In addition to state and federal protections, the City and County of Denver passed Ordinance 22-1614, which allows workers in Denver — whether employees or contractors or employees of staffing agencies — to file wage claims, which will investigate and can impose penalties. Additionally, the City can, under the ordinance, commence its own investigation without first receiving a complaint. Protections against retaliation are included in the Ordinance. Workers also have a private right of action whereby they can file suit in court if they opt to do so instead of relying on an administrative complaint.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2023-02-28 13:34:012023-02-28 13:34:01Denver passes ordinance recognizing municipal-level wage claim rights in addition to state and federal protections
In its Field Assistance Bulletin 2023-1 , the DOL reminds employers that federal wage-hour requirements still apply even when employees are working remotely. Thus for example, employers still must comply with the requirements to provide and document meal periods and rest breaks, as well as lactation breaks, and although employers may suspect that a remote worker is taking unauthorized breaks, the company may not simply assume time should be unpaid. The DOL also discusses an employer’s ability to either schedule work hours (assign remote workers a particular shift of hours to be worked) or assign a certain number of hours to be worked each day. The DOL discusses how employers can instruct employees in a variety of telework scenarios to clock in/clock out at the beginning, the end and throughout the day.
The DOL reminds employers though that, when they know or have reason to believe the employee is working outside recorded hours, the time must be recorded and paid as hours worked, even if the employee is themself choosing to work “off the clock” as it were from home. The DOL cites to its Field Assistance Bulleting 2020-5, which discussed how employers can instruct workers to record all hours worked, including such time, even where not requested, scheduled or authorized by the company.
Employers are reminded that in addition to the federal requirements discussed in the DOL’s Field Assistance Bulletin, additional state and local requirements might apply, including in Colorado for example the CDLE‘s COMPS order and related requirements.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2023-02-20 12:17:122023-02-20 12:17:12DOL issues Field Assistance Bulletin reminding employers that federal wage-hour requirements still apply even when employees are working remotely
Colorado wage law affords employees (1) a 30-minute meal period, subject to a number of requirements and conditions, which, if circumstances on a given day make it impractical to take, requires that the employee be paid for the time spent working instead and further that the employee be allowed an on-the-clock opportunity to consume a meal and (2) a 10-minute rest break for every 4 hours of work, again subject to a number of requirements and conditions. In Hicks v. Colorado Hamburger Co., the Colorado Court of Appeals was confronted with a case in which the timecards for workers in multiple locations allegedly did not show workers’ meal periods or rest breaks. A single worker at one location filed suit alleging he had not been granted them as required by Colorado law and further, he alleged, his co-workers at his and the other locations had similarly not been granted them. He sought a right to pursue his claims not only on his own individual behalf but on behalf of a class consisting of his co-workers at all locations.
The Colorado Court of Appeals ruled that his claim for rest break violations could be pursued as a class action, but the court refused to certify a class on his meal periods. The Court held that the timcards’ silence on the meal periods did not evidence whether there had been a meal period violation because, the Court noted, the employees may have been allowed to consume the on-the-break meal as permitted by and in accordance with the requirements of Colorado law; therefore, the Court held that class certificaiton would be inappropriate since every workers’ right to a meal period on any given day would be subject to individual analysis over just what exactly happened to them that day. However, the Court found the timecards’ silence as to rest breaks indicative of a possible claim because it held that the timecards’ silence did indicate, at least in the Court’s view of the circumstances of this case, that all workers may have been denied the required rest breaks.
The Court’s decision should not be read as a simple rule that all Colorado state law claims for rest breaks may be brought as class actions and that no Colorado state law meal period claims may be brought as class actions. The Court’s ruling may be limited to the facts before it, which the Court discussed in detail explaining its reasoning why the timecards’ silence, at least on the record before it in this case, warranted the different outcomes. It is also noted that the Court’s ruling did not address whether it was or wasn’t likely that any violation actually occurred; the case was simply over whether either claim could be pursued on behalf of a class. The Court’s ruling does not reflect any likely outcome on the merits.
