HomeMy WebLinkAboutMoore 95-07-26 IN THE MATTER OF AN ARBITRATION
BETWEEN:
FANSHAWE COLLEGE OF APPLIED ARTS AND TECHNOLOGY
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
GRIEVANCE OF LINDA MOORE
BOARD OF ARBITRATION:
JANE H. DEVLIN CHAIR
HUGH JOHN COOK COLLEGE NOMINEE
JON MCMANUS UNION NOMINEE
Appearances for the College:
Robert J. Atkinson
Gail Rozell
Appearances for the Union:
Mary Anne Kuntz
Linda Moore
Jean Crawford
Louise Watt
OPSEU FILE NO.: 94E524 (Support)
DATE OF HEARING: May 31, 1995
1
The Grievor, Linda Moore, occupies a "less than 12-
month position" and claims entitlement to continued benefit
coverage for the period of up to 3 months each year during which
she is laid off. The subject of less than 12-month positions is
dealt with in a Letter of Understanding which is appended to the
collective agreement which provides as follows:
August 27, 1981
Mr. Sean O'Flynn
President
Ontario Public Service Employees Union
1901 Yonge Street
Toronto, Ontario
Dear Sir:
LESS THAN 12 MONTH POSITIONS
It is recognized that the Colleges have positions within the
bargaining unit from time to time that, because of the
nature of the service rendered, require staffing for less
than twelve (12) months a year. In such a case, where less
than full time employment is identified prior to the time of
hiring such employees, the College may effect a layoff of
such employees for a period of up to but not exceeding three
(3) months in any employment year without regard to the
provisions of the Collective Agreement. Notwithstanding the
foregoing, seniority and service shall accumulate for all
purposes under the Collective Agreement during such period
of layoff. This provision shall have no application where
the employee in lieu of layoff hereunder has been granted a
leave of absence in which case Article 14.2 shall have
application.
Prior to posting such a position, the College shall notify
the Local Union of the circumstances and, where the Local
Union requires discussion and explanation as to the basis
for such a position being reduced to less than a twelve (12)
month basis, it may request a meeting with the College, at
which time a full explanation of the circumstances
surrounding the designation of the position shall be given.
Yours truly,
A.M. Pesce,
Secretary
Staff Affairs Committee
2
Also of relevance is Article 8 of the agreement which deals with
benefits and the material portions of this Article are as
follows:
8. BENEFITS
8.1 Insurance
8.1.1 Life Insurance
During the term of this Agreement, the Colleges shall
pay one hundred per cent (100%) of the monthly premiums
of the current basic life insurance plan to provide for
term insurance coverage of $20,000.00 on the life of
the employee and including a rider providing for the
same coverage for accidental death or dismemberment.
The Colleges will provide supplementary life insurance
on a voluntary basis in units of $10,000.00 each to a
maximum of five (5) units. The Colleges shall pay
sixty per cent (60%) of the monthly premiums and the
balance of the premiums will be paid by subscribing
employees through payroll deductions.
8.1.4 Long Term Disability
The Long Term Disability Income Plan shall provide
benefits of sixty-six and two-thirds per cent (66 2/3%)
of regular earnings. Details of the Plan are published
in the revised Group Benefit Program folder.
The Colleges shall contribute seventy-five per cent
(75%) of the present premiums towards coverage of
eligible employees subject to the payment of the
balance of premiums by the employees through payroll
deduction and subject to the eligibility requirements
provided under such Plan. It is understood and agreed
that employees eligible for~and receiving disability
payments under the Plan up to September 1, 1974, shall
continue to receive benefits under the original Plan
providing for benefits of sixty per cent (60%) of
regular earnings so long as such disability continues
and subject to the provisions of the original Plan.
The Colleges shall pay one hundred percent (100%) of
the premiums payable for Life insurance, OHIP, Extended
3
Health, Dental Plan, Vision Care and Hearing Care, on
behalf of persons receiving Long Term Disability
payments, provided that such persons were subscribing
to such benefits on the date the Long Term Disability
payments commenced, if the ~erson so desires.
