Summer Cleaning: Three Easy Tips to Reduce Joint Employment Risks

Donate some, pitch some. That’s our third dumpster.

This month I have been focused on summer clean up. We moved back into our house after six months of unintentional reconstruction, thanks to failed plumbing supply line on the second floor that created an impromptu shower and bath throughout the first floor of our house. Welcome home from vacation, late December 2020.

But now I’m back and getting organized. Cleaning house. Moving forward.

Late summer can also be a good time to clean house and eliminate unnecessary legal risks. With the White House about to release a new rule on joint employment, now is the time to review your staffing agency agreements.

You’ll want to check for these three things:

  1. The Monster with Three Eyes. You need these three components to protect against joint employment claims, no matter what test applies.
  2. A clause like this one, to allow you to remove unwanted workers without exerting the type of control that would make you their employer.
  3. Awareness of FMLA risks. Know what to watch with temps-to-hire, and don’t forget about this often-overlooked rule.

Still looking for more places to click? Here are Five Things You Should Know About Joint Employment.

The rules and the tests will keep changing, but the joint employment issue is here to stay. The risks of joint employment will only increase over the next few years.

It’s time for some summer cleaning. You can work magic with a few adjustments to your contracts, and you shouldn’t need a dumpster to complete this clean up exercise.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

2018_Web100Badge
 

Like Being Thrown on a Trotting Horse? This Company is Trying Rideshare without Independent Contractors

In 18th Century Europe, common methods for trying to revive drowning victims included throwing the victim onto a trotting horse, dunking in freezing water (ironic?), and my personal favorite, blowing tobacco smoke into the rectum.

These were creative ideas and sometimes they actually worked. The bouncing motion from being on a trotting horse could force air in and out of the lungs, like modern CPR. Tobacco smoke contains nicotine, which causes the brain to release epinephrine, which helps to stimulate the heart to contract.

It’s fun now to look back at how people tried to solve problems when they didn’t know what would happen.

The biggest unknown in the world of independent contractor misclassification is what would happen if rideshare and delivery companies were forced to reclassify all drivers as employees. A well-funded startup in Dallas is attempting to find out.

As reported here, a new rideshare service called Alto just completed a $45 million round of Series B funding. Alto’s model is to use all W-2 drivers and company-owned vehicles. The service currently operates only in Dallas, Houston, and Los Angeles, and has announced plans to switch to all-electric vehicles.

Will it work? Who knows.

Is it a viable business model? Who knows.

But in some ways, it’s a test case to see how an industry dominated by the independent contractor model might operate if forced to use all W2 workers. Yes, I know the taxi industry is another comparable. But it hasn’t exactly thrived since the emergence of rideshare. I’m pretty sure that’s not the model that rideshare would look to if force to pivot.

As the old proverb goes, necessity is the mother of invention. For those keeping score at home, Mothers of Invention was also the name of an experimental rock band in California once fronted by Frank Zappa and which featured tracks such as “My Guitar Wants to Kill Your Mama.” But that’s for another day.

For now, the rideshare industry continues to operate with its independent contractor model under siege. Widespread conversion of driver contractors to employees would be difficult and would introduce massive disruption in the industry. We’ll see what happens. In the meantime, let’s continue to innovate. Sometimes, even being thrown on a trotting horse can be helpful.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

2018_Web100Badge
 

Independent Contractors May Have a Weil Problem On Their Hands

Crash Test Dummies is a band from Winnipeg that I really like — especially the 1993 album, God Shuffled His Feet. It’s full of thoughtful questions asked in a booming deep voice. The song In the Days of the Caveman takes a look back, with some keen observations added for good measure:

In the days of the caveman
And mammoths and glaciers
Bugs and trees were your food then
No pajamas or doctors

See, that’s all true and probably not something you had thought about before.

President Biden has given us another reason to look back and reconsider some things you hadn’t thought about in a while. Last week, Biden nominated David Weil to serve as Wage and Hour Administrator. Weil served in the same role under Obama, so we’ve seen that movie too.