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On September 29, 2022, the CDLE issued four sets of proposed Rules and accompanying explanatory Statements.
Proposed revisions to 7 CCR 1103-14, which are the rules implementing the CDLE’s PAY CALC Order, which sets the minimum wage rates in Colorado. The new rules would increase
the minimum hourly rate to $13.65 from $12.56,
the minimum hourly rate with tip credit to $10.63 from $9.54,
the minimum guaranteed weekly salary for executive, administrative and professional exempt employees to $961.54 from $865.38, and
the minimum guaranteed annual salary for highly compensated exempt employees to $112,500 from $102,250.
Proposed revisions to 7 CCR 1103-11 to implement this year’s new law SB 22-097, which expanded whistleblower protections to prohibit retaliation for the expression of any “reasonable concerns about workplace violations of governmental health or safety rules, or otherwise significant workplace health or safety threats,” without a requirement any longer to prove the concerns were “related to a public health emergency.”
Proposed revisions to 7 CCR 1103-7, which implements increases including under this year’s new law SB 22-161 to penalties, attorney fees, claim and appeal processes, under the laws overseen by the CDLE in the Colorado Wage Act (CWA).
Proposed revisions to 7 CCR 1103-6, which vest authority in the CDLE to issue, and oversee enforcement of, prevailing wage determinations on certain public projects under the Colorado Prevailing Wage Act (PWA) and the Keep Jobs in Colorado Act (KJICA).
The CDLE invites comments and has schedule rulemaking deadlines, including public hearings, on its website.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2022-10-07 11:52:542022-10-06 12:03:38CDLE proposes four sets of new rules
The CDLE has published INFO 16, which explains an employer’s right (and obligation) to deduct and take certain credits. Included in INFO 16, the CDLE explains Colorado’s new law governing an employer’s ability — by way of a new very specific timeline — to deduct “to recover the amount of money or the value of property that an employee failed to properly pay or return to the employer when their job ends.”
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2022-06-03 14:04:422022-06-03 14:04:42CDLE publishes INFO 16 explaining an employer’s right and obligation to deduct and take certain credits
By SB 22-161, the Colorado legislature clarified and expanded a number of enforcement processes, remedies and penalties related to a variety of wage, misclassification, safety and enforcement procedures. Included in the changes are restructurings of the ways and procedures by which penalties can be assessed, as well as enhancement of available remedies and penalty amounts.
Employers should note, even without being involved in a litigation or enforcement action, they will no longer be able to withhold from a final paycheck for an employee’s failure to return property or repay money unless the employer, first, provides the employee, within 10 days following the employee’s separation from employment, written notice, which “must include a written accounting specifying the amount of money or the specific property that the employee failed to pay or return, the replacement value of the property, and, to the extent known, when the money or property was provided to the employee and when the employer believes the employee should have paid the money or returned the property to the employer.” Thereafter, the employee will have 14 days to return/repay, and if the employee does, the employer will have 14 days to pay the employee the amount deducted.
Additionally employers should note that a new 14-day provision applies for employers to pay in response to a written demand, agency claim, lawsuit, etc., for unpaid wages. Compliance/non-compliance with this procedure has the ability then to initiate shifting exposures for remedies, penalties, and even possible attorney fees.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2022-05-23 15:29:012022-05-23 15:29:01Colorado clarifies and expands enforcement processes, remedies and penalties related to a variety of wage, misclassification, safety and enforcement procedures
The new minimum hourly wage in Colorado ($12.56, or for tipped employees, $9.54).
A new exemption under Colorado state employees for Highly Compensated Employees who earn at least the minimum weekly guaranteed salary for exempt employees ($515) and, annually, at least 2.25 times the minimum guaranteed salary required for other exemptions ($101,250 for 2022, equaling 2.25x$45,000). This new exemption applies to individuals who perform at least one of the exempt duties of a white-collar exemption and whose primary duty is office or non-manual work.
A rule (5.2.4) that states the remedies for failure to permit the required rest 10-minute periods include an extension of the employee’s actual hours worked that day by the required 10 minutes. In other words the employer cannot count the 10 minutes as a rest period, rather, it counts as hours worked that day.
