Constangy, Brooks & Smith, LLP Jeffery L. Thompson Constangy, Brooks & Smith, LLP Telephone:...

Constangy, Brooks & Smith, LLPConstangy, Brooks & Smith, LLP

Jeffery L. ThompsonConstangy, Brooks & Smith, LLP

Telephone: 478-621-2414E-mail: [email protected]

Latest Labor & Employment Law Trends


Patient Protection and Patient Protection and Affordable Care ActAffordable Care Act


Implementation ScheduleImplementation Schedule


2013 Changes2013 Changes

Plans must provide a Plans must provide a participant participant noticenotice regarding the regarding the upcoming upcoming exchangesexchanges (after Department of Labor (after Department of Labor issues guidance regarding the notice).issues guidance regarding the notice).

Health flexible spending account limit Health flexible spending account limit will be will be $2,500$2,500. .


2014 and Beyond2014 and Beyond

Some of the additional changes Some of the additional changes scheduled for implementation are:scheduled for implementation are: Establishment of Establishment of state insurance state insurance

exchangesexchanges.. Imposition of a Imposition of a penaltypenalty on large on large

employers not offering health insurance employers not offering health insurance ($2,000($2,000 per full-time employee) per full-time employee) ($3,000($3,000 for an employee who receives tax-for an employee who receives tax-subsidized coverage through an subsidized coverage through an exchange). exchange).


2014 and Beyond2014 and Beyond Employers are required to provide a Employers are required to provide a qualifying qualifying

groupgroup health planhealth plan that meets the ACA that meets the ACA requirements. requirements. Provides Provides minimum essential benefitsminimum essential benefits (for fully (for fully

insured small group plans, also provides all insured small group plans, also provides all required required “essential health benefits”),“essential health benefits”),

Limits cost-sharingLimits cost-sharing for such coverage, and for such coverage, and Provides either a Provides either a bronze, silver, gold, or bronze, silver, gold, or

platinumplatinum level of coverage (meaning benefits level of coverage (meaning benefits that are the equivalent to (respectively) 60%, that are the equivalent to (respectively) 60%, 70%, 80%, or 90% of the full benefits provided by 70%, 80%, or 90% of the full benefits provided by the plan).the plan).



““Essential health benefits”Essential health benefits” include (at include (at this point):this point):

- Ambulatory Patient Services- Emergency Services- Hospitalization- Maternity and Newborn Care- Mental Health and Substance

Abuse Services- Behavioral Health Treatment

- Laboratory Services- Preventive and Wellness

Services- Chronic Disease

Management- Prescription Drugs- Pediatric Services,

including oral and vision care



Requirement for Requirement for individualsindividuals to have to have health insurance health insurance oror pay a pay a tax penaltytax penalty. . Individuals without “minimum essential Individuals without “minimum essential

coverage” would be required to pay a coverage” would be required to pay a penalty tax of the greater of $695 per penalty tax of the greater of $695 per year, up to a maximum of three times year, up to a maximum of three times that amount per family ($2,085), or that amount per family ($2,085), or 2.5% of household income2.5% of household income



The penalty would be phased in accordingly: The penalty would be phased in accordingly: $95 in 2014, or 1.0% of taxable income $95 in 2014, or 1.0% of taxable income $325 in 2015, or 2.0% of taxable income $325 in 2015, or 2.0% of taxable income $695 in 2016, or 2.5% of taxable income $695 in 2016, or 2.5% of taxable income Beginning after 2016, the penalty will be Beginning after 2016, the penalty will be

increased annually according to cost-of-increased annually according to cost-of-living adjustmentliving adjustment



Beginning in 2014, the Beginning in 2014, the maximum maximum waiting periodwaiting period an employer can an employer can impose upon an employee is impose upon an employee is 90 days90 days. .

Beginning on or after January 1, 2014, Beginning on or after January 1, 2014, plans and insurers will be required to plans and insurers will be required to eliminateeliminate restrictions on plan entry restrictions on plan entry based on a based on a pre-existing conditionpre-existing condition, and , and they will be prohibited from excluding they will be prohibited from excluding coverage for a pre-existing condition. coverage for a pre-existing condition.


