Employers must reimburse employees for all necessary business expenditures or losses incurred in the course of their employment. This requirement applies to employee personal cell phone use when employees must use their personal cell phones for business purposes, even when employees have unlimited minutes and do not incur any extra charge by using their personal cell phones.
In Cochran v. Schwan’s Home Serv., Inc., 228 Cal. App. 4th 1137 (2014), a group of customer service managers brought a putative class action against their employer for failing to reimburse them for work-related use of personal cell phones. The trial court did not certify the class action; in part because it determined that too many questions existed concerning individual cell phone plans (unlimited or limited minutes) and payment of the cell phone bills (by the employee or by someone else). The court of appeal simplified the issue for the trial court by determining that employer-required use of personal cell phones is always required. It makes no difference whether employees incur an additional expense that they would not have incurred if they did not have to use their cell phones for work. Employers must still pay a reasonable percentage of their employees’ personal cell phone bills.
Nowadays, employers would be hard pressed to identify one employee who does not have a personal cell phone. As discussed in an earlier issue this year (Volume 17, Issue 4), employers may be liable for constructive discharge based on failing to reimburse employees for necessary work expenditures. Employers, therefore, should take their reimbursement obligation seriously and ensure that employees are not required, and are aware that they are not required, to use their personal cell phones for business purposes. Alternatively, where employees are required to use their personal cell phones for business purposes, employers should ensure that they receive reimbursement for the expense.
__________________________________________________________________________________
DID YOU KNOW…
The United States Supreme Court recently determined that time spent by hourly warehouse employees waiting for and participating in antitheft security screenings before they could leave work each day was not compensable under the federal Fair Labor Standards Act. See, Integrity Staffing Solutions, Inc. v. Busk, No. 13-433, 2014 WL 6885951 (Dec. 9, 2014).
_____________________________________________________________________________________________
In July of 2014, the U.S. Equal Employment Opportunity Commission (“EEOC”) issued its first comprehensive guidance on pregnancy discrimination and pregnancy-related disabilities since 1983 concerning the federal Pregnancy Discrimination Act (“PDA”). The PDA prohibits discrimination on the basis of past, current and intended pregnancy. With respect to intended or future pregnancy, employers may be liable for any adverse actions taken on the basis of (1) perceived or actual reproductive risks, (2) intention to become pregnant, (3) fertility treatments, and/or (4) the use of contraceptives. Additionally, the PDA prohibits discrimination against employees based on medical conditions related to pregnancy or childbirth, including lactation, breastfeeding and abortion. The EEOC’s guidance brings federal law more in line with California law.
One of the most discussed provisions in the EEOC guidance involves the EEOC’s position that employers must provide reasonable accommodations to pregnant employees or those with pregnancy-related conditions. While pregnancy does not automatically constitute a disability under the ADA, the guidance requires employers to treat pregnant employees who are temporarily unable to perform the functions of their job the same as it treats other employees with similar inabilities to perform their jobs, including those with disabilities. Thus, pregnant women with work restrictions must be offered light duty if the employer offers light duty, even if light duty is typically only offered to employees recovering from job-related injuries.
Another key highlight from the EEOC guidance concerns parental bonding leave. Parental bonding leave is generally offered so that new parents can bond with or care for a new child. The guidance requires that men and women must be offered bonding leave on equal terms. Thus, if female employees are offered five weeks of parental leave, male employees must also be offered five weeks of parental leave.
Employers should review their pregnancy, discrimination, leave and disability accommodation-related policies and practices to ensure compliance with the PDA and ADA’s requirements and EEOC guidance. Employers should also monitor their compensation practices and performance appraisal systems for patterns of potential discrimination based on pregnancy, childbirth or related medical condition.
__________________________________________________________
DID YOU KNOW…
As of January 1, 2015, California-mandated sexual harassment training must now include training and education on the prevention of bullying. (AB 2053) The training must be provided every two years for supervisory employees, or within six months of an employee assuming a supervisory position, for employers with 50 or more employees.
__________________________________________________________
The California Supreme Court recently determined that employees who are not authorized to work in the United States may still bring claims against their former employers for violating the Fair Employment and Housing Act (“FEHA”), and may even recover damages (e.g., lost wages) against them.
In Salas v. Sierra Chemical Co., (2014) 59 Cal.4th 407 a former employee sued his employer under the FEHA for failure to provide reasonable accommodations for his physical disability, and for retaliation. During his employment, the employee suffered a couple of back injuries. The employee filed a workers’ compensation claim after one of the injuries. Shortly thereafter, the employer laid the employee off as a part of a seasonal reduction of workers, and the employee sued his employer. During the litigation, the employer discovered that the employee used false identification documents, without which, the employee would not have been eligible to work. The employer argued that this “after-acquired” evidence completely barred the employee’s claims. The California Supreme Court determined it did not. It concluded that FEHA’s antidiscrimination provisions apply to employees regardless of their immigration status, and therefore, the employee could continue with his suit against his former employer.
