The Full Story on Same Sex Marriage Benefits for Employers and Federal Contractors

THE FULL STORY ON SAME SEX MARRIAGE BENEFITS

FOR EMPLOYERS AND FEDERAL CONTRACTORS

AUGUST 13, 2015

John C. Fox, Esq. Fox, Wang & Morgan P.C. 315 University Avenue Los Gatos, CA 95030 Phone: (408) 844-2360

© 2015 Fox, Wang & Morgan P.C.

Candee J. Chambers, SPHR, Sr. CAAP VP - Compliance & Partnerships Direct Employers Association 9002 N. Purdue Road, Suite 100 Indianapolis, IN 46268 Phone: (317) 874-9052

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AGENDA

Abbreviation Key……………………………….............. p. 3

I.  Background............................................................ p. 4

II.  Basic Definitions……………………..…………….. p. 5

III. The Law……………………………………………… p.11

IV. The Questions…………………………………….… p.16

V.  The Four Sexual Orientation Scenarios: Which Is Your Scenario?………………………….. p.18

VI. Bonus (Transgender) Issues…………………....... p.43

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ABBREVIATION KEY

Ø  DOL = U.S. Department of Labor Ø  Ees = Employees Ø  EO = Executive Order Ø  FR = Federal Register Ø  GI = Gender Identity Ø  IC = Independent Contractor Ø  K = Contract Ø  Kor = Contractor Ø  LGBT = Lesbian, Gay, Bisexual, &/or Transgender Ø  NPRM = Notice of Proposed Rulemaking Ø  SCOTUS = Supreme Court of The United States Ø  SO = Sexual Orientation Ø  Title VII = Title VII of the Civil Rights Act of 1964

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A.  December 9, 2014 OFCCP Final Rule re LGBT became legally effective.

B.  April 10, 2015 FAR Council Issued “Interim Final” Rule re LGBT and sought comment on definitions of “Gender Identity” and “Sexual Orientation” (not contained in OFCCP Final Rule)

−  Comments from public due 9/23/2016

I.  BACKGROUND

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A.  OFCCP’s FAQs supply the following definitions:

•  “Gender identity: The term ‘gender identity’ refers to one’s internal sense of one’s own gender. It may or may not correspond to the sex assigned to a person at birth, and may or may not be made visible to others.”

•  “Sexual orientation: ‘Sexual orientation’ refers to an individual’s physical, romantic, and/or emotional attraction to people of the same and/or opposite gender. Examples of sexual orientations include straight (or heterosexual), lesbian, gay, and bisexual.

II.  BASIC DEFINITIONS

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B.  Other definitions:

•  “Sexual Orientation” is generally associated with gay and lesbian issues. “Gender Identity” is generally associated with transgender issues.

• Note: OFCCP’s working definition is narrow and does not necessarily cover and protect “Gender Expression”

•  As taken from the Human Rights Campaign.

II.  BASIC DEFINITIONS (CON’T)

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•  Sexual orientation

“Sexual orientation is the preferred term used when referring to an individual's physical and/or emotional attraction to the same and/or opposite gender. ‘Gay,’ ‘lesbian,’ ‘bisexual’ and ‘straight’ are all examples of sexual orientations. A person's sexual orientation is distinct from a person's gender identity and expression.”

•  Gender identity

“The term ‘gender identity,’ distinct from the term ‘sexual orientation,’ refers to a person's innate, deeply felt psychological identification as a man, woman or some other gender, which may or may not correspond to the sex assigned to them at birth (e.g., the sex listed on their birth certificate).”

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•  Gender expression

“Gender expression refers to all of the external characteristics and behaviors that are socially defined as either masculine or feminine, such as dress, grooming, mannerisms, speech patterns and social interactions. Social or cultural norms can vary widely and some characteristics that may be accepted as masculine, feminine or neutral in one culture may not be assessed similarly in another.”

•  Transgender

“Transgender – or trans – is an umbrella term for people whose gender identity or expression is different from those typically associated with the sex assigned to them at birth (e.g., the sex listed on their birth certificate). Not all people who consider themselves (or who may be considered by others as) transgender will undergo a gender transition.”

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•  Gender transition

“Transitioning is the process some transgender people go through to begin living as the gender with which they identify, rather than the sex assigned to them at birth. This may or may not include hormone therapy, sex reassignment surgery and other medical procedures.”