Also Coming Up in 2014:Also Coming Up in 2014:Patient ProtectionsPatient Protections

Wellness incentive limit raised from 20% to Wellness incentive limit raised from 20% to 30%30% Allows an incentive such as premium Allows an incentive such as premium

reduction for achieving a health reduction for achieving a health standardstandard

Must be alternative means of Must be alternative means of qualifyingqualifying

Up to 50% for wellness programs for Up to 50% for wellness programs for tobaccotobacco


Issues - ViabilityIssues - Viability If enrolling in a health care plan is viewed as If enrolling in a health care plan is viewed as

optional for U.S. citizens because of the low optional for U.S. citizens because of the low penalties, those who consider themselves penalties, those who consider themselves healthy are less likely to enroll because it is not healthy are less likely to enroll because it is not in their economic best interest.in their economic best interest.

Much of the law’s success depends on having Much of the law’s success depends on having young, healthy people sign up for insurance.young, healthy people sign up for insurance. They have much lower health care expenses.They have much lower health care expenses. Their insurance premiums help offset the higher Their insurance premiums help offset the higher

medical expenses of older, sick people in a health medical expenses of older, sick people in a health plan.plan.


Issues - ConflictIssues - Conflict

State ExchangesState Exchanges Few states have proceeded with their Few states have proceeded with their

implementation activities.implementation activities. Many states have not taken any action Many states have not taken any action

toward the establishment of a state toward the establishment of a state health insurance exchange.health insurance exchange.


Issues - EnforcementIssues - Enforcement IRS EnforcementIRS Enforcement

Since the decision labeled the penalty a tax, it will Since the decision labeled the penalty a tax, it will be collected by the IRS.be collected by the IRS.

The IRS may have few options for collection The IRS may have few options for collection because:because:

Congress restricted the agency’s collection Congress restricted the agency’s collection authority,authority,

The IRS cannot file a tax lien against individuals The IRS cannot file a tax lien against individuals who do not comply with the health insurance who do not comply with the health insurance mandate, andmandate, and

The IRS can only collect the money by withholding The IRS can only collect the money by withholding it from tax refunds or Social Security checks.it from tax refunds or Social Security checks.


Hot Button Issues For Hot Button Issues For 20132013


The Family Medical Leave The Family Medical Leave ActAct


New FMLA RulesNew FMLA Rules

Final regulations issued February 5, Final regulations issued February 5, 2013,implementing National Defense 2013,implementing National Defense Authorization Act of 2010Authorization Act of 2010

Relating to military leavesRelating to military leaves Other changes to 2009 Regulations Other changes to 2009 Regulations

include intermittent leaveinclude intermittent leave Effective March 8, 2013Effective March 8, 2013


New FMLA Regulations New FMLA Regulations (Military)(Military)


New FMLA RegulationsNew FMLA Regulations

Use smallest increments of time as used Use smallest increments of time as used for other types of leavefor other types of leave


New Guidance on CareNew Guidance on CareFor Adult ChildFor Adult Child

Child must:Child must: have an ADA-defined disability have an ADA-defined disability be incapable of self-care due to that disability be incapable of self-care due to that disability be in need of care because of the serious health be in need of care because of the serious health

conditioncondition Age child became disabled does not matterAge child became disabled does not matter


New FMLA Regulations – Next New FMLA Regulations – Next Steps Steps

Employers covered by the FMLA should do the following:

Update FMLA policies in accordance with the new rule.

Replace the current FMLA poster with new poster. Make sure all FMLA Fact Sheets are up to date. Use the new DOL notification and certification

forms. Insure that leave administrators are familiar with

the changes that took effect March 8.


Immigration Non-ComplianceImmigration Non-Compliance


Immigration ReformImmigration Reform

The political climate makes The political climate makes legislation more likely than in prior legislation more likely than in prior yearsyears

Any “reform” will include greater Any “reform” will include greater burdens on employers to verify burdens on employers to verify employment eligibility and increased employment eligibility and increased penalties for hiring undocumented penalties for hiring undocumented workersworkers


Common I-9 Errors - Common I-9 Errors - EmployeesEmployees

Did employee sign and date?Did employee sign and date?

Did employee check 1 of the 4 boxes?Did employee check 1 of the 4 boxes?

If permanent resident, did employee If permanent resident, did employee write in his Alien Registration Number?write in his Alien Registration Number?

If employee has temporary work If employee has temporary work authorization, did he write his authorization, did he write his immigration number and the expiration immigration number and the expiration date?date?


Common Errors - EmployersCommon Errors - Employers

Form calls for document name, issuing Form calls for document name, issuing authority, document number and expiration authority, document number and expiration date (if any).date (if any).

