HomeMy WebLinkAboutP-2020-2705.Berezowsky.21-08-17 Decision
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Commission des
griefs de la fonction
publique
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Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
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PSGB# P-2020-2705
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Berezowsky Complainant
- and -
The Crown in Right of Ontario
(Ministry of the Solicitor General)
Employer
BEFORE Marilyn A. Nairn Vice Chair
FOR THE
COMPLAINANT
Evelyn Berezowsky
FOR THE EMPLOYER
No one appearing for the Employer
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Decision
[1] The Board is in receipt of a complaint filed by Evelyn Berezowsky (the
“Complainant”), alleging that the Employer acted irresponsibly with respect to
consideration of her 2019 performance rating. The complaint seeks an investigation into
the process utilized for assigning her rating and a transparent process going forward, and
to be assigned a rating with an associated performance pay increase for 2019.
[2] This complaint is essentially the same as a number of complaints that were filed
with the Board challenging the assignment of performance ratings. Those complaints
also sought a compensation increase based on the associated performance rating for
2018. The only other apparent difference in this complaint is that the Complainant
appears to have been initially overlooked with respect to her performance evaluation due
to the retirement of her direct supervisor. The complaint asserts that the evaluation was
then conducted by a Deputy Superintendent who had limited knowledge of her
performance.
[3] It is the finding of the Board that this complaint cannot proceed and it is hereby
dismissed for the following reasons.
[4] Rule 11 of the Board’s Rules provides:
Where the Board considers that a complaint does not make out a case for the orders
or remedies requested, even if all the facts stated in the complaint are assumed to be
true, the Board may dismiss the complaint without a hearing or consultation. In its
decision the Board will set out its reasons.
[5] For purposes of this decision, I assume that the facts as set out in the complaint
are true and provable. In the Board’s earlier decision Bowmaster v Ontario (Solicitor
General), 2020 CanLII 105698 (ON PSGB), the issue of the Board’s jurisdiction to
consider pay for performance was considered and determined as follows:
[14] This Board is established pursuant to the terms of the Public Service of
Ontario Act, 2006 (the “PSOA”) and the scope of its authority to consider and resolve
complaints is set out in Ontario Regulation 378/07 (the “Regulation”) made pursuant
to the PSOA. That Regulation sets out the type of complaints that the Board has
jurisdiction to entertain, providing a limited forum in which excluded employees may
bring complaints about the alleged breach of, inter alia, terms and conditions of
employment.
[15] Section 4 of the Regulation provides:
Complaint about a working condition or a term of employment
4. (1) Subject to subsection (2), a public servant who is aggrieved about
a working condition or about a term of his or her employment may file a
complaint about the working condition or the term of employment with
the Public Service Grievance Board…
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(2) The following matters cannot be the subject of a complaint about a
working condition or about a term of employment:
…
4. The evaluation of a public servant’s performance or the method of
evaluating his or her performance.
5. The compensation provided or denied to a public servant as a result
of the evaluation of his or her performance. O. Reg. 378/07, s. 4 (2).
[16] It is the position of the Employer that paragraphs 4 and 5 of sub-section 4(2)
prevent the Board from taking jurisdiction over these complaints - that the Regulation
is clear and specifically precludes an employee from making any complaint
concerning the performance review process and/or its result. Regardless of the most
generous reading one might give to the complaints, argued the Employer, they all
relate to the evaluation of the complainants’ performance and are expressly
precluded from review by the Board.
…
[18] I have reviewed the following decisions of the Board, referred to me by the
parties: Younger v Ontario (Environment), 2007 CanLII 30471; Tyrell v Ontario
(MCSCS), 2004 CanLII 55241; Berenbaum v. Ontario (Labour), 2011 CanLII 23299;
Sumner et al v Ontario (Health and Long Term Care), 2007 CanLII 36065; Hill v.
Ontario (MCSCS), 2006 CanLII 30740; Garratt v. Ontario (Health and Long Term
Care), 2005 CanLII 53194; Tighe v. Ontario (Solicitor General), 2020 CanLII 45594;
Drakos v Ontario (MCSCS), 2013 CanLII 88258; Chyczij v. Ontario (Labour), 2006
CanLII 26472; Aspiotis v. Ontario (MCSCS), 2019 CanLII 21767; and Charlton v.
Ontario (MCSCS), 2007 CanLII 24192.
…
[21] In 2004 in Tyrell, supra, the complainant sought reconsideration of the
dismissal of his complaint. As here, the complaint alleged that the employer had
failed to follow its own policy for implementing pay for performance and challenged
the cap placed on the number of managers able to achieve an “exceeds all” rating
as being arbitrary and discriminatory. In its original decision dated February 4, 2004
(cited in the reconsideration decision at page 2 and following) the Board stated:
The Public Service Grievance Board, as a statutory tribunal, can only
deal with those complaints falling within its legislative mandate…set
out in [the Regulation]…
…
Your complaint…relates to either the method of performance
evaluation, or the performance evaluation itself, or the compensation
provided or denied as a result of a performance evaluation. For this
reason it does not constitute a grievance over which this tribunal has
jurisdiction and, accordingly, it must be dismissed.
[22] At page 5 of the reconsideration decision, the Board re-iterated:
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Regardless of the most generous reading one could give to the
complaints, they all related to the evaluation of the complainants’
performance.
[23] In Younger, supra, the complainant entered into Minutes of Settlement that
contemplated his retirement. The complainant had expected that by retirement, his
performance would, in the normal course, be evaluated and rated for his final year
of employment, with an attendant merit pay increase. That did not happen. That
issue was not discussed during the negotiation of the settlement and the
complainant argued that the settlement and the release contained therein did not
shield the employer from future breaches while he remained employed.