This case is important for employers who unknowingly hire undocumented workers. On the one hand, employers must comply with federal work eligibility requirements, including verification of identity and work eligibility of new employees. On the other hand, California employers may not discriminate against unauthorized employees who misrepresent their work status, even though the employees were never authorized to work for the employer in the first place. Those employees may still recover lost wages for the period before the employer learned the employee was not legally eligible to work, but not for the period after the employer learned of their unauthorized work status.
DID YOU KNOW…
Beginning July 1, 2015, California employers, subject to limited exceptions, are required to provide paid sick leave to exempt and non-exempt employees. Employers are not required to allow employees to accrue more than 6 work days of sick leave, and may limit an employee’s annual use of sick leave to 3 work days. Employers do not have to pay employees for accrued, unused sick leave upon separation from employment.
Public works projects are publicly financed construction projects done under contract. California law generally requires contractors and subcontractors who are working on public works projects to pay their employees the rates of wages (“prevailing wages”) set by the Director of the Department of Industrial Relations (“DIR”) in the location where the work will be performed. However, a recent court of appeal decision determined that employees of a subcontractor on a public works project who fabricated materials from a permanent, offsite facility were not entitled to prevailing wages.
In Sheet Metal Workers’ International Association, Local 104 v. Duncan (Cal. Ct. App., Aug. 27, 2014) 14 Cal. Daily Op. Serv. 10205, the employee of a subcontractor for a public works project filed a complaint with the DIR alleging non-payment of prevailing wages for materials he fabricated for a public works project. The employee fabricated custom sheet metal materials away from the project site. The Court of Appeal determined that the employee’s work was not work done in the execution of a public works contract. Neither the custom-nature of the materials nor the fact that the subcontractor did not sell fabricated materials to the general public were determinative. What was determinative was that the work was done at a permanent, offsite facility, and the location and existence of that facility was established independent of the public works project.
Previously, a materials supplier exemption for “on-hauling” materials onto public works sites was recognized for contractors who sold their supplies to the general public. This case now recognizes another exemption for contractors who do not sell their fabricated materials to the general public. Contractors and subcontractors should ensure they meet the exemption. In other words, verify that their facility is truly a permanent, offsite facility, as opposed to an off-site, temporary facility established specifically for the public works project. Subcontractors, in particular, will also want to review their contracts to ensure that the contracts do not obligate them to pay prevailing wages whether or not prevailing wage law applies.
DID YOU KNOW…
The Equal Employment Opportunity Commission (EEOC) recently released guidance concerning its enforcement of the Pregnancy Discrimination Act and the Americans with Disabilities Act. This is the first time in 23 years that the EEOC updated its guidance on these laws governing pregnant employees. The guidance may be accessed at: http://www.eeoc.gov/laws/guidance/pregnancy_guidance.cfm
Employers are generally required to pay nonexempt California employees overtime for any hours worked in excess of eight in one day or forty in one week, and for the first eight hours worked on the seventh consecutive day in a workweek. Employees are entitled to payment for overtime – even if not reported – when their employers have actual or constructive knowledge that they are working overtime. A recent court of appeal decision is instructive, and affirmed judgment for the employer because the employee could not prove his employer was aware of his off-the-clock hours.
In Jong v. Kaiser Foundation Health Plan, Inc., 226 Cal.App.4th 391, 399 (2014), Jong, and other non-exempt employees, brought a putative wage and hour class action against Kaiser for non-payment of overtime compensation. Jong argued that his job could not be completed unless he worked overtime, and that he was criticized for working overtime, which was why he worked overtime hours off-the-clock. But Jong was unable to demonstrate that Kaiser knew or should have known that he was working unreported overtime hours. He had no evidence that his supervisors told him he could or should work off the clock, or that he should not report his overtime. When Jong reported overtime work, he was paid for that time. Jong also signed an attestation acknowledging that off-the-clock work was a violation of Kaiser’s policies. Accordingly, Jong could not prove that Kaiser should have paid him for his unreported overtime hours because Kaiser was not aware of his unreported overtime.
Employers should be particularly sensitive to wage and hour claims, which are particularly ripe for class action lawsuits. Additionally, failing to compensate employees for overtime can subject employers to civil lawsuits to recover unpaid overtime, including interest, attorney fees, and costs of suit. Once employers become aware of unreported overtime, they should address it. They may require employees to sign attestations that failing to report all hours worked violates company policy, and to verify the hours worked on their timesheets. If they have policies prohibiting overtime work without prior approval, they may discipline employees for working unapproved overtime. However, employers should still compensate employees for all time worked of which they are aware.