The Colleges will endeavour to ensure that persons
otherwise entitled to the payment of the benefits
premiums pursuant to this clause, who have not had such
payments made on their behalf from September 1, 1989,
to the ratification date of the September 1, 1989 -
August 31, 1991 Collective Agreement, shall have such
benefits reinstated effective the date of ratification
of that Collective Agreement.
8.1.5 Extended Health
The Colleges agree during the term of this Agreement,
to contribute one hundred per cent (100%) of the
present premiums towards the current Extended Health
Benefit Plan subject to the eligibility requirements
provided under such Plan.
The Plan shall be increased to provide three (3) pairs
of orthopaedic shoes per year for children under 8, two
(2) pairs per year for children from 8 to 18 years and
one (1) pair per year for adults.
8.1.6 Dental
The Colleges agree, during the term of this Agreement,
to pay one hundred per cent (100%) of the billed
premiums of an insured dental plan for coverage of
eligible full-time employees on the active payroll who
have completed their probationary period. The Plan
provides features comparable to Blue Cross Plan 7, plus
Rider 1 and Rider 2 and the ODA schedule for the
immediately preceding year, subject to the eligibility
requirements and terms and conditions of the Plan. In
addition, effective November 1, 1992, the Plan will be
amended to provide coverage on a non-cosmetic basis for
crowns and bridges to be reimbursed at fifty per cent
(50%) co-insurance, subject to the eligibility
requirements and terms and conditions of the Plan. The
combined maximum for the crowns and bridges coverage
and Blue Cross Plan 7, Rider 1 and Rider 2 shall be
$1,000.00 per person per plan year. Effective
September 1, 1993, the combined maximum shall increase
to $2,000.00.
In addition, during the term of this Agreement, the
Colleges will pay one hundred per cent (100%) of the
billed premium for an insured dental plan with features
comparable to the Blue Cross Rider 3 with $1,000.00
lifetime maximum per person.coverage regardless of age
and fifty percent.(50%) co-insurance, subject to the
eligibility requirements and terms and conditions of
the Plan.
Employees may opt out if, in their judgement, they have
full coverage through a spouse's Plan. Details of the
Plan are published in the revised Group Benefit Plan
folder.
8.1.10 vision Care
During the term of this Agreement, the Colleges agree
to pay seventy-five per cent (75%) of the premiums for
a Vision Care Plan providing coverage to a maximum of
two hundred dollars ($200.00) each two (2) years for
persons eighteen (18) years of age and over and two
hundred dollars ($200.00) each one (1) year for persons
under eighteen (18) years of age for glasses, frames,
and contact lenses, subject to eligibility requirements
and enrolment requirements, and the balance of the
premium shall be deducted by payroll deduction.
8.1.11 Hearing Care
The Colleges agree to pay seventy-five per cent (75%)
of the premiums for a Hearing Aid Plan providing
coverage to a maximum of five hundred dollars ($500.00)
each five (5) years, per person, subject to eligibility
requirements and enrolment requirements and the balance
of the premiums shall be deducted by payroll deduction.
The relevant facts are set out in an Agreement
Statement of Fact which is as follows:
1. Linda Moore has been employed at the College in a less
than 12-month position since 1987. Attached as Exhibit
6 is her original letter of appointment together with a
completed Staff Appointment form.
2. The College has had less than 12-month positions for at
least 10 years.
5
3. The consistent practice throughout this time with
respect to employees in less than 12-month positions,
including the grievor throughout her employment, is as
follows:
(a) In accordance with the letter of understanding
respecting less than 12 month positions, employees
are laid off for a period of up to three months in
each year, normally in the summer. They are
issued a Record of Employment in order to claim
and receive Unemployment Insurance benefits during
the period of their layoff. The grievor's layoff
has been in the summer.
(b) The employees do not receive any salary and are
not on the active payroll of the College during
the period of their layoff.
(c) The College does not now nor has it ever paid any
premiums for any benefits under the collective
agreement for employees in less than 12-month
positions while they are laid off under the terms
of the letter of understanding.