You must write “SS card/SSA/123-45-6789.You must write “SS card/SSA/123-45-6789. Write in first day worked.Write in first day worked. Sign and date.Sign and date. Write full company name (no abbreviations) Write full company name (no abbreviations)

Can use a stamp for this.Can use a stamp for this. Write physical address vs. P. O. box number.Write physical address vs. P. O. box number.


ICE PenaltiesICE Penalties

I-9 Penalties for Substantive and Uncorrected I-9 Penalties for Substantive and Uncorrected Technical Violations for each I-9 Form:Technical Violations for each I-9 Form:

Standard Fine AmountStandard Fine Amount

Substantive Substantive Verification Verification ViolationsViolations

11stst Offense Offense

$110-$1100$110-$1100

22ndnd Offense Offense

$110-$1100$110-$1100

33rdrd Offense + Offense +

$110-$1100$110-$1100

0%-9%0%-9% $110$110 $550$550 $1100$1100

10%-19%10%-19% $275$275 $650$650 $1100$1100

20%-29%20%-29% $440$440 $750$750 $1100$1100

30%-39%30%-39% $605$605 $850$850 $1100$1100

40%-49%40%-49% $770$770 $950$950 $1100$1100

50% or more50% or more $935$935 $1100$1100 $1100$1100


Immigration To Do List for Immigration To Do List for EmployersEmployers

Enroll in E-Verify at: Enroll in E-Verify at:

https://e-verify.uscis.gov/enroll/StartPage.aspx?JS=YES https://e-verify.uscis.gov/enroll/StartPage.aspx?JS=YES Schedule I-9 training because the E-Verify system is only as Schedule I-9 training because the E-Verify system is only as

good as the information collected on your I-9 forms – must be good as the information collected on your I-9 forms – must be retained as before; retained as before;

Use new I-9 Form issued March 8, 2013;Use new I-9 Form issued March 8, 2013; Conduct I-9 Audit for all past hires - with professional signoff Conduct I-9 Audit for all past hires - with professional signoff

that you are currently in compliance. that you are currently in compliance.


Refusal to Receive Flu ShotRefusal to Receive Flu Shot

Chenzira v. Cincinnati Children’s HospitalChenzira v. Cincinnati Children’s Hospital (2012)(2012)

Employee is a vegan; refuses mandatory flu Employee is a vegan; refuses mandatory flu shot based on religious beliefshot based on religious belief

Ct: duty to accommodate employee’s Ct: duty to accommodate employee’s religious beliefsreligious beliefs


Americans With Disabilities Americans With Disabilities ActAct


EEOC Issues ADA Guidance for EEOC Issues ADA Guidance for Veterans With DisabilitiesVeterans With Disabilities

Preventing disability discriminationPreventing disability discrimination

Accommodation of veterans with disabilitiesAccommodation of veterans with disabilities

eeoc.gov/eeoc/publications/ada_veterans_employers.cfmeeoc.gov/eeoc/publications/ada_veterans_employers.cfm


Wellness Program FitsWellness Program FitsADA Safe HarborADA Safe Harbor

Seff v. Broward CountySeff v. Broward County (11(11thth Cir. 2012) Cir. 2012)

Employees who declined to participate in Employees who declined to participate in wellness program charged $20/pay periodwellness program charged $20/pay period

Ct: No violation of ADA; safe harbor for Ct: No violation of ADA; safe harbor for insurance plansinsurance plans


ADA Requires Transfer to ADA Requires Transfer to Vacant PositionVacant Position

EEOC v. United AirlinesEEOC v. United Airlines 7 7thth Cir. 2012 Cir. 2012

Employee can not perform own jobEmployee can not perform own job

Ct: Not sufficient to let employee compete for Ct: Not sufficient to let employee compete for vacant job; duty of accommodation requires vacant job; duty of accommodation requires transfertransfer

But don’t have to ignore union contractBut don’t have to ignore union contract


A New Day At The Equal A New Day At The Equal Employment Opportunity Employment Opportunity

Commission (EEOC)Commission (EEOC)


EEOCEEOCIncreased Charges & LawsuitsIncreased Charges & Lawsuits

99,412 FY 2012 (Most Ever)99,412 FY 2012 (Most Ever)

580 “Systemic” Matters580 “Systemic” Matters

122 Lawsuits Filed122 Lawsuits Filed

$365 Million Obtained$365 Million Obtained


Systemic ChargesSystemic Charges

Employment TestsEmployment Tests

Leave and Termination PoliciesLeave and Termination Policies

Criminal Background ChecksCriminal Background Checks

Credit ChecksCredit Checks


What Now?What Now?