•  Cross-dresser

“Cross-dressing refers to people who wear clothing and/or makeup and accessories that are not traditionally associated with their biological sex. Cross-dressers are sometimes called ‘transvestites,’ but that term is considered pejorative.”

“Many people who cross-dress are comfortable with their assigned sex and generally do not wish to change it. Cross-dressing is a form of gender expression that is not necessarily indicative of a person’s gender identity or sexual orientation.”

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•  Gender dysphoria

“Gender dysphoria is a psychological diagnosis recognized by the American Psychiatric Association (APA). This disorder is marked by clinically significant distress caused by a marked difference between the individual’s expressed/experienced gender and the gender others would assign him or her.”

“In 2012, the APA announced that the term ‘gender identity disorder’ would be replaced by the more neutral term ‘gender dysphoria’ in the latest version of the Diagnostic and Statistical Manual of Mental Disorders (DSM-V).”

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III.  THE LAW

A.  EXECUTIVE ORDER 11246, as amended:

“The contractor will not discriminate against any employee or applicant for employment because of race, color, religion, sex, sexual orientation, gender identity, or national origin.” Section 202(1) of Executive Order 11246, as amended (2014)

B.  EXECUTIVE ORDER RULE, as amended

“The Kor will not discriminate against any employee or applicant for employment because of race, color, religion, sex, gender identity, sexual orientation, or national origin.” 41 CFR § 60-1.4(a)(1) [2014] (the EEO clauses to EO 11246)

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SURVEY QUESTION 1:

Are you a federal contractor or subcontractor with contracts with federal Executive Branch agencies > $10,000 (aggregated) in any rolling 12 month period?

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C.  TITLE VII

“It shall be an unlawful employment practice for an employer - (1) to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin; or

(2) to limit, segregate, or classify his employees or applicants for employment in any way which would deprive or tend to deprive any individual of employment opportunities or otherwise adversely affect his status as an employee, because of such individual’s race, color, religion, sex, or national origin.” SEC. 2000e-2 (a)

III.  THE LAW (CON’T.)

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SURVEY QUESTION 2: Are you an employer with 15 or more employees and which sells or buys across state lines?

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D.  SEXUAL ORIENTATION Case Decision of Note and Questions:

• EEOC Administrative Decision: Complainant v. Anthony Foxx (Secretary U.S. Department of Transportation), EECX Appeal No. 0120133080 (EEOC July15,2015)

•  Does E.O. 11246 now require covered federal contractors and subcontractors to provide benefits to lawfully married same-sex couples equal to those the Kor supplies to opposite sex couples who are lawfully married?

•  Similarly does Title VII now require covered employers to provide benefits to lawfully married same-sex couples equal to those the Kor supplies to opposite sex couples who are lawfully married?

III.  THE LAW (CON’T.)

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E.  GENDER IDENTITY Case Decisions of Note and Questions:

• Macy v. Holder (Attorney General of The United States), EECX Appeal No. 0120120821, 2012 WL 1435995 (EEOC Apr. 20, 2012) • Lusardi v. McHugh (Secretary of the Army),

EECX Appeal No. 0120133395 (EEOC March 27, 2015): •  Does EO11246/Title VII now require covered federal Kors/

employers to provide Sex [re-]Assignment Surgery (“SAS”) to transgender employees?

IV. THE QUESTIONS

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E.  GENDER IDENTITY (con’t):

•  Does a biological male transitioning to become a woman have a legal right to enter the company’s female bathroom or the female shower room of a corporate exercise facility during the year before SAS?

•  What about vice-versa? Biological female transitioning to become a man?

IV.  THE QUESTIONS (CON’T)

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There are four different scenarios as to the question concerning benefits for same sex couples. Three Scenarios address the possibility that lawfully married same-sex couples may be legally entitled to employment benefits equal to those the Kor/Company provides to lawfully married opposite sex couples. The fourth Scenario addresses the possibility that a closely head small corporation may be exempt from sexual orientation law prohibitions if the company’s owners hold religious beliefs which do not recognize same sex marriage.