(d) Rather, the College has always given the employees
an option of suspending benefit coverage for the
period of the layoff or paying for the coverage
themselves (100% of the premiums). The employees
exercise their options,in respect of each benefit.
(e) If the employee electslto suspend coverage for a
particular benefit, the employee is not covered
for the period of the layoff for that particular
benefit but is signed up again for coverage upon
being recalled to work from layoff.
(f) Benefits in respect of which the employee elects
to take coverage during the period of the layoff
are paid for completely by the employee for such
period.
(g) The elections of the employees with respect to the
various benefits are entered on an Absent
Employees Benefit Election Form, an example of
which is attached as Exhibit 10.
4. Prior to filing this grievance, the practice set out in
paragraph 3 above has never been the subject of ~
complaint or grievance at Fanshawe College.
6
5. In the case of a layoff of any bargaining unit employee
in circumstances other than those contemplated in the
letter of understanding, the policy and practice at the
College is that benefit coverage ceases altogether at
the end of the month in which the layoff takes place.
Attached as Exhibit 11 is an excerpt from the Benefits
Administration Manual prepared for use by all colleges.
Apart from the Agreed Statement of Fact, the parties
advised the Board that the grievance filed by Ms. Moore initially
raised two issues; one of which concerned benefit coverage and
the other, vacation entitlement. This latter issue was resolved
by the parties on the basis of the College's agreement that the
Grievor's vacation entitlement would not be pro-rated to take
into account periods of layoff of up to 3 months contemplated by
the Letter of Understanding. According to Mr. Atkinson, the
College based its agreement on an amendment to Article 14.2 of
the collective agreement negotiated during the last round of
bargaining which provides that seniority and service shall
accumulate for any period of layoff pursuant to the Letter of
Understanding respecting less than 12-month positions. Prior to
this amendment, Article 14.2 was silent as to accumulation of
seniority and service in such circumstances. As a result, in
Ontario Public Service Employees Union and Cambrian College
January 31, 1991 (P.C. Picher (unreported)), the majority of a
Board determined that pursuant to Article 11, vacation was to be
pro-rated for employees who were actively employed for less than
12 months of the year. The majority noted that the only
exception to the pro-rating requirement was contained in Article
7
14.2 and that Article did not provide for the accumulation of
seniority and service during periods of layoff for employees
occupying less than 12-month positions. Nevertheless, as
indicated previously, in view of the recent amendment to Article
14.2, the parties agreed that pro-rating vacation entitlement is
no longer appropriate for such employees.
Turning then to the issue of benefit coverage, it was
the submission of Ms. Kuntz, on behalf of the Union, that there
is nothing in the Letter of Understanding respecting less than
12-month positions or elsewhere in the collective agreement which
would disentitle employees, such as the Grievor, to continued
benefit coverage during periods of layoff. In this regard, Ms.
Kuntz contended that while the Letter of Understanding permits
the College to layoff employees for up to 3 months each year
without regard to the~provisions of the collective agreement,
this proviso simply alleviates the necessity to follow the layoff
procedures set out in Article 15. Ms. Kuntz further contended
that the parties have drawn a distinction between employees laid
off pursuant to Article 15 and those occupying less than 12-month
positions and that for these latter employees, the Letter of
Understanding provides that seniority and service accumulate "for
all purposes" during periods of layoff. This accumulation, it
was submitted, is relevant not only to vacation entitlement but
also to benefit coverage. Moreover, Ms. Kuntz contended that
employees occupying less than 12-month positions would be
8
substantially prejudiced if they were deprived of benefit
coverage while on layoff. She further contended that it is
unreasonable for the College to require employees to pay full
premiums in order to maintain coverage during this period. In
the result, Ms. Kuntz asked the Board to find that the College
violated the collective agreement in failing to pay premiums to
maintain benefit coverage for the Grievor while on layoff.
