The Department of Labor (DOL) recently changed what it considers reportable “persuader” activity under the Labor-Management Relations Act. Any agreements entered on or after July 1, 2016 with attorneys or consultants to provide a number of common services (supervisor training, drafting of employee communications and certain policy materials, providing union avoidance-related planning help, to name just a few) must be reported to DOL, will trigger other, broader labor relations reporting for the attorneys or consultants, and will be publicly disclosed.

In June 2016, the DOL clarified how it will handle agreements entered into before July 1, 2016. Andrew Auerbach, the Deputy Director in charge of reporting, stated the DOL’s position that:

“Services and payments made pursuant to a multi-year agreement, even if they occur after July 1, are not required to be reported on the new Form LM-20, so long as the agreement was signed prior to July 1.”

If you have questions about the DOL Rulemaking, I encourage you to check here or the DOL website here.

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An HR practitioner for over 25 years, Michael VanDervort specializes in helping companies and clients to build thriving workplaces driven by positive associate relations. Currently, the Executive Director at CUE Inc. the leading global organization for positive employee relations, he specializes in helping companies and clients to build thriving workplaces driven by positive associate relations.