Less Experienced Investigators – But Less Experienced Investigators – But More AggressiveMore Aggressive

Closer Review of Position StatementsCloser Review of Position Statements

Hospitals Quilty Until Proven Hospitals Quilty Until Proven OtherwiseOtherwise

More On-SitesMore On-Sites


EEOC’s Strategic Action PlanEEOC’s Strategic Action Plan


Nationwide PrioritiesNationwide Priorities

Eliminating Systemic Barriers in Recruitment and Eliminating Systemic Barriers in Recruitment and HiringHiring

Exclusionary Policies and PracticesExclusionary Policies and Practices

Channeling/Steering of Individuals Into Specific Channeling/Steering of Individuals Into Specific Jobs Due to Their Status in a Particular GroupJobs Due to Their Status in a Particular Group

Restrictive Application Processes (i.e., pre-Restrictive Application Processes (i.e., pre-employment tests, background screens, date of employment tests, background screens, date of birth screens and on-line applications).birth screens and on-line applications).


Emerging IssuesEmerging Issues

ADAAA – Proper Application of Defenses such as ADAAA – Proper Application of Defenses such as Undue Hardship, Direct Threat and Business Undue Hardship, Direct Threat and Business NecessityNecessity

LGBT (Lesbian, Gay, Bisexual and Transgender LGBT (Lesbian, Gay, Bisexual and Transgender Individuals) – Coverage Under Title VII Sex Individuals) – Coverage Under Title VII Sex Discrimination ProvisionsDiscrimination Provisions

Accommodating Pregnancy – Women Who Are Accommodating Pregnancy – Women Who Are Forced Into Unpaid Leave After Being Denied Forced Into Unpaid Leave After Being Denied Accommodations Routinely Provided to Similarly Accommodations Routinely Provided to Similarly Situated EmployeesSituated Employees


Question #1Question #1


Medical LeaveMedical Leave Facially neutral policies that may violate Facially neutral policies that may violate

the ADA:the ADA: Strict leave of absence policies that do not Strict leave of absence policies that do not

provide for exceptions or any provide for exceptions or any accommodationsaccommodations

Policies that consider additional leave but Policies that consider additional leave but limit the amount of additional leavelimit the amount of additional leave

Policies that result in automatic termination Policies that result in automatic termination at the exhaustion of FMLA, despite a need at the exhaustion of FMLA, despite a need for additional treatment or recoveryfor additional treatment or recovery


EEO Action PlanEEO Action Plan Review Review hiring/recruitment policieshiring/recruitment policies concerning concerning

requirements such as high school diplomas, criminal requirements such as high school diplomas, criminal background checks, credit histories, applicant testing.background checks, credit histories, applicant testing.

Review Review EEO statementsEEO statements (is it broad enough?) (is it broad enough?) TrainingTraining and practices concerning and practices concerning ADA ADA

accommodation, accommodation, pregnancypregnancy accommodation, accommodation, leave leave practicespractices in conjunction with FMLA. in conjunction with FMLA.

Review Review training methodstraining methods and and policiespolicies concerning concerning discriminationdiscrimination and and harassmentharassment in the workplace. in the workplace.

Revisit whether you are currently Revisit whether you are currently complyingcomplying with with OFCCP/affirmative action requirementsOFCCP/affirmative action requirements and have and have current written affirmative action plans.current written affirmative action plans.


Failure to Accommodate Failure to Accommodate Pregnant Employee May Pregnant Employee May

Violate Title VIIViolate Title VII Chapter 7 Trustee v. Gate Gourmet, Inc. 11Chapter 7 Trustee v. Gate Gourmet, Inc. 11 thth

Cir. 2012Cir. 2012 Pregnant employee’s doctor imposed Pregnant employee’s doctor imposed

restrictions; supervisor says no light duty; restrictions; supervisor says no light duty; fires herfires her

Ct: have to at least consider whether light Ct: have to at least consider whether light duty work availableduty work available


Supervisor Status Under Title Supervisor Status Under Title VIIVII

Vance v. Ball State UniversityVance v. Ball State University

U.S. Supreme Court will decide U.S. Supreme Court will decide whether someone who directs whether someone who directs employees’ work, but lacks other employees’ work, but lacks other authority, is a supervisorauthority, is a supervisor

Implications for harassment casesImplications for harassment cases


Gay MarriageGay Marriage

2013 – U.S. Supreme Court will 2013 – U.S. Supreme Court will consider two cases on consider two cases on constitutionality of gay marriageconstitutionality of gay marriage

Result could have implications for Result could have implications for employers regarding benefits and employers regarding benefits and other employment issuesother employment issues


Tracking EmployeesTracking Employees

Tracking Through Technology Tracking Through Technology • Laws are not keeping upLaws are not keeping up

Reasonable expectation of privacyReasonable expectation of privacy Policies define expectationsPolicies define expectations

• Notify of expectations re: e-mail, texting, Notify of expectations re: e-mail, texting, data etc.data etc.