Here is a short summary followed by detailed discussions:

V. THE FOUR SEXUAL ORIENTATION SCENARIOS: WHICH IS YOUR SCENARIO?

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Scenario 1:

Federal Law: Executive Order 11246 or Title VII may provide same sex couples a right to benefits -- but read below in greater detail to see how messy (technical legal term) this conclusion is; and/or

V.  THE FOUR SEXUAL ORIENTATION SCENARIOS (CON’T)

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Scenario 2:

State Law: State laws prohibiting sexual orientation discrimination and applicable to the employer may provide lawfully married same sex couples a right to dependent/family benefits -- but read below to see what a “checkerboard” picture of legal obligation emerges; and/or


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Scenario 3:

Contract Based: The employer’s own benefits policy and/or plan may provide by K that an employee lawfully married to a same-sex spouse enjoys a right to dependent and/or family benefits (see “Eligibility” section of your company policy or benefit/privileges plan).


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Scenario 4:

Religious Exemption: Even assuming coverage, the religious beliefs of the owners of a small closely held corporation that same-sex marriage violates their religious beliefs may immunize the owners from the dictates of sexual orientation non-discrimination requirements pursuant to either or both the Religious Freedom Restoration Act (“RFRA”), ala the U.S. Supreme Court’s recent decision in Burwell v. Hobby Lobby, 573 U.S. ____ (2014), or perhaps even pursuant to the First Amendment’s Freedom of Religion clause.


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SURVEY QUESTION 3:

Is your company a small closely-held corporation whose owner(s) believes his/her religion does not recognize same sex marriage?

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We now discuss each of these four scenarios in greater detail:

Scenario 1:

The Easy Option: The employer could be (a) a covered federal contractor and (b) could conclude that OFCCP’s Final LGBT Rule is lawful.

If so, Executive Order 11246 would obligate this federal contractor to supply the same benefits to lawfully married same-sex couples which the contractor makes available to lawfully married opposite-sex couples (because it believed itself obligated by law to do so).


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Scenario 1 (con’t):

−  Employer benefit plans typically provide dependent/family benefits to employees who are lawfully “married,” AND the effect of (i) the 30 states and two territories (Guam and the District of Columbia) which recognize same-sex marriage by operation of state law and (ii) the U.S. Supreme Court’s recent decision in Obergefell et al. v. Hodges, Director, Ohio Department of Health, et al., 576 U.S. _____ (2015) is that these 32 local statutes and the U.S. Constitution now legally equate same-sex marriage with opposite-sex marriage in all 50 states and in all 15 U.S. Territories.


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−  Granting dependent/family benefits made available to employees lawfully married to opposite-sex spouses while denying those same benefits to employees lawfully married to same-sex spouses treats the employee married to a same-sex spouse differently based solely on his/her “sexual orientation.”

NOTE: SCOTUS decision in Obergefell is relevant to the same-sex benefit issue only because it expanded from 32 to 65 the number of states and federal territories of the United States willing to issue marriage licenses to same sex couples.

So a lot more same-sex marriages are now likely to occur in the United States.


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NOTE: There are 15 federal territories in “the United States,” OFCCP’s Rules, however, cover only 7 of them:

1)  The District of Columbia 2)  The Virgin Islands 3)  The Commonwealth of Puerto Rico 4)  Guam 5)  American Samoa 6)  The Commonwealth of the Northern Mariana Islands 7)  and Wake Island

See 41 CFR Section 60-1.3 (second definition of “United States:” there is a misprint. Really! No Kidding!)


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Scenario 2:

The “Doubting Thomas” Checkerboard Option: If:

(a) a federal contractor (i) does NOT believe that the OFCCP Final LGBT Rule is lawful and (ii) does not believe that EO 11246 has always made SO discrimination unlawful, AND

(b) does NOT believe that Title VII has always made SO discrimination unlawful,

This Kor/Er would nonetheless have to provide benefits to lawfully married same sex couples on the same basis it provides benefits to lawfully married opposite-sex couples (if it does) in the 22 States, the District of Columbia and Puerto Rico which make sexual orientation discrimination unlawful.


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Here are the 22 states which currently make sexual orientation discrimination unlawful:

1. California 8. Maine 15. Nevada

2. Colorado 9. Maryland 16. New Hampshire

3. Connecticut 10. Massachusetts 17. New Jersey

4. Delaware 11. Minnesota 18. Rhode Island

5. Hawaii 12. New Mexico 19. Utah

6. Illinois 13. New York 20. Vermont

7. Iowa 14. Oregon 21. Washington

22. Wisconsin


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The 22 States and 2 Federal Territories Which Make SO Employment Discrimination Unlawful in the Private Sector


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Scenario 2 (cont’):

It is not just federal law which governs employers. State law, too, can limit corporate discretion to act as the company pleases.