Here are some highlights from Weil’s last stint as W&H Administrator:

  • Administrator’s Interpretation 2016-1: Joint Employment under the FLSA, which I wrote about here when it was issued. Weil embraces the broadest possible view of joint employment. The Trump Administration’s DOL rescinded this guidance in 2017.
  • Administrator’s Interpretation 2015-1: Applying the FLSA’s “Suffer or Permit” Standard to Independent Contractor Classification, which I wrote about here. Weil advocates an expansive view of employment, declaring that “most workers are employees under the FLSA’s board definitions.”

Here’s what we can expect from Weil 2.0:

  • Increased enforcement activity by the DOL against companies using independent contractors.

Right now, claims generally arise through lawsuits, and class/collective actions present the most danger. The risk of class claims can be limited with arbitration agreements and class waivers. But arbitration agreements provide no defense against a DOL action. Those agreements don’t bind the government. Expect the DOL to go after companies that make extensive use of independent contractors.

  • Increased enforcement activity by the DOL on joint employment claims.

Remember, unlike independent contractor misclassification, joint employment is not illegal. Joint employment is a problem when a primary employer (such as a staffing agency or vendor/subcontractor) fails to comply with some aspect of the FLSA and its wage payment rules. Under a broad theory of joint employment, the company benefitting from the services is going to be liable for the errors of the primary employer, even though the alleged joint employer had no control over the primary employer’s wage practices.

  • New regulations on independent contractor classification and joint employment.

The standards and test keep changing, depending on who holds the White House. One step the Wage and Hour Division can take to try to make its views more permanent is to adopt its views as formal regulations, not just Administrator’s Interpretations. This is what the Trump DOL tried to do for both independent contractor misclassification and joint employment. Expect a strong push by the DOL to adopt new regulations that make it harder to maintain independent contractor status and easier to find joint employment.

The bottom line is that we’re going back in time. Maybe not so far back that bugs and trees were your food then, but back to 2015 and 2016 interpretations of the FLSA. Expect no pajamas or doctors.

What to do about it? Businesses that rely on independent contractors should tighten their agreements now. Businesses that engage staffing agencies should review those contracts now.

These posts contain a few of my favorite tips:

Good luck out there, and beware of mammoths and glaciers.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

2018_Web100Badge
 

What Are the I-9 Requirements for Independent Contractors?

The Munker-White Illusion, image by David Novick (UTEP)

This is one of my favorite optical illusions. The spheres here are all beige. They are not red, green, or purple. Look closely and you’ll see. David Novick, a professor of engineering at UTEP, explains the illusion here.

It’s fun to be fooled with optical illusions. But it’s not fun to be fooled with federal immigration law.

Companies retaining independent contractors should remember these key points for I-9s and immigration law compliance:

1. Properly classified independent contractors do not need to complete I-9 forms.

2. Misclassified independent contractor — that is, those who are really employees under federal law — are employees and should have a completed I-9. A multi-factor test is used to make this determination. According to federal regulations, these factors should be considered:

  • Who supplies tools or materials;
  • Whether the worker makes services available to the general public;
  • Whether the worker works for a number of clients at the same time;
  • Worker’s opportunity for profit or loss as a result of labor or services provided;
  • Worker’s investment in facilities for work;
  • Who directs the order or sequence in which the work is to be done; and
  • Who determines the hours during which the work is to be done.

3. Federal law prohibits individuals or businesses from contracting with an independent contractor to provide services in the U.S., knowing that the contractor is not authorized to work in the U.S. [8 U.S.C. 1324a(a)(4)]

4. Staffing agency temps employed by the staffing agency must complete I-9s as employees of the staffing agency. Contracts with staffing agencies should make clear the staffing agency accepts this obligation. If an agency sends a bunch of undocumented temps to your worksite, you might get an unscheduled visit from ICE, which is not a good look.

For those keeping a list at home (wait, that’s just me?), you can add immigration law noncompliance to the list of Things That Can Go Badly When Independent Contractors are Misclassified.