It was the submission of Mr. Atkinson, on behalf of the
College, that as the Letter of Understanding allows the College
to layoff employees, such as the Grievor, for up to 3 months
"without regard to the provisions of the collective agreement",
except as expressly provided, the agreement has no application
during periods of layoff. Moreover, although the Letter
expressly provides that seniority and service will accumulate,
this accumulation is relevant to matters such as wages and
vacation but has no bearing on benefit coverage. Accordingly,
Mr. Atkinson contended that there is no basis to support the
Grievor's claim to continued coverage while on layoff. In the
alternative, it was submitted that benefit coverage is provided
to employees on the active payroll of the College and that, in
~'most cases, entitlement to coverage is specifically made subject
to the eligibility requirements of the plan. All of the plans in
issue provide that coverage ceases upon termination of employment
which is deemed to occur on the last day of the month that an
employee ceases to be actively at work. Moreover, although the
9
College retains the discretion to deem employment to continue in
certain circumstances, including periods of temporary layoff, Mr.
Atkinson contended that the exercise of this discretion is not
%.subject to arbitral review. In any event, it was submitted that,
in this case, the College has exercised its discretion to deem
employment to continue during periods of layoff for employees in
less than 12-month positions provided those employees pay the
premiums for continued coverage. In the result, Mr. Atkinson
contended that there is nothing in the Letter of Understanding or
the substantive provisions of the agreement which requires the
College to pay premiums to maintain benefit coverage for the
Grievor during periods of layoff.
Nevertheless, if there were any doubt about the matter,
Mr. Atkinson submitted that the Board ought to consider the past
practice of the College which did not involve the payment of
premiums for employees, such as the Grievor, while on layoff. In
response to this latter submission, Ms. Kuntz contended that the
College's past practice is not relevant given the recent
amendment to Article 14.2 of the collective agreement.
In determining the Grievor's entitlement to benefit
coverage while on layoff, the appropriate starting point is the
Letter of Understanding which recognizes that there are certain
positions within the bargaining unit which require staffing for
less than 12 months a year. Where this requirement is identified
10
prior to hiring, the Letter of Understanding entitles the College
to layoff employees occupying such positions for up to 3 months
each year without regard to the provisions of the collective
agreement. The Letter of Understanding further specifies that
seniority and service shall accumulate for all purposes during
periods of layoff.
In the Board's view, although the Letter of
Understanding permits the College to disregard the collective
agreement in effecting a layoff, it is not sufficiently broad so
as to exclude the application of all provisions of the agreement
(except as expressly provided) during periods of layoff.
Moreover, while both the Letter of Understanding and Article 14.2
expressly provide for seniority and service to accumulate, this
accumulation is relevant to matters such as wages and vacation
where entitlement is based on service. Benefit coverage,
however, is governed by Article 8 of the collective agreement
and, as indicated above, for purposes of this case, the relevant
benefits are life insurance, long term disability, extended
health, dental, vision and hearing care.
In this regard, Article 8.1.6, which deals with dental
coverage, provides that the College shall pay 100% of the billed
premiums for an insured dental plan for eligible full-time
employees on the active payroll who have completed their
probationary period. In the Board's view, the requirement to be
11
on the "active payroll" excludes the Grievor from entitlement to
coverage during periods of layoff when she is not in receipt of
salary. As to the remaining benefits, as pointed out by Mr.
Atkinson, in the case of supplementary life insurance, long term
disability, vision and hearing care, where responsibility for
premiums is shared, Article 8 provides that the employee's share
is to be paid "through payroll deduction". Although, as
suggested by Ms. Kuntz, there are other means by which an
employee's share of premiums could be paid, payroll deduction is
the manner specified in the collective agreement. In this
regard, in Durham College of Applied Arts and Technology and
Ontario Public Service Employees Union March 14, 1983 (McLaren
(unreported)), the majority of the Board determined that the
reference to "payroll deduction" was intended to require the
College to make premium payments only for employees in receipt of
salary. As a result, the majority concluded that the Grievor,
who was absent from work on long term income protection, was not
entitled to O.H.I.P. and extended health coverage.