In these 22 states and in the District of Columbia and Puerto Rico, the company operates at its legal risk to deny dependent/family benefits to an employee lawfully married to a same-sex spouse if the employer made those same benefits available to employees lawfully married to opposite-sex spouses.

Why? The reason for denial would be based on the sexual orientation of the employee married to a same-sex spouse… employment discrimination these 22 states and the District of Columbia and Puerto Rico currently make unlawful.


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In those states in which sexual orientation discrimination is lawful (and if one believed federal law did not make sexual orientation discrimination unlawful), the employer would be free to deny dependent/family benefits to an employee working in that state who was lawfully married to a same-sex spouse EVEN THOUGH the employer nonetheless makes available those same benefits to an employee in that state lawfully married to an opposite-sex spouse.

This is because while the same-sex spouses are lawfully married, there is no legal prohibition in this Scenario making unlawful the employer’s discrimination based on the sexual orientation of its employee lawfully married to a same-sex spouse.


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Scenario 3:

The “Least Common-Denominator” Option: This option would adopt nationwide the toughest requirement the employer will face… in that way the employer is never wrong and has a uniform policy which is easier to administer than to have several different policies addressing the same employment benefit or privilege.

This policy determination allows a company to create uniform policies, rights and administration nationwide without the fear of misapplying the company’s policy in the “odd ball” state or states which require some special rule different from the other states in which the company has employees.


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Mechanically, companies would create BY CONTRACT with it’s employees such a uniform policy nationwide by creating the right to dependent/family benefits for employees lawfully wed to same sex spouses.

The employer would simply want to be careful to make that contract at least as generous as the most onerous and demanding requirement of the two federal and the 22 state sexual orientation non-discrimination laws the company determines are applicable to it.

Most Fortune 500 companies have reportedly drafted the eligibility portion of their written benefits and privileges policies/plans to make benefits and privileges of employment available nationwide to lawfully married same sex couples.


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Changes you need to consider for older “progressive” same sex couples benefit policies.

1)  Reduced benefits to opposite sex couples?

Ø  Does not work in jurisdictions making sexual orientation unlawful.

2)  Higher premium charged to opposite sex couples?

Ø  Does not work in jurisdictions making sexual orientation unlawful.


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SURVEY QUESTION 4: Does your company provide benefits to same sex couples?

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SURVEY QUESTION 5: For those of you who answered “no” to Question 4, is your company now considering providing benefits to same sex couples?

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SURVEY QUESTION 6: For those of you who answered “yes” to Question 4 (you provide benefits to same-sex couples), does your company:

(a) have employees in states which permit sexual orientation discrimination; and

(b) does your company provide same sex benefits in those states?

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Scenario 4:

Small closely held “family company” owner(s) may believe that federal law now prohibits sexual orientation discrimination and their company may have employees in one or more states which make sexual orientation discrimination unlawful.

But, this owner(s) may nonetheless also believe that his/her/their company is exempt from the prohibitions of sexual orientation law because the owner(s) hold religious beliefs which do not recognize same sex marriage.

Presumably, too, this kind of employer would have a benefit plan which stated that it would render “eligible” for dependent/family benefits only those employees lawfully married to opposite sex spouses.


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Would be a true and closely watched legal “test” case. First Amendment case by itself would be a true test case. (SCOTUS has never previously accorded corporations (as opposed to individuals) religious freedom protections under The First Amendment… only pursuant to RFRA.)

Conclusion: Figure out which of the above four scenarios captures the state of affairs at your company and then write your employee benefit plans accordingly.


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Conclusion:

Most companies now believe the right thing to do is to equalize benefits for lawfully married same sex couples and end the era of supplying differential benefits depending upon the sexual orientation of the spouse to the employee.

•  Most of our clients are in Scenario 3: they don’t believe federal law protects sexual orientation but they nonetheless have decided to equalize benefits for same sex couples.