And that’s no illusion.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

2018_Web100Badge
 

SLoB Act? Really? Businesses Should Support This Joint Employment Bill Despite Dumb Name

Image by Prawny from Pixabay

It’s all about branding, fellas. Republicans have introduced bills with clever acronyms before. Examples include:

  • JAWS Act (Justice Attributed to Wounded Sharks)
  • BEER Act (Brewers Excise and Economic Relief Act); and
  • EL CHAPO Act (Ensuring Lawful Collection of Hidden Assets to Provide Order), to require El Chapo to forfeit assets from the drug trade.

But I’m puzzled by the more recent lack of effort.

Seeking to counter the Democrats’ boldly named PRO Act (Protecting the Right to Organize), Republicans have introduced the SLoB Act (Save Local Business).

Seriously? That’s the best that your marketing team could do?

The SLoB Act would narrow the definition of joint employment. To find “joint employer” status, proof would be required of direct, actual, immediate, and significant control over essential terms and conditions of employment, such as hiring, firing, pay, benefits, supervision, scheduling, and discipline.

That would be terrific for franchising and for all businesses that use outsourced labor, such as through staffing agencies. The SLoB Act would amend both the National Labor Relations Act (NLRA) and the Fair Labor Standards Act (FLSA). For those of you who recall the Browning-Ferris escapades, this bill would repeal the loosey-goosey joint employment standard the NLRB tried to adopt in 2015, later repealed, unrepealed, and appealed. The bill would codify a tougher test, making it much harder to prove joint employment.

The SLoB Act will not pass, at least not in this Congress. It is unlikely to have any Democratic support. But it has a letter of support signed by 65 leading industry groups, including the U.S. Chamber of Commerce, the American Trucking Association, the National Franchise Association, and the Society for Human Resource Management.

I like the bill, but I’d have gone with a better acronym. Such as…

  • JERKY Act (Joint Employment is Really Kinda Yucky)
  • EJECT Act (Editing the Joint Employment Control Test)
  • JESUS Act (Joint Employment Should be Used Sparingly).

I think the last one would garner the most support, no matter what the bill was about. No one wants to go on record opposing Jesus.

But nobody asked me.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

2018_Web100Badge
 

Schrödinger’s Cat? Ninth Circuit Disrupts Trucking Industry with Contractor Misclassification Ruling

Have you heard of Schrödinger’s cat? It’s not a real cat, like Felix or Brian Setzer. It’s a hypothetical, seemingly impossible cat that exists only in the world of quantum physics. Schrödinger’s cat refers to a thought experiment in which a cat in a box is simultaneously alive and dead, until you open the box and observe the cat. Then, stubborn as cats are, it will be only one or the other, and that’s when you realize you prefer dogs anyway.

In a ruling last week, the Ninth Circuit has tried to give the trucking industry Schrödinger’s cat.

The issue was whether California’s infamous ABC Test applies to the trucking industry. The answer now is both yes and no, depending on where you look.

If you’re in California, the Ninth Circuit says yes, the ABC Test applies to the trucking industry. Under the ABC Test, now part of California’s Labor Code, most workers are classified as employees, not independent contractors, unless the work they perform is “outside the usual course of the hiring entity’s business.” (There’s more to the ABC Test, but that’s Part B, the hardest part to meet.)

In the trucking industry, it’s hard to argue that owner-operator truckers retained by a trucking company are performing work that is “outside the usual course” of the trucking company’s business. The ABC Test would likely reclassify most owner-operators as employees. The California Trucking Association brought a lawsuit in 2018, arguing that the Federal Aviation Administration Authorization Act of 1994 (FAAAA) preempts this California law from being applied to trucking. The FAAAA preempts state laws “relating to a price, route or service of any motor carrier … with respect to the transportation of property.” Cal Trucking argued that applying the ABC Test and reclassifying owner-operators as employees would affect the prices, routes, and services provided.