In any event, apart from the references to payroll
deduction, the provisions of Article 8 dealing with extended
health, certain aspects of dental coverage, long term disability,
vision and hearing care also specify that entitlement is subject
to the "eligibility requirements" of the plan. Accordingly, it
is necessary to examine those requirements in order to determine
the Grievor's right to coverage while on layoff. Moreover,
12
although Article 8.1.1, which deals with term life insurance,
does not specifically refer to the eligibility requirements of
the plan, the Article prowides that the College shall pay 100% of
the premiums of "the current baSic life insurance plan". In the
Board's view, as reference is made to a particular plan; that is,
the existing plan, it is equally necessary to have recourse to
the plan for purposes of determining the extent of the College's
obligation. In fact, the Board notes that a single plan covers
life insurance, extended health, vision and hearing care. The
relevant provisions of that plan are as follows:
Definitions
Employee - a person who is employed by the employer on a
full-time basis and who is a member of the Support Staff
whose terms of employment require him to work more than 24
hours a week or less than full-time Support Staff related
employee who the Employer has determined to be eligible
under the terms of the Pay Equity Plan.
Employment - employment as employee.
Termination of Employment - occurs on the last day of the
month in which a person
(a) ceases to qualify under the definition of employee, or
(b) ceases to be actively at work,
whichever is the earlier, except that the Policyholder,
acting in accordance with the rules which apply equally to
all employees within the same classification, may deem that
employment continues
3. during any period in which the employee is temporarily
laid off, ...
Actively at work - an employee is actively at work on any
day when he actually works at the employer's business
establishment or at some other location where the employer's
business requires him to be. An employee is deemed to have
worked on a scheduled non-working day if he worked until the
en~ of the immediately preceding scheduled working day.
13
INDIVIDUAL TERMINATIONS
An employee will cease to be insured on the earliest of the
following dates:
1. the date of termination of employment.
2. the end of the period for which the last premium is
paid to Sun Life for the employee's insurance.
3. the date of termination of the policy.
Similar provisions appear the plans covering long term disability
and dental benefits.
Apart from the provisions set out above, Ms. Kuntz
pointed out that the Employee Benefit Booklet, which summarizes
the benefits available to employees, stipulates certain waiting
periods to which employees are subject prior to receiving benefit
coverage. As these waiting periods are based upon specified
terms of employment from the date of hire, Ms. Kuntz contended
that service is directly relevant to the matter of entitlement to
coverage. Nevertheless, it is noteworthy that both the Booklet
and the plans provide that if an employee is not actively at work
on the date that he or she would otherwise become entitled to
coverage, such coverage will begin only when the employee returns
to active employment.
Moreover, the eligibility requirements of the
respective plans make it clear that coverage ceases upon
14
termination of employment which is deemed to occur on the last
day of the month that an employee ceases to be actively at work
as defined by the plans. Accordingly, we find that there is no
entitlement to coverage during periods of layoff with the
exception of a circumstance in which the employee is actively at
work for some period during the month, in which case it would
appear that he or she is entitled to coverage for the balance of
that month. Further, although the plans give the College
discretion to deem employment to continue during periods of
temporary layoff, we can see no basis upon which this Board could
compel the College to exercise that discretion to deem employment
to continue for employees in less than 12 month positions so as
to oblige the College to pay premiums for benefit coverage during
layoffs of up to 3 months.
We are reinforced in this conclusion by the award of a
Board chaired by Arbitrator MacDowell in Ontario Public Service
Employees Union and Loyalist College February 17, 1994
(unreported). The grievance in that case was filed under the
academic collective agreement and involved a claim that the
College was required to maintain extended health, vision and
hearing coverage for employees who were absent from work and in
receipt of long term disability benefits. Among other matters,
the Board noted that the academic agreement did not contain a
provision equivalent to Article 8.1.4 of the support staff
agreement which requires the College to pay 100% of the premiums
15
for benefit coverage for persons in receipt of long term
disability payments, provided that they were subscribing to such
benefits on the date payments commenced. In any event, the Board
in Loyalist College also noted that Article 22.02 of the academic
collective agreement specified that coverage was subject to the
eligibility requirements of the particular plan. On this basis,
the Board concluded as follows:
Article 22.02 does not create an open-ended obligation to
pay premiums in all circumstances, or for all persons who
might be considered "employees" under the terms of the
collective agreement. The employer is only obliged to make
premiums for "employees covered by [the Plan] and subiect to
the eligibility requirements of the Plan". We do not think
that we can ignore this limiting language, which takes one
inevitably to the terms of the Plan.