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Conclusion (con’t):

OFCCP believes all federal contractors must now equalize benefits for lawfully married same sex couples because it believes both that all same sex couples now have a right to be lawfully wed in all states and territories of the United States and that Executive Order 11246 outlaws sexual orientation discrimination as to all covered federal contractors.

OFCCP is spoiling for fight on this issue. It is primed and ready to litigate this issue. Fox prediction: OFCCP would lose a properly tried case.

This issue could arise pursuant to either individual or class-type Complaint (from an employee or Applicant) or via a routinely scheduled OFCCP Compliance Evaluation.


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Bonus Issue # 1:

Ø  GI and The Bathroom

It is currently thought that:

i.  The number of transgendered individuals in the U.S. is unknown, but is probably close to 1 million.

−  UCLA study documents at least 700,000.

ii.  Not all transgendered individuals need or want surgery to change to the opposite sex.

VI.  BONUS (TRANSGENDER) ISSUES

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Bonus Issue # 1 (con’t):

Ø  GI and The Bathroom (con’t)

iii.  Transition: Those transgendered individuals who want to undergo sex change surgery typically follow medical protocols which, among other things, typically call for cross-dressing for a period of time (usually one year) as the other sex before surgery occurs/hormone infusions occur. This one year, or so, period is known as the “transition period.” −  This advice includes a biological male who wishes to

become a woman (i.e. gender identity is as a woman) to behave/think/act like a woman, including using the Ladies restroom while in transition.

−  Vice-versa is true for a biological female who wishes to become a man.

VI.  BONUS ISSUES (CON’T)

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SURVEY QUESTION 7: If you are a woman, please answer this question:

Would you feel uncomfortable if a biological male in transition to becoming a woman entered the women’s bathroom at work while you were using it?

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SURVEY QUESTION 8: If you are a man, please answer this question:

Would you feel uncomfortable if a biological female in transition to becoming a man entered the men’s rest room at work while you were using it?

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−  See, Macy v. Holder

−  See, Lusardi v. McHugh

The REAL WORLD OF HR:

a.  Don’t fight the bathroom issue unless you are ready to defend an OFCCP lawsuit (you should win if properly tried). Thus, you will:

•  allow the biological male with a gender identity of a female to use the women’s restroom, and

•  allow the biological female with a gender identity of a male to use the male restroom.


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The REAL WORLD OF HR (con’t):

b.  -Limiting a transgendered Ee to a single-use restroom is unlawful adverse action based on “gender identity,” unless those are the only restrooms you make available to any Ees: Lusardi v. McHugh, Appeal No. 0120133395, April 1, 2015 (EEOC)

-Federal OSHA now suggests (does not require) that all employees “have access to restrooms that correspond to their gender identity”: See, “A Guide to Restroom Access for Transgender Workers.”


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c.  Prepare for transgender issues in the workplace:

•  Consider training managers, even if not all employees. (Training all employees would be the best way forward, of course.)

•  Do you refer to a biological male in transition as her/ma’am? Yes, says Lusardi. Failing to do so is unlawful harassment says Lusardi.

•  Prepare an investigation protocol (just like for sexual/racial harassment) for Ees who ridicule/demean transgender individuals. You know it is unfortunately going to happen. What will your action/reaction be?


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c.  Prepare for transgender issues in the workplace (con’t):

•  This is just another context of “respect training.”

•  Publish a policy on SO/GI. Example:

See U.S. Office of Personnel Management Policy re GI: “Guidance Regarding the Employment of Transgender Individuals in the Federal Workplace”.


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SURVEY QUESTION 9: If you are a woman, please answer this question:

Would you feel uncomfortable if a biological male in transition to becoming a woman entered the women’s shower room at your company’s exercise facility (or imaginary shower room if your company does not have one) while you were using it?

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SURVEY QUESTION 10: If you are a man, please answer this question:

Would you feel uncomfortable if a biological female in transition to becoming a man entered the men’s shower room in the company exercise facility (or imaginary shower room if your company does not have one) while you were using it?

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Bonus Issue # 2:

Ø  Does the law now require a Kor/Title VII employer to allow a biological man in transition to use the female locker room shower at the corporate fitness center? −  Mayday! Mayday!

Ø  Does the law now require a Kor/Title VII employer to allow a biological woman in transition to use the male locker room shower at the corporate fitness center? −  Well, hello, baby!