Last week, the Ninth Circuit ruled that the ABC Test is a “generally applicable” law that does not sufficiently affect prices, routes, or service to be preempted. California’s ABC Test therefore applies to trucking and is not preempted by the FAAAA.

Now remember the cat – both alive and dead?

If you’re in Massachusetts, the answer to the same question is no, the ABC Test does not apply to trucking. In 2016, the First Circuit ruled that the FAAAA preempts Massachusetts’ ABC Test (which is the same as California’s) because of its effect on prices, routes, and service, when applied to trucking.

So what happens now? How can one federal law simultaneously mean two different things?

There are three ways this can play out:

  • The full Ninth Circuit might rehear the case and could reverse its ruling (which was a 2-1 split) to conform with the First Circuit’s view;
  • The ruling might stay as it is, meaning that the interpretation of a federal law (the FAAAA) is different in California and Massachusetts, even though their state ABC Tests are the same; or
  • The Supreme Court will take the case and resolve the circuit split.

I grew up in Miami where they had greyhound racing, which you can bet on. I don’t think there’s anywhere you can go and bet on cats. But if I were a betting man on this one, I’d wager that the Supreme Court weighs in at some point.

The owner-operator model in the trucking industry is so well-established and has been permitted for so long under federal law that it seems impossible for the Supreme Court to allow the FAAAA to mean two different things in two different states.

And what about the rest of the country?

The Third and Seventh Circuits have ruled that the FAAAA does not preempt state wage and hour laws when applied to trucking, but those courts were not considering strict ABC Tests like those reviewed by the First and Ninth Circuits. The ABC Test aims to reclassify most contractors as employees; it is no ordinary wage and hour law. More states are considering adopting strict ABC Tests and, in those states, we don’t know whether the FAAAA would preempt state classification law for truckers or not.

In other words, for most of the country, the cat is both alive and dead, and we won’t know which it is until we look. Unfortunately for tens of thousands of truckers, this is not a mere thought experiment. The disruption to the industry is massive, and the sooner we get a clear answer, the better it will be for everyone. Except maybe the cat.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

2018_Web100Badge
 

A Million Dollar Bill? Be Careful Before Relying on the Direct Seller Exemption for Contractor Status

All this cash is available on Amazon for just $13.67!

A Tennessee woman was recently busted for trying to use a $1 million bill to buy a cartful of personal items at a dollar store. The clerk reported the woman to Blount County police, who issued a no trespass order.

That really had no chance of working. Did the woman really think the register at a dollar store had $999,900 or so in change? She did not think that one through too carefully.

Thinking things through is important in all walks of life, including when classifying sales personnel as contractors or employees.

You may have heard that the Internal Revenue Service treats a “direct seller” as an independent contractor, not an employee. But don’t assume all directs sellers are contractors, not employees. Here are two important notes of caution:

First, the definition of “direct seller” is narrow. Here’s what it means, according to IRS Guidance on Direct Sellers:

Direct sellers include any of the following:

  • A person who sells consumer products in the home or a place of business other than a permanent retail establishment,
  • A person who sells consumer products on a deposit or commission basis, or to other persons who will sell the products in the home or place of business,
  • A person who delivers and/or distributes newspapers or shopping guides.

Direct sellers have certain things in common. Their compensation is related to sales rather than to the number of hours worked. Services are performed under a written contract between the seller and the person for whom the seller performs the services.

And the contracts involved provide that sellers are not treated as employees for federal tax purposes.

But wait, there’s more. The Internal Revenue Code also requires, for someone to be a “direct seller,” that:

(B) substantially all the remuneration (whether or not paid in cash) for the performance of the services described in subparagraph (A) is directly related to sales or other output (including the performance of services) rather than to the number of hours worked, and

(C) the services performed by the person are performed pursuant to a written contract between such person and the person for whom the services are performed and such contract provides that the person will not be treated as an employee with respect to such services for Federal tax purposes.

The full statute is here. Further IRS Guidance can be found here.

Second, even if someone is a “direct seller” under the Internal Revenue Code, that doesn’t mean they’re automatically independent contractors under other laws, including federal wage and hour laws state laws.