[24] While the Board found that the Minutes of Settlement precluded it from
entertaining the complaint, it also addressed the issue of whether the exclusion in
the Regulation precluded the Board from entertaining the complaint. Again, the
assertion was that the Employer had failed to comply with its own policy. At page 7
the Board stated:
…the issue is that the employer failed to follow its own guidelines so
that what occurred in the employee’s absence was not a true
evaluation…
…
There is no doubt that certain aspects of the employer’s pay for
performance program are properly considered terms or conditions of a
manager’s employment. However, by virtue of subsection 31(4) [the
predecessor to sub-section 4(2) of Regulation 378/07], complaints
regarding it are excluded from the grievances over which this Board
has jurisdiction, as they are complaints regarding the method…of
evaluation of the employee’s performance, the evaluation itself…and
the compensation provided or denied as a result… the core of the
grievor’s complaint is about how he was evaluated (not in the way it
had been done before and as he had expected, after a face-to-face
meeting), the content of the evaluation itself (negative, and not giving
sufficient recognition to the high quality of his achievement) and the
compensation provided or denied as a result of that evaluation (a zero
percentage merit award). This is exactly the kind of claim excluded by
subsection 31(4) and thus the Board has no authority to deal with it.
[25] Also in Berenbaum, supra, the complainant alleged that his pay for
performance award should not have been pro-rated. In finding that it had no
jurisdiction to entertain the complaint, the Board stated at para 26:
The grievor stresses that he is not complaining about the substance of
the evaluation of his performance…He is complaining about its
implementation, as he is convinced that there was a mistake in what
he was paid, not how he was evaluated…However, some mistakes, if
mistake it was, have been removed from the Board’s purview to fix.
Even if the Board were to be persuaded, on a hearing of the merits of
the grievance, that the employer had erred, the grievor has not
demonstrated how it could be within the Board’s jurisdiction to award
the grievor a larger pay-for-performance award, given the wording of
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the Regulation, which effectively removes elements related to pay-for-
performance from the grievance over which the Board has jurisdiction.
(emphasis added)
[26] [The Complainant] relies on the decisions in Drakos and Chyczij, both supra,
to argue that the Board has jurisdiction to deal with allegations that an employer’s
treatment of an employee is arbitrary, discriminatory or in bad faith. Further, relying
on the decision in Aspiotis, supra, she argues that the Board has elected to hear a
complaint where it raised the possibility that the Employer’s actions were arbitrary,
discriminatory or in bad faith. She further argued that any lack of remedial authority
did not deter the Board from proceeding to a hearing on the merits in Aspiotis.
[27] The Board’s decision in Garratt, supra, confirms that there may be
circumstances where the Board will inquire into an allegation of arbitrary,
discriminatory or bad faith conduct on the part of the Employer. Fundamentally, the
allegation must relate to an existing term or condition of employment which the
Board has jurisdiction to enforce. In Garrett, the complainants sought a transparent
process for setting and communicating wages. No such process then existed and
the Board dismissed the complaint on the basis that the complainant was seeking
to establish a new process - to create a new term of employment, a matter beyond
the Board’s jurisdiction. The Board’s role is the enforcement of existing terms and
conditions of employment. The Board did go on to say that an allegation that an
existing term or condition of employment had been applied in bad faith was a matter
that could be brought to the Board. However, that decision did not deal with a term
or condition of employment that was otherwise expressly excluded from the Board’s
purview.
…
[33] I am not persuaded that it is appropriate to read the decision in Aspiotis as
going so far as to find that the Board has jurisdiction to consider complaints related
to pay for performance for allegations of arbitrary, discriminatory or bad faith
treatment on the Employer’s part. The Board’s historical and consistent caselaw
stands opposed to that conclusion as do the clear words of the Regulation which
bind the Board in the scope of its authority.
[34] Pay for performance is a term and condition of employment for excluded
employees, including these complainants (and see Kaine v. Ontario (CYS), 2014
CanLII 48097 at paragraph 36). These complaints all assert that the manner in which
their performance was evaluated, first done by their direct manager and then
changed without notice or consultation was in breach of the EPP and that the
Employer cannot shield itself from its own misconduct. However, what is being
fundamentally complained about are those matters excluded from the Board’s
purview by paragraphs 4 and 5 of sub-section 4(2) of the Regulation. Each complaint
seeks to be remedied by the complainant being awarded a higher performance
rating as each challenges the evaluation ultimately made by the Employer. In
asserting that the Employer acted in a manner that was arbitrary, discriminatory
and/or in bad faith the complainants are challenging “the method of
evaluating...performance”. They also seek “the compensation.. denied…as a result
of the evaluation”.
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[35] Having regard to the specific exclusion in the Regulation, I find that the
Employer is effectively protected from a complaint at the Board asserting that it acted
in a manner that was arbitrary, discriminatory, or in bad faith in respect of matters
concerning pay for performance. This in no way speaks to the quality of the
Employer’s treatment of the complainants or to the actual work performance of any
complainant. It is a decision based on the fact that this Board has no inherent
authority and the clear language of the Regulation specifically excludes these
allegations from the Board’s jurisdiction to consider and/or remedy.
[6] Reading this complaint as broadly as possible, it remains the case that it takes
issue with the evaluation of the Complainant’s performance, the method of that
evaluation, and the compensation denied as a result of that evaluation, in not providing
the Complainant with the merit pay increase that she feels she ought to have received.
This Board simply has no jurisdiction to entertain those issues in light of sub-paragraphs
4 and 5 of Section 4 of Regulation 378/07.
[7] Therefore, having regard to all of the above, this complaint is hereby dismissed.
Dated at Toronto, Ontario this 17th day of August, 2021.
“Marilyn A. Nairn”
________________________
Marilyn A. Nairn, Vice-Chair