An explanation of how to calculate the regular rate of pay for employees working at two or more non-exempt hourly rates during a single week.
Employers are also reminded to post the new COMPS Order (and the new PAY CALC Order’s numbers) or if not practical in any given physical site, to distribute the same pursuant to Rule 7.4.
Wage Protection Rules, effective 1/1/2022, includes Rule 2.17 defining “vacation” (which is required to be paid out at termination and cannot be subject to use-it-or-lose-it forfeitures) as including any paid leave the employee may use “at the employee’s discretion … rather than leave usable only upon occurrence of a qualifying event (for example, a medical need, caretaking requirement, bereavement or holiday),” in other words, and as an example, PTO is now considered “vacation” that must be paid out at termination and cannot be subject to use-it-or-lose-it forfeitures.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2022-02-02 04:13:402022-01-27 12:14:42CDLE publishes new crop of rules and posters for 2022
Colorado State Labor Relations Rules, 7 CCR 1103-12; And
Equal Pay Transparency Rules, 7 CCR 1103-13.
Look for its latest posters on the CDLE’s Poster page (the following list is quoted from CDLE)
The “Colorado Overtime and Minimum Pay Standards” (“COMPS”) poster and notice, covering wage and hour law — see COMPS Rule 7.4, Posting and Distribution Requirements, unchanged from the 2020 COMPS Order, which requires employers to display the annually revised poster (and send it to off-site employees), plus include either the poster or COMPS itself in any handbook or manual the employer has.
The “Colorado Workplace Public Health Rights Poster: Paid Leave, Whistleblowing, & Protective Equipment” poster and notice, covering HFWA and PHEW since their enactment in July 2020 — see Colorado WARNING Rule 4, Notice and Posting Rights and Responsibilities, unchanged from the temporary WARNING Rules in effect since September 21, 2020, which requires employers to post and give employees notice of these rights.
Translations of posters and INFOs — to implement requirements for employers to provide posters and notices to non-English-fluent workers, DLSS in 2020 posted translations of its posters in 12 languages and Spanish translations of INFOs (on the same pages as the English posters and INFOs), with new translations of the 2021-updated posters to be posted later this month, and translations of INFOs coming thereafter.
With translations into Spanish and other language.
Look for informational summaries on the CDLE’s INFO page, where the CDLE provides the following information summaries (again quoting the CDLE):
INFO# 1: Colorado Overtime &, Minimum Pay Standards Order (COMPS Order) #37 [In Spanish:Hoja Informativa y Opinión Formal (INFO por sus siglas en inglés) # 1: Orden de COMPS #37] (Próximamente)
INFO# 2:DLSS Wage Claim Investigation Process
INFO# 3: Tips (Gratuities) and Tipped Employees Under Colorado Wage Law
INFO# 4: Meal and Rest Period
INFO# 5: Public Health Emergency Whistleblower Rights [In Spanish:Hoja Informativa y Opinión Formal (INFO por sus siglas en inglés) # 5: Ley de Protección al Denunciante de Emergencias de Salud Pública] (Próximamente)
INFO# 6A: Paid Leave Under the Healthy Families and Workplaces Act, through December 31, 2020 [In Spanish:Hoja Informativa y Opinión Formal (INFO por sus siglas en inglés) # 6A: Pago por Ausencia Laboral bajo el Acta de Familias y Lugares de Trabajos Saludables, vigente hasta el 31 de diciembre, 2020]
INFO# 6B: Paid Leave Under the Healthy Families and Workplaces Act, as of January 1, 2021 [In Spanish:Hoja Informativa y Opinión Formal (INFO por sus siglas en inglés) # 6B: Pago por Ausencia Laboral bajo el Acta de Familias y Lugares de Trabajos Saludables, a partir de 1º de enero] (Próximamente)
INFO# 7: Payment of Wages & Required Record-Keeping
INFO #8: Colorado Chance to Compete Act (“Ban the Box”)
In recent posts, this blog has summarized a number of the CDLE’s latest rules. Some of the highlights from this most recent information just posted by the CDLE implementing its new rules includes the following:
INFO #1: The new hourly minimum wage in Colorado will be $12.32. The new minimum guaranteed salary for exempt workers will be $40,500.