For example, the FLSA says that “outside sales” professionals are exempt from minimum wage and overtime requirements, but the requirements are different. DOL Fact Sheet #17 explains this exemption.

California’s ABC Test does not apply to “direct salespersons,” but only if those individuals meet the test in California’s unemployment law. Other states have different rules for sellers.

The bottom line when classifying direct sellers is to remember that different tests apply to different laws. Be thorough, and remember that a worker’s classification may be different under federal tax law than under wage and hour law or state law. You’ve got to think this all the way through.

Getting it wrong can be costly, especially for businesses that use lots of independent contractors, and — most important — novelty U.S. currency like million-dollar bills won’t cover those penalties or litigation damages. But, according to the seller of these bills on Amazon, these are the “million dollar bills that get the WOW response.” So there’s that.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

Sign up now for the BakerHostetler 2021 Master Class on The State of Labor Relations and Employment Law. Twelve sessions, one hour every Tuesday, 2 pm ET, all virtual, no cost. Click here for more information. List me as your BakerHostetler contact so I know you’ve registered. 

2018_Web100Badge
 

Managing a Large Contingent Workforce: What are MSP, VMS, and FMS?

When something important has to get done, you’ll do whatever it takes. And you’re not alone. This ten-year old, for example, stole his parents’ car to drive to the grocery store to buy Cheerios when he found they had run out at home.

I’d start hiding the car keys. There are better ways to replenish the Cheerios.

Replenishing your workforce can be a tougher job. When building a contingent workforce management program, there are lots of options and lots of acronyms.

Here’s a high level cheat sheet of the key options, along with the acronyms you’ll hear:

MSP = Managed Service Provider.  Third party that oversees the selection of service providers. An MSP negotiates contracts with staffing agencies and works with suppliers, usually not working directly with individual talent. Uses VMS, possibly FMS.

VMS = Vendor Management System.  Web-based application that allows organization to secure and manage staffing services on a temporary, permanent, or contract basis. Features include job requisitions and staff ordering. Centralizes and handles the administrative process of multiple vendors for invoicing and payments.

FMS = Freelance Management System.  Technology platform used to match opportunities with talent. May include a talent pool; may include public marketplace and a private talent pool. Helps ICs find opportunities.

VOP = Vendor on premise. Preferred staffing agency, onsite.

Your company can use a VMS directly or can retain an MSP (which will use its own VMS) to manage the talent acquisition process. Here’s my weak attempt at a flow chart:

          MSP

        /       \

     VMS    FMS   

       |            |

Staffing       ICs

Agencies

     |

Temps, ICs

Here’s what I’m trying to show: If you retain an MSP, the MSP will likely use a VMS to work with staffing agencies, and the staffing agency will identify temps or ICs. Or, the MSP may use a FSP to directly retain ICs.

If you do not retain an MSP, you can handle the talent search process in house, using a VMS to oversee the relationship with staffing agencies, who will procure temps or ICs. Or you can use a FMS to match qualified ICs with your project-based needs.

This is a vast oversimplification, but hopefully it’s helpful at a high level. Best wishes for a terrific week, and don’t forget to maintain an adequate supply of Cheerios.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

Sign up now for the BakerHostetler 2021 Master Class on The State of Labor Relations and Employment Law. Twelve sessions, one hour every Tuesday, 2 pm ET, all virtual, no cost. Click here for more information. List me as your BakerHostetler contact so I know you’ve registered. 

2018_Web100Badge
 

Who WAS My Employee? Companies Must Provide This Notice to Former Employees By May 31.

Please hold. The past is calling. Source: LOC

This weekend I watched The Call, a South Korean horror film (yes, subtitles) about a woman who receives a call from 20 years earlier. The past and present keep changing as the two callers interact over time. Oddly there were two movies released in 2020 named The Call. It’s this one.

The past can affect the present, but not usually the way it did in the movie.