Ø  Do privacy issues arise allowing an employee to sue his/her employer for invasion of privacy? −  Is there more of an invasion of privacy in a shared

shower room than in a shared bathroom? −  Which “rattlesnake” do you want to bite you?


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Bonus Issue # 3: Do GI discrimination prohibitions require federal contractors/employers subject to EO 11246/Title VII/state law prohibitions on GI to cover the costs in their medical insurance plans for SAS (sex [re-]assignment surgery) for transgender employees?

−  Could cost up to $70,000. ($30,000 - $50,000 is a good average)

Context:

−  700,000 – 1 million transgenders in U.S.

−  Only a small percentage are type V or VI transgender

−  See Harry Benjamin scale:


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The Harry Benjamin (Now Dated) Scale: Transgender On A Spectrum

TYPE I - Transvestite (Pseudo) Gender “feeling”: Masculine. Conversion Operation (SAS): Not considered in reality. Hormone Therapy: Not considered. / Not indicated. Psychotherapy: Not wanted. Unnecessary. Remarks: Only a sporadic interest in “dressing.” Rarely has a female name when “dressed.”


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The Harry Benjamin Scale (con’t.)

TYPE II - Transvestite (Fetishistic)

Gender “feeling”: Masculine.

Conversion Operation (SAS): May consider in fantasy. Rejected.

Hormone Therapy: Rarely interested. / May help to reduce libido.

Psychotherapy: May be successful in favorable environment.

Remarks: May imitate male & female double personality with male and female names.


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TYPE III - Transvestite – True Gender “feeling”: Masculine (but with less conviction). Conversion Operation (SAS): Rejected but the idea is attractive. Hormone Therapy: Attractive as an experiment. Psychotherapy: If attempted, almost never successful as to cure. Remarks: May assume a double personality.


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TYPE IV - Transsexual – Non-Surgical

Gender “feeling”: Uncertain Wavering between TV and TS. May reject “gender.”

Conversion Operation (SAS): Attractive but not required.

Hormone Therapy: Needed for comfort & emotional balance.

Psychotherapy : Only as guidance, most often refused and unsuccessful.

Remarks : Social life dependant on circumstances. Often identifies as “transgenderist.”


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TYPE V - Transsexual - Moderate Intensity Gender “feeling”: Feminine “trapped” in a male body. Conversion Operation (SAS): Often requested. Hormone Therapy: Needed for a substitute for or preliminary to SAS. Psychotherapy: Rejected. Unless as to cure. Permissive psychological guidance. Remarks: Operation hoped for and worked for, often attained.


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TYPE VI - True Transsexual - High Intensity Gender “feeling” : Feminine. “Total psycho-sexual” inversion. Conversion Operation (SAS): Urgently requested and usually attained. Hormone Therapy: Required for partial relief only. Psychotherapy: Psychological guidance or psychotherapy for symptomatic relief only. Remarks: Despises her male sex organs. Strong danger of genital self-mutilation or even suicide if too long frustrated before SAS is attained.


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SURVEY QUESTION 11: Does your company’s medical insurance plan currently cover SAS?

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Bonus Issue # 3 (con’t): Benchmarking:

Ø  Deliver SAS medical coverage via K? 167 of Fortune 1000 companies offer SAS medical benefits.

Ø  Federal government does not require its insurers to supply SAS coverage to federal employees.

Ø  ERISA? Allows Ers to choose coverages.

Ø  Does Affordable Care Act (“Obamacare”) require coverage of SAS? No. Health and Human Services agrees.

Ø  Medicare now pays for SAS as of May 2015.

Ø  Prisoner “rights” cases pending.


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Benchmarking (con’t):

Ø  Does EO 11246 as amended require SAS medical benefits?

Ø  Does Title VII require SAS medical benefit?

Should you undertake a Young v. UPS analysis reasonable accommodation? (i.e. what is not covered?)

•  Note: “Gender dysphoria” is a medical “disorder.” See p. 10, above. ADA implications here, too.

Ø  Two state laws currently require employers to provide SAS medical benefits?

•  Washington State •  Massachusetts


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BE CAREFUL OUT THERE!

Questions?

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THANK YOU

The Full Story on Same Sex Marriage Benefits for Employers and Federal Contractors

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Transcript of The Full Story on Same Sex Marriage Benefits for Employers and Federal Contractors