Employers are reminded they must distribute a copy of the COMPS poster or the entire COMPS Order 37 (new for this year) with any policies/handbooks that are being distributed otherwise. Signatures must be obtained.
INFO #4: The CDLE has taken a strict approach to meals and rest periods, summarized in INFO #4.
Employers are responsible for not only “authorizing” workers to take breaks, but they must “permit” them to do so, and CDLE explains a rest break is “authorized” if the company has an adequate policy for example, but even if “authorized,” it is not “permitted” if the employee is “unable or discouraged” to take the break. Evidence that the employee is not “permitted” to take a break may simply be the employee’s own statement that they “felt pressure from the employer not to take the break.
It is the employer’s obligation, not the employee’s, to track and record and keep records of employee breaks. An employer cannot simply say it assumed the breaks were being taken as “authorized” where an employee claims not to have been “permitted” to take the break.
When a break is missed, it counts as work time, must be paid as such, even if that triggers daily or weekly overtime.
INFO #5: In its rules and now in its INFO implementing Colorado’s new PHEW law (already in effect), the CDLE has take the position that an employer who provides no PPE (mask) in a time of a public health emergency may not prohibit an employee from using an unsafe mask. PHEW allows employers to prohibit employees from using masks that do not meet the company’s requirements, only if — according to the CDLE’s interpretation — the employer has first provided its own mask to the worker. Employers should consider making appropriate disposable masks available in their workforces, so that they can later prohibit inappropriate masks that employees might otherwise wish to wear.
INFO #7: The CDLE summarized rules regarding the payment of wages, the establishment of pay periods, payment of final wages at separation, pay statement requirements and recordkeeping requirements.
INFO #8: The CDLE explained Colorado’s new ban-the-box law. Companies may not state in job applications or advertisements “that a person with a criminal history may not apply,” nor ask about the person’s criminal history on an application, nor require the applicant to disclose any criminal history on the application. Additionally, the CDLE says this prohibits an employer from stating that background checks will be required. Although an employer may require background checks as part of a conditional offer of employment, that may not be stated in an application or advertisement. The CDLE explains the limited exceptions available where employers are otherwise required by law to inquire into these matters.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2020-12-07 04:10:092020-12-08 17:00:37CDLE issues more new information for Colorado employers
The Colorado Department of Labor and Employment (CDLE) has finalized a half dozen rules on a wide array of topics. Employers should take care to immediately familiarize themselves with these rules, as many take effect January 1, 2021. The rules can be found on the CDLE’s rulemaking page, where the CDLE summarizes its new rules with the following table that contains links to the actual rules themselves:
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2020-11-20 14:40:352020-11-20 14:40:35CDLE finalizes crop of new rules
On March 16, 2020, the Colorado Department of Labor and Employment (CDLE) issued amendments, effective that same day, to its prior Wage Protection Act Rules. The amendments added language that articulated the CDLE’s opinion that Colorado state law on the Joint Employer doctrine is and, in its opinion, has always been contrary to federal law.
The Statement also clarified what information needs to be included in paycheck statement eliminating prior proposed requirements that CDLE concedes “make() no sense.”
In an email to stakeholders distributing the revisions on March 16, 2020, the CDLE also advised of grace periods it will permit in light of the on-going coronavirus events, as follows:
(B) Division Operations, and Compliance Grace Periods
As of now, the Division remains fully operational. Based in part on potential delays to employer internal operations that have been called to the Division’s attention, the Division has adopted the following policies to grant what leniency it can, within the confines of existing law, for the coming weeks.
(1) COMPS-required paperwork (posters, handbook inserts, acknowledgements, etc.) – compliance by 4/16/20 will be sufficient. To the extent that COMPS requires new paperwork from employers (new posters, handbook inserts, acknowledgement forms, etc.), the Division will deem compliance within the first month of COMPS – i.e., by April 16th – to be sufficient to qualify as compliant.