Video CamerasVideo Cameras

Electronic Communications Electronic Communications Privacy ActPrivacy Act• Video is generally permissibleVideo is generally permissible

Size of camera Size of camera Reasonable expectation of privacyReasonable expectation of privacy Announce monitoring Announce monitoring

• No audio recordingsNo audio recordings


Social MediaSocial Media

Ignorance is blissIgnorance is bliss• Knowing personal informationKnowing personal information

Potential ADA or GINA claimPotential ADA or GINA claim

Stored Communications ActStored Communications Act

Invasion of Privacy claimsInvasion of Privacy claims


Social Media PoliciesSocial Media Policies NLRB Memos & OpinionsNLRB Memos & Opinions

• Reasonably chill employees’ Section Reasonably chill employees’ Section 7 rights 7 rights Right to complain about terms and Right to complain about terms and

conditions of employmentconditions of employment• wageswages• hourshours• disciplinary actiondisciplinary action


The New NLRBThe New NLRB5 NLRB Nominations Go To Full 5 NLRB Nominations Go To Full

SenateSenate Mark Gaston Pearce (Chairman – D)Mark Gaston Pearce (Chairman – D)

Richard Griffin (Recess – D)Richard Griffin (Recess – D)

Sharon Black (Recess – D)Sharon Black (Recess – D)

Harry Johnson III (R)Harry Johnson III (R)

Phillip Miscimarra (R)Phillip Miscimarra (R)


NLRBNLRBExamining Non-Union Examining Non-Union

Workplace IssuesWorkplace Issues At Will DisclaimersAt Will Disclaimers

Social Media TrstrictionsSocial Media Trstrictions

Employee Access RulesEmployee Access Rules

Employee Behavior PoliciesEmployee Behavior Policies


Cases Answering Question Cases Answering Question #2#2

American Red Cross of Arizona-AOG found American Red Cross of Arizona-AOG found unlawful an at-will acknowledgement form unlawful an at-will acknowledgement form stating “the at-will employment stating “the at-will employment relationship cannot be amended, modified relationship cannot be amended, modified or altered in any way.”or altered in any way.”

Rocha Transportation – NLRB GC found Rocha Transportation – NLRB GC found unlawful – “no representative of the unlawful – “no representative of the company has any authority to enter into company has any authority to enter into an employment agreement that is contrary an employment agreement that is contrary to the employment at-will relationship.”to the employment at-will relationship.”


Cases Answering Question Cases Answering Question #2#2

St. John’s Medical Center – NLRB found St. John’s Medical Center – NLRB found unlawful a rule which prohibited off-duty unlawful a rule which prohibited off-duty employees from entering the workplace except employees from entering the workplace except to attend employer-sponsored events (similar to attend employer-sponsored events (similar case concerning employer-related business).case concerning employer-related business).

Karl Knauz Motors – Found unlawful rule which Karl Knauz Motors – Found unlawful rule which stated – “No one should be disrespectful or use stated – “No one should be disrespectful or use profanity or any other language which injures profanity or any other language which injures the image or reputation of the dealership.”the image or reputation of the dealership.”


InternshipsInternships


Interns Compensated?Interns Compensated? The following The following six criteriasix criteria must be must be

applied when making this applied when making this determination:determination: The internship is The internship is similarsimilar to to trainingtraining

given in an given in an educational environmenteducational environment, , even though it includes the actual even though it includes the actual operation of the employer’s business;operation of the employer’s business;

The internship is The internship is for the benefit offor the benefit of the the internintern;;

The intern The intern does notdoes not displacedisplace regular regular employeesemployees, but works under close , but works under close supervision of existing staff;supervision of existing staff;


InternshipsInternships The The employeremployer providing the training derives providing the training derives no no

immediate advantageimmediate advantage from the intern’s from the intern’s activities and its operations may actually be activities and its operations may actually be impeded by the intern;impeded by the intern;

There is There is no guaranteeno guarantee of of jobjob at the conclusion of at the conclusion of the internship; andthe internship; and

The employer and the intern both understand that The employer and the intern both understand that the intern is the intern is not entitled to wagesnot entitled to wages for for tasks tasks performedperformed during the internship. during the internship.

