unemp question re: privacy laws

Hiya everyone

I need some help. Here are the facts:

Employee became ill in late January. 1/29/03 I sent her a letter with fmla form, dol statement of rights, a copy of our regular leave policy and a copy of our fmla leave policy. Also said if she became in a leave without pay situation we would make payment arrangements for her insurance.

The fmla paperwork was returned to me (signed by an ARNP on 2/10). It stated employee would be out from 1/27 to 2/16.

Employee called every week, but did not return. On 2/25 I noticed that we were well beyond the end date of the paperwork (oops) and wrote employee. Letter stated we must have new form within 15 days and since employee was now on leave without pay, showed insurance amounts due. Received no response and at this time employee stopped calling weekly.

March 14 sent a certified letter informing employee we should have received her form by March 12. Told employee if we did not hear from her within 7 days (March 21) we would assume job abandonement. Told her what she still owed for Feb. insurance and what it would be for March, but that since she had not made a payment she currently did not have insurance for March.

March 17 I received a call from employee. She said she did not get my 2/25 letter and could not be without insurance. That she would get me the money, and that she was waiting to hear the results on 2 tests she had done the previous week. She kept talking about the money and not having insurance; I stressed that I needed the form signed and returned right away (3 times). I then documented the phone call and sent employee copies of 2/25 letter.

Did not hear from her again, but sent a certified letter informing her that we considered her terminated on March 26th. (Also told her what she owed for Feb. and regular "termination" info.)

Employee filed for unemployment. I completed the form stating that we considered it job abandonment and that it was because of no fmla form though we had tried 3 times. Unemployment was denied.

Employee has now appealed (says I told her ok on the phone and that her letter says "termination of employment"). Now I come to my question. The judge is willing to look at my documentation, but how much of this can I send without violating privacy laws? I assume I can send copies of my letters and documentation on the phone conversation since I did not specifically refer to her exact illness, but what about the fmla form. Isn't the dates on the form important to my case? Would it help if I copied the form and then made sure the medical part is unreadable? Help!

Comments

  • 6 Comments sorted by Votes Date Added
  • If the court has requested that you turn over supporting documents, I believe that the FMLA forms would be included. I would not put them on overheads for the entire courtroom to see but a judge would be reasonable. Now if the judge has not requested to see the FMLA documentation I wouldn't share it.
  • Myself I provide the hearing officer or judge with all information needed to make my case. This is company documentation, technically the diagnosis should not be on the form anyhow. But all is fair in court.
    My $0.02 worth............back after an exhausting day at a golf tournament! x:D
    DJ The Balloonman
  • The answer to your question is that in 50 states, even California for Gods' sakes, it is appropriate for an employer to furnish the appeals hearing process any and all documentation upon which the termination was based and can even produce the entire file if needed for an eligibility ruling at appeal. I would never provide it to a claimstaker, however, for use in the initial determination stage. Looks from your post as if the intention is to 'mail it in' rather than produce it into evidence at a hearing, which seems a strange process if this is an appeal hearing. Anyway, send or produce it. If you send it, send it certified and cover it with an explicit letter advising for the record that "All of the material enclosed herein (itemize it) is strictly confidential company property from the personnel file of John Doe and is to be used by the (State) unemployment insurance division only for purposes of unemployment insurance eligibility determination and use for any and all other purposes, or copying or further distribution of it is prohibited." I don't claim to have any legal knowledge but would certainly do that before mailing off anything confidential such as medical information.
  • Ahhhhh Don. I knew you would have the exact answer. Unfortunately I had to catch the mail BEFORE you posted. The hearing will not be in person, but via the phone. So I had to mail my documentation to both the judge and the claimant (per the instructions provided). I ended up blocking out the diagnosis the provider wrote in, and in my cover letter explained that I had done so and why. I just wish I had thought to mark the envelope confidential. I addressed it to the judge though, so I hope it only gets opened by him or his assistant.

    Thanks to everyone for your input. I'll try to remember all this if I ever get stuck in this position again.
  • Not to worry. I'm just especially anal (no pun intended) about covering my a--. Mailing the requested material to him at his work address will not in any way open you up to ridicule or liability. If he has incompetent clerks or mailroom staff who open people's mail and run their mouths about it, that's the agency's problem. By the way, in the claims process, the claimant has signed a form attesting to their knowledge that their employment records may be examined and used as a basis for an eligibility decision or in furtherance of an appeal to a decision already rendered.

    The only other suggestion I have, which may come too late for you, is to mark each item, which will become items of evidence. I always mark them, for example, item a,b,c,d1,d2. I mark the copy I provide the judge as well as my own for ease in referring to and locating them. It would keep you from having to say (on the phone), "No sir, I'm referring to the two-page letter, the one with the heading 'ABC Clinic', not the one from Charity Hospital, yes, that one, I believe we have the same document, tell me again what yours says." When that happens and the claimant chimes in, "Wait a minute. I'm not sure what ya'll are looking at", the judge gets frustrated and the ruling begins to slant in the direction of the claimant. Call me anal, but I've lost one appeal in several decades (and it was in California of course).
  • UPDATE

    We had the hearing over 2 weeks ago, and I cringe with embarrassment at some of my mistakes. For instance, I actually had the stupidity to put in my final warning letter that if we had not "heard from" employee within the week we would consider her termed. x:-8 Of course, employee called during that period, but did not supply the form. She stated in the hearing that I had basically told her that everything was ok (NOT!!!)during that phone conversation so she did not worry about getting the form in.

    Though my final point to the judge was to repeat over and over again that we did everything we could short of escorting the employee to the doctor so we should not be charged, I really felt we could not win. Between my dumb "heard from" statement and the fact that things kept sounding like the judge felt we termed her for not following instructions when she was just sick, not to mention employee's testamony about my response to her phone call, I just knew it was a lost cause.

    Late yesterday I finally got the decision. Employee gets benefits. Employer does NOT get charged!!!! xclap YIPEE!!! It CAN happen!!! :DD
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