(2) No Division-initiated investigations of new COMPS rules until 4/16/20. While the Division by statute must investigate any claims filed with us, the Division’s “Direct Investigations” team launches its own investigations, based on tips, leads, and known problem sectors. For the first month of COMPS being in effect (i.e., until April 16th), Direct Investigations will not launch new investigations based on violations of new COMPS rules.
(3)Deeming violations of new COMPS provisions rules non-willful if remedied by 4/16/20. As noted above, the Division cannot by statute reject a claim filed shortly after COMPS takes effect. But to the extent that a violation committed within the first month of COMPS is solely of a new obligation under COMPS, the Division will deem the violation not “willful” if the employer remedies it within the first month of COMPS – i.e., by April 16th.
(4) Starting tomorrow, March 17th, no new “notices of claim” will be sent to employers until April 1st. This is for all wage claims, not just those related to COMPS. Because some employers may be currently struggling to keep up with mail receipt, the Division will postpone mailing any new “notice of claim” – the mailing that tells an employer that a claim has been filed against it – because by statute, a notice of claim starts a 14-day clock for the employer to avoid penalties by paying any wages due. A longer extension would risk backlogging claims, but the Division aims for this period of just over two weeks to postpone employers’ receipt of mail that starts a statutory deadline.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2020-03-25 14:35:282020-03-25 14:35:28COMPS Order 36 takes effect with some changes
As previously posted, the DOL issued an opinion letter in 2019, purporting to jettison the Obama Administration’s 80-20 rule and expanding the ability to claim tip credits for tipped employees, specifically, during time when they do not earn tips (example, while wait staff vacuum and clean). Bloomberg BNA reports that opinion letter has met with rejection in the courts:
Restaurant chains have lost at least seven decisions over the last year in which federal district court judges refused to give deference to a 2018 Labor Department opinion letter advising restaurants to pay a lower minimum wage to tipped workers for tasks that don’t yield gratuities.
In most of those decisions, judges held that DOL wasn’t justified in turning its back on a standard that’s been in place for more than three decades.
Also as previously posted, the DOL issued a propose regulation to the same effect, which if finalized would become law, to which courts should defer in lawsuits.
Employers are reminded that Colorado law requires additional notice-posting to employees if a tip credit is to be claimed.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2020-02-17 16:28:042020-02-17 14:29:52Restaurants and other employers with tipped employees, beware relying on DOL opinion letter
As noted in a previous post, Colorado proposed a new wage order in 2019. On January 22, 2020, the Colorado Division of Labor and Employment finalized its new order — now called COMPS order #36 — effective March 16, 2020.
As noted in the previous post, COMPS order #36 is radical overhaul of Colorado’s prior wage orders. Among other things the changes include:
A title change: Reflecting the fact that this new order addresses far more than simple wages, its title will change from the “Colorado Wage Order” (WO) to the “Colorado Overtime and Minimum Pay Standards Order” (COMPS).
COMPS 36 will now reach almost all private employers in Colorado. Previous WOs had applied only to the following four industries: retail and service, commercial support service, food and beverage, and health and medical. COMPS will apply to all employers as a general rule, unless the employer falls within one of the newly defined exemptions set forth in prosed Rule 2 of COMPS. Therefore employers who previously considered themselves exempt from the WOs should now review COMPS to determine if it will become covered.
Minimum guaranteed salary: If covered COMPS will increase the minimum guaranteed salary to $42,500, effective 7/1/20, well above that in federal law. COMPS minimum will rise steeply thereafter, each year, to $57,500 effective 1/1/26 and be adjusted thereafter per the CPI.
Changes to particular job-specific exemptions have been proposed.
Changes to the timing of required rest periods and a requirement that employees who are not allowed their 10-minute rest period receive pay not only for the 10-minute rest period but an extra 10 minutes pay.
Changes to the ability to take credits and the ability to charge for uniforms.