The American Rescue Plan Act of 2021 (ARPA) imposes new COBRA-related obligations on employers, including notice requirements to former employees. In this blog, we usually ask Who Is My Employee?, but this week’s post is about Who Was My Employee?

ARPA changes the COBRA rules for April 1 through September 30, 2021. Employees who are involuntary terminated or become COBRA-eligible due to a reduction in hours are entitled to a 100% subsidy on their COBRA premiums for six months, April 1 to September 30. The company must pay the premiums, which are then reimbursed by the government through payroll tax credits.

ARPA extends this subsidy opportunity to former employees too, even those who did not sign up for COBRA when they were terminated. Under ARPA, those individuals get a second chance to sign up if they became COBRA-eligible less than 18 months ago.

Employers must send new COBRA notices to individuals who were involuntarily terminated (or who became COBRA-eligible due to a reduction in hours) within the last 18 months, including those who did not choose coverage at the time. These individuals can take advantage of the subsidized premiums from April through September, unless their 18-month COBRA eligibility period ends earlier or they become ineligible for another reason. Eligibility ends if the individual becomes eligible for other healthcare coverage or Medicare.

The DOL will be publishing model notices by April 10.

Employers must send this notice by May 31.

There’s more that employers need to know about changes to COBRA. The changes mean that your template severance agreements probably need to be revised too. There are new COBRA notice requirements for departing employees and new notices that must be sent when the subsidies are about to end.

I drafted a post addressing these subjects for BakerHostetler’s Employment Law Spotlight blog, which you can read here.

Reaching back 18 months to send notices to departed employees is an unusual requirement, but employers will have to make reasonable efforts to track these people down. Fortunately, unlike in The Call, employers don’t need to worry about anything that happened 20 years ago. The 18-month lookback is plenty to worry about.

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

Sign up now for the BakerHostetler 2021 Master Class on The State of Labor Relations and Employment Law. Twelve sessions, one hour every Tuesday, 2 pm ET, all virtual, no cost. Click here for more information. List me as your BakerHostetler contact so I know you’ve registered. 

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

 
2018_Web100Badge
 

Macaques & The Guess Who: Why the New Independent Contractor Rule Won’t Take Effect March 8

Photo by Hectonichus and, yes, this fella is sticking his tongue out at you (but he can’t remember why).

A Swedish study concluded that baboons, pig-tailed macaques, and squirrel monkeys have some of the worst short-term memories in the animal kingdom, barely exceeding that of bees. The point is, never ask a pig-tailed macaque where you left your car keys.

Having a short memory can be a problem in some situations, but not it’s not an issue if you’re just trying to recall the latest Department of Labor test for independent contractor misclassification. Everything you recall from six weeks ago is being undone anyway. (Or Undun, if you’re a fan of the spelling-impaired Canadian band The Guess Who.)

Remember the new rule issued by the DOL in January 2021 for determining employee vs. independent contractor status? It was going to modify the Economic Realities Test to focus on two core factors: (1) the nature and degree of the worker’s control over the work, and (2) the worker’s opportunity for profit or loss based on personal initiative or investment. The new rule was to take effect March 8. The test would apply only to claims under the Fair Labor Standards Act (FLSA).

No more. Last week, the DOL delayed implementation until May, but the rule most likely will be rescinded completely. Undun.

This decision comes on the heels of the DOL rescinding two opinion letters that were also issued in January. Undun. The letters provided guidance on determining independent contractor status in a few particular situations.

The Economic Realities Test remains the test used to determine who is an employee under the FLSA. It’s a multi-factor balancing test.

So if you’ve been relying on recent DOL guidance for how to apply that test, channel your inner pig-tailed macaque. Whatever you recall from January can be forgotten. And where did I put my car keys?

© 2021 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

Sign up now for the BakerHostetler 2021 Master Class on The State of Labor Relations and Employment Law. Twelve sessions, one hour every Tuesday, 2 pm ET, all virtual, no cost. Click here for more information. List me as your BakerHostetler contact so I know you’ve registered. 

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

 
2018_Web100Badge