DID YOU KNOW…
All employers, regardless of size, are subject to sexual harassment claims pursuant to California’s Fair Employment and Housing Act. Kim v. Konad USA Distribution, Inc., 226 Cal.App.4th 1336, 1350 (2014). Sexual harassment training may help prevent and assist in defending against sexual harassment claims, and is required every two years for supervisory employees, or within six months of an employee assuming a supervisory position, for employers with 50 or more employees.
Eleven of Wilke Fleury’s attorneys have been listed as 2014 Northern California Super Lawyers and Rising Stars. The firm’s Super Lawyers are Philip Birney, Daniel Egan, George Guthrie, Ronald Lamb, Stephen Marmaduke, Thomas Redmon and Robert Tyler. The firm’s Rising Stars are Daniel Baxter, Anthony Eaton and Steven Williamson.
Super Lawyers® is a service of the Thomson Reuters, Legal Division. Each year, the research team at Super Lawyers® undertakes a rigorous multi-phase selection process that includes a statewide survey of lawyers, independent evaluation of candidates by the attorney-led research staff, a peer review of candidates by practice area and a good-standing and disciplinary check.
Super Lawyers® can be found online at www.superlawyers.com.
The California Supreme Court recently issued a decision with widespread ramifications for employers. Previously, the Court determined that class action waivers in employment contracts may be enforceable as long as they were not unconscionable or violative of public policy. The California Supreme Court, following intervening U.S. Supreme Court precedent, determined that its prior decision was abrogated and reversed itself. Class action waivers in employment contracts are enforceable in California notwithstanding unconscionability or State public policy to the contrary.
In Iskanian v. CLS Transp. Los Angeles, LLC, 2014 WL 2808963 (June 23, 2014), an employee brought a wage and hour class action lawsuit. The employer sought to enforce an arbitration agreement whereby the employee had waived the right to proceed by class and representative proceedings. The lower courts ordered individual arbitration and dismissed the class claims with prejudice. Similarly, the California Supreme Court determined that the class action wavier was enforceable because the Federal Arbitration Act (“FAA”) does not permit States to refuse to enforce class action waivers on public policy or unconscionability grounds.
On the other hand, the California Supreme Court determined that representative actions under the Labor Code Private Attorneys General Act of 2004 (“PAGA”) cannot be waived. PAGA allows employees to bring claims on behalf of the State of California against their employers, and seek statutory penalties for violations of the California Labor Code, such as overtime and meal and rest period violations. The FAA did not require a contrary result because the FAA seeks to ensure a forum for resolution of private disputes (e.g., disputes between an employer and employee relating to their employment contract), but PAGA actions are not private disputes. PAGA disputes are disputes between the State and the employer concerning violations of the Labor Code.
Individual arbitration of employee claims can be advantageous for employers. For example, it can prevent employees from aggregating otherwise small dollar claims that may not otherwise be economically feasible for an employee to bring as an individual claim. Employers will want to make sure their arbitration agreements do not contain overbroad language that could invalidate otherwise enforceable class action waivers (e.g. waivers of representative actions). PAGA representative actions cannot be waived as a condition of employment in any forum, including arbitration and state and federal court.
_________________________________________________________________________________ DID YOU KNOW…
The Equal Employment Opportunity Commission (“EEOC”) issued new guidance on the application of federal employment discrimination law under Title VII to religious dress and grooming practices, and what steps employers can take to meet their legal responsibilities in this area. The guidance can be viewed at:http://www.eeoc.gov/eeoc/publications/qa_religious_garb_grooming.cfm
Our firm was proud to participate in the Sacramento Habitat for Humanity ‘s 2nd Annual Attorney Build!
Wilke Fleury’s 11-member team included attorneys and professional staff who worked on the home in order to provide home buying opportunities for low-income families. The Habitat for Humanity builds affordable homes in partnership with families in need, supported by a host of volunteers, faith based organizations, donors and corporations for the betterment of Sacramento’s community.
We also congratulate our managing partner, Ronald Lamb, on his recent appointment to the Habitat for Humanity Board.
In overturning a trial court decision made two years ago and ordering a new trial to establish damages, California’s Fifth District Court of Appeals has ruled that hospitals can no longer expect to seek reimbursement from health plans in amounts well in excess of the actual value of services rendered to plan members.
In issuing its decision in Children’s Hospital Central California v. Blue Cross of California, the appellate court shifted the state’s health care provider reimbursement landscape. Wilke Fleury’s Dan Baxter, a member of the legal team that tried the original case in 2012 on behalf of Blue Cross in Madera County Superior Court, explained the court’s ruling means the ‘charge master’ system—whereby providers sought, for example, $10.00 in reimbursement for the provision of two aspirin—will no longer stand as a legitimate, defining measure