Changes to the fluctuating workweek method of calculating overtime.
Expansion of anti-retaliation protections.
Expansion of employer obligations as to “transparency,” “language inclusiveness” and posters.
In addition, the as-finalized COMPS order #36 dramatically expanded the definition of an “employee” and “employer” in Colorado — in apparent reflection of similar narrowing in California — by mandating that a worker will be deemed an “employee” not an independent contractor who otherwise meets all requirements to be an independent contractor but who performs work that is itself part of the company’s own regular business. The CDLE explained this “entirely new factor to the ’employee’ analysis'” in its Statement of Basis, Purpose, Specific Statutory Authority, and Findings in support of COMPS Order #36, as follows:
For example: if a retail clothing store hires an outside plumber on a one-time or sporadic basis to make repairs as needed, the plumber’s services are not part of the store’s primary work — selling clothes. On the other hand, when a clothing manufacturer hires work-at-home seamstresses to make dresses, from cloth and patterns supplied by the manufacturer, that the manufacturer will sell, or when a bakery hires cake decorators to work on a regular basis on custom-designed cakes, the workers are performing the “primary work” of the hiring business.
Other changes to the prior draft order include a rule that workers who are putting on and taking off work clothes and gear (so-called “donning and doffing” cases) are engaged in work and accordingly must be paid for the such time if it takes “over one minute” and if it is not clothes/gear that is “worn outside work as well. Additionally COMPS order #36 will effectively require that, when a 10-minute break is otherwise required, nearly all such workers will need to be made to take their 10-minute breaks every 4 hours. Only workers who work under collectively bargained agreements that say otherwise will be allowed to take breaks outside a 4-hour period, as can some workers who work for certain Medicaid-funded entities.
Perhaps most importantly the final order also implemented a slower increase in the required guaranteed minimum salary for overtime exempt person in 2020 and 2021, then a steeper climb in 2023 to reach the previously planned 2024 minimum salary of $55,000.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2020-01-27 12:23:502020-01-27 12:23:50Colorado finalizes new wage order, COMPS Order no. 36, 7 CCR 1103-1 (2020)
Effective January 1, 2020, Colorado has criminalized wage thefts. This new law applies to “employers,” a term defined to be commensurate with the Fair Labor Standards Act’s coverage, and protects “employees,” as defined to exclude independent contractors.
Under this new law it will be a crime to:
refuse to pay or “falsely” deny “the amount of a wage claim, or the validity thereof, or that the same is due”
“with intent to secure for himself, herself, or another person any discount upon such indebtedness or any underpayment of such indebtedness”
“or with intent to annoy, harass, opress, hinder, coerce, delay, or defraud” the employee.”
Who may be charged with this crime? “Every employer or other person who intentionally, individually or as an officer, agent, or employee of a corporation or other person” who “pays or causes to be paid to any such employee a wage less than” that required.
This new crime will rise to the level of a felony if the amount at-issue equals or exceeds $2,000.
Employers, including all individuals involved in the payroll function and related decisions whether or not to pay wages, should anticipate that employees will seek to have such matters prosecuted, in addition to or instead of civil wage claims. This new Colorado law is all the more reason for employers to carefully review their wage compliance efforts.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2019-08-06 01:16:382019-07-25 15:24:31Colorado criminalizes wage theft
Colorado employers are reminded that Colorado’s new ban-the-box law will take effect September 1, 2019 for employers with more than 10 employees (then September 1, 20121 for all other employers). Together with the crop of other new Colorado employment laws this year, Colorado employers should:
Review and revise their handbooks, workplace policies, and hiring documents accordingly.
Review and revise their hiring and promotion practices.
Consider undertaking an audit of pay levels as encouraged now by HB19-085.
https://l2slegal.com/wp-content/uploads/2017/05/logo-orig.png00Bill C. Bergerhttps://l2slegal.com/wp-content/uploads/2017/05/logo-orig.pngBill C. Berger2019-07-25 15:35:392019-07-25 15:37:40Reminder, Colorado employers, new ban-the-box law will take effect soon