law practice on the side. According to the allegations, Tran used company funds to apply for patents in his own name and for his clients, ran his side business using the company’s phones and computer systems, and misappropriated company property by applying for patents in his own name. Align allegedly learned of Tran’s side business as the result of at least 13 phone calls from his clients, including one call in June 2005 from an individual who indicated that Tran had been his company’s intellectual and patent attorney for three years. Tran denied these allegations and accused Align of defaming him and attempting to undermine his new business. 

Bottom line: Don’t assume that your executives aren’t a problem. Many companies focus on rank-and-file employees, even though executives can cause 10 times the damage. 

To read the case, click here.

Rude Boys

The Alabama Federal District Court case, Reeves v. CH Robinson Worldwide, offers a significant guide to sexual harassment workplace issues. Plaintiff Ingrid Reeves began working as a transportation sales rep in the company’s office. She was the only woman. Reeves alleged that sexually offensive language permeated her work environment every day (To read a complete collection of crude language, review the facts of the case). This rude behavior continued despite complaints to co-workers and management. What’s more, an offensive radio program played in the workplace every day. 

Reeves resigned and filed a complaint alleging that the sexually offensive language and radio show created a hostile work environment that violated Title VII. The trial court entered a summary judgment for the company on the grounds that because men and women were subject to the same language, the harassment was not “based on” Reeves’ sex.  

She appealed, claiming that simply because she was not the target of the harassing language did not determine whether there was a hostile work environment. The appellate court agreed, ruling that “sex-specific profanity” is more degrading to women than men, and that a workplace permeated with discriminatory intimidation, ridicule, and insult satisfied the “based-on” element required to support a sexual harassment hostile environment case. The court based this conclusion in part on parallels with race discrimination cases. 

After analyzing the frequency and severity of the problem, the court held that the evidence provided could lead a reasonable jury to believe that the harassing conduct need not tangibly affect an employee’s job performance to be actionable. The court added that, “Ordinary tribulations of the workplace, such as the sporadic use of abusive language, gender-related jokes, and occasional teasing does not satisfy the severe or pervasive element required for a claim.” 

Lesson learned: Beware of employees entering a traditionally male or female role at your company. Once this happens, the rules do in fact change! 

To read the case, click here.

Sex Stereotyping   

Brenna Louis v. Harlan Inns, a Federal District court case in Iowa, involved a unique set of facts. To make a long story short: An admittedly “masculine looking,” yet productive woman was not considered “front desk material” for the Harlan Inn, according to one (female) manager who insisted on front desk clerks coming as close to the perfect “Midwest girl” image as humanly possible.  

The court, relying heavily on the U.S. Supreme Court case Oncale v. Sundowner (1988) stated that the plaintiff’s dismissal and harassment “was because of her sex.” According to the court, “The question is whether [the managers’] requirements that Louis be ‘pretty’ and have the ‘Midwestern girl’ look is because she is a woman.”  

Interestingly, the chief judge dissented. He likened the hotel’s actions to declining to hire a female cheerleader because she isn’t pretty enough or a male fashion model because he isn’t handsome enough. The other justices disagreed, arguing that the employer is responsible for proving the affirmative defense that physical appearance is a bona fide occupational qualification (which they could not).  

Editor’s comment: One can easily see the arguments on both sides. If I don’t like the way someone looks, I don’t have to work with them, whether I have one employee or 5,000. On the other hand, there’s the argument that we’ve progressed past the place of permitting discrimination of any kind without a real business justification. Enforcing this level of tolerance or acceptance is always difficult at best. Of course, there’s a proper balancing point — someplace. Here’s the case link.  

The bottom line: If you’re aiming for a specific “look in employees,” you might face a lawsuit. A well-known California case involved a manager saying that one of the L’Oreal cosmetic girls wasn’t pretty enough. The fact that she complained about this as a discriminatory remark eventually resulted in her filing a wrongful termination retaliation-based claim.

Keeping Complaints Confidential   

In a Second Circuit case, Karen Duch sued the State of New York for sexual harassment. Duch, a court officer at the Manhattan Midtown Community Court, spoke with a manager who was also an EEO liaison about ongoing harassment. Duch told the manager, “I’m telling you as a friend;” when asked if she wanted the harassment reported, she responded “Absolutely not.” Because of this request and despite her EEO responsibilities, the manager did not report the harassment to anyone. In ruling against Duch, the court stated several conclusions that employers should consider:  

• When harassment comes from a co-worker, rather than a supervisor, the employer is held liable only if it fails to provide a reasonable avenue for complaint or to take appropriate remedial action about a problem they know of.
• In this case, Duch had reasonable avenues of complaint, despite the fact the EEO liaison was poorly trained and failed to report her complaints to anyone. Duch acknowledged she could seek assistance from at least five different sources, in addition to the manager.
• Also at issue was the question of whether her manager’s failure to react could be imputed to the company. The court reminded us this would be the case when: (a) the official is at a high enough level of management to qualify as a proxy for the company; (b) the official has a duty to act on the knowledge and stop the harassment; or (c) the official has a duty to inform the company of the harassment. The court held that in this case, the manager did not breach her duty to remedy the harassment because she honored an employee’s request to keep her complaint confidential. The court also ruled that the conduct had not reached the point that a manager simply cannot stand by, even if requested to do so by the employee.
• Unfortunately for the employer, there was another higher-level executive, whose knowledge of the complaints was imputed to the employer. The court stated that when an employee’s complaint raises the specter of harassment, a supervisor’s purposeful ignorance of the nature of the problem would not shield an employer from liability under Title VII. This holds true even where the executive never learned about, and did not witness, the alleged harassment.
• In light of their ruling that a jury could find that there was knowledge of the harassment when Duch requested a schedule change from another manager, a jury could also find that their response was unreasonable. A formal investigation of the complaint did not begin until three months later.

Lesson learned: Be very clear about what you want your managers to do when they suspect or know about wrongful conduct:  

• What should they do if they know about it but nobody complains?
• What should they do if somebody complains to them, but asks them not to say anything?
• What should they do when things gets so bad that they should say something despite the employee’s request?
• How should they approach someone about what they might suspect is harassing conduct? Should they say something like, “Is Bob harassing you? Should I speak to the EEO about this? If you want me to keep it confidential I’m going to write this down to protect the company and myself. If you feel you need help, bear in mind that I’ll always report it to a proper superior or you can go directly to that person without involving me if you want to.”

As always, we recommend that all HR That Works members use the Employee Compliance Survey every six months. If the company had done so in this case, it could have avoided the second-guessing and engaged in appropriate conduct. To read the case, click here. 

Form of the Month

Powerful Presentation Techniques (PDF)  

 Use these guidelines to get your message across to managers, employees, clients, and the public.  

(HR That Works Users can access this form in Word format by logging on to the site).  

 

Podcast

Please click here to listen to the April 2010 Compliance and Culture Podcast.