Had the parties intended to make'a particular benefit
available to everyone, regardless of employment status, they
could have used language like that found in the support
staff agreement. Had the parties intended to make a benefit
available to all "employees" in a general sense, they might
easily have done so without any reference to the Plan, its
coverage, or eligibility requirements. But they did not do
that.
This is not a case in which the employer has sought to
diminish its obligations under a collective agreement, or
has entered into a collateral contract inconsistent with
those obligations. It is clear it could not do so. The
employer is required to provide the benefits specified in
the collective agreement; but in this case, those
obligations can only be defined and understood with
reference to the insurance documents that establish "the
Plan".
The Board in Loyalist College then set out certain excerpts from
the insurance plan which are similar to the provisions of the
plans in issue in this case and continued as follows:
16
As will be seen, that the insurance contract defines the
group of "employees" covered by this benefit plan, and deals
expressly with persons who "cease to be actively at work on
full time". Such persons - which include individuals on
long term disability - are considered to have terminated
their employment. But that, in itself, does not preclude
their continued coverage and participation in the benefit
program. The employer is given the discretion to deem that
employment continues provided that it exercises that
discretion "in such a manner to preclude individual
selection".
The union does not challenge the applicability of this
definition or point to any other portion of the plan which
qualifies its effect. Nor, with respect, was the union able
to point to any contractual basis for its submission that
the "discretion" contained in the plan could only be
exercised jointly by the employer and the union through some
collective bargaining process. This is not what the plan
contemplates. The clause in question gives the employer a
discretion. It does not, on its face, invite a process of
collective bargaining, nor was our attention drawn to any
other clause in the collective agreement or the plan which
would have that effect. The union did not argue that this
discretion under the insurance contract could be reviewed by
an arbitrator and we do not see any basis for arbitral
intervention.
In a grievance such as this, the onus is on the union to
establish that the employer contravened some article of the
collective agreement. We are.not persuaded that the union
has met that onus in this case, On the basis of the
evidence and the argument put before us, we must conclude
that the employer has complied with its obligations in
Article 22.02, 22.06, 22.07, as defined and limited by the
eligibility requirements in the plan.
In this case, the benefit coverage provided for in Article 8 is
also subject to the eligibility requirements of the particular
plans and the terms of those plans are similar to those in the
Loyalist College award.
Moreover, the language of the collective agreement in
this case is distinguishable from that in Re Andres Wines (B.C.)
17
Ltd. and Brewery & Soft Drink Workers, Local 300 (1977), 15
L.A.C.(2d) 370 (Bird) in which the majority of the Board found
that employees were entitled to continued benefit coverage during
periods of temporary layoff. In an application for review of
that award which was dismissed in Re Andres Wines (B.C.) Ltd. and
United Brewery and Distillery Workers, Local 300 (1977) 16
L.A.C.(2d) 422 (B.C.L.R.B.), the Board noted that entitlement to
fringe benefits under the collective agreement was expressed in
"broad and vague language". The Board also noted that there was
no indication on the face of the agreement that the parties had
turned their minds to the situation of employees on layoff, nor
was there any consistent practice to Support the deficiency in
contract language.
In this case, in contrast, there is a 6onsistent past
practice which favours the interpretation advanced by the
College. Nevertheless, in the Board's view, it is unnecessary to
consider this practice as the collective agreement requires
recourse to the respective benefit plans which provide that
coverage ceases on termination of employment which is deemed to
occur on the last day of the month that an employee ceases active
employment. As there was no suggestion that the College failed
to pay premiums to maintain coverage to the end of the month that
the Grievor ceased active employment, we cannot conclude that she
18
was otherwise entitled to coverage while on layoff. Accordingly,
the grievance is dismissed.
DATED AT TORONTO, this 26th day of July, 1995.
Chair
"Hugh John Cook"
College Nominee
Dissent to Follow
Union Nominee