If these factors are met, there is If these factors are met, there is no no employment relationshipemployment relationship under the FLSA, under the FLSA, and the Act’s and the Act’s minimum wageminimum wage and and overtime provisionsovertime provisions do not apply.do not apply.


Employee VolunteersEmployee Volunteers Under the FLSA, Under the FLSA, employeesemployees may may not not

volunteervolunteer services to services to for-for-profit privateprofit private sector employers. sector employers.

On the other hand, in the vast majority On the other hand, in the vast majority of circumstances, of circumstances, individuals can individuals can volunteervolunteer services to services to public sector public sector employersemployers. .

Exception - public sector employers Exception - public sector employers may not allow employees to volunteer may not allow employees to volunteer additional time to perform normal job additional time to perform normal job tasks without compensation.tasks without compensation.


Employee VolunteersEmployee Volunteers

Activity reasonably regarded as Activity reasonably regarded as charitable or civic (5K Run)charitable or civic (5K Run)

Occurs outside work hoursOccurs outside work hours

No obligation to participateNo obligation to participate

No expectation of compensationNo expectation of compensation

Activity different from normal dutiesActivity different from normal duties


FLSA: Mobile Technology Blurs FLSA: Mobile Technology Blurs Work And Non-work HoursWork And Non-work Hours

Employees "Suffered or Permitted" to Employees "Suffered or Permitted" to work: Work not requested but work: Work not requested but suffered or permitted to be suffered or permitted to be performed is work time that must be performed is work time that must be paid for by the employer. paid for by the employer. For example, responding to emails, text For example, responding to emails, text

messages or phone calls.messages or phone calls.


FLSA: Mobile Technology Blurs FLSA: Mobile Technology Blurs Work And Non-work HoursWork And Non-work Hours

In In Agui v. T-Mobile, Inc.,Agui v. T-Mobile, Inc., non-exempt non-exempt salespersons sued claiming they were salespersons sued claiming they were required to respond to emails after hours required to respond to emails after hours while off the clock (the suit settled).while off the clock (the suit settled).

In In Allen Allen and other similar suits, courts will and other similar suits, courts will likely focus on whether the time spent likely focus on whether the time spent checking mobile devices ischecking mobile devices is de de minimusminimus and whether doing so qualifies as and whether doing so qualifies as a “principle activity.” a “principle activity.”


USERRAUSERRA The Uniformed Services Employment The Uniformed Services Employment

and Reemployment Rights Act and Reemployment Rights Act (USERRA) protects service members' (USERRA) protects service members' reemployment rights when returning reemployment rights when returning from a period of service in the from a period of service in the uniformed services, including those uniformed services, including those called up from the reserves or called up from the reserves or National Guard, and prohibits National Guard, and prohibits employer discrimination based on employer discrimination based on military service or obligation. military service or obligation.


One of the major provisions of One of the major provisions of USERRA is that there is no longer any USERRA is that there is no longer any differentiation between voluntary and differentiation between voluntary and involuntary service. involuntary service.

The term “service in the uniformed The term “service in the uniformed services” means the performance of services” means the performance of duty on aduty on a voluntaryvoluntary or involuntary or involuntary basis in a uniformed service…basis in a uniformed service…

USERRAUSERRA


Motivation and SupportMotivation and Support


Let’s Start With YouLet’s Start With You

Save LivesSave Lives

Save FamiliesSave Families

Save FinancesSave Finances

Build HopeBuild Hope


First – Help YourselfFirst – Help Yourself

RecalibrateRecalibrate

Start Day Off RightStart Day Off Right

Health = HappinessHealth = Happiness

Love/Respect For Family/FriendsLove/Respect For Family/Friends

Be A Friend To YourselfBe A Friend To Yourself


First – Help YourselfFirst – Help Yourself

Set Positive GoalsSet Positive Goals

Have Something To Look Forward ToHave Something To Look Forward To

Hide SometimesHide Sometimes

Let Work Glorify GodLet Work Glorify God


Final ThoughtsFinal Thoughts

It Starts At HomeIt Starts At Home


Questions?Questions?

Constangy, Brooks & Smith, LLP Jeffery L. Thompson Constangy, Brooks & Smith, LLP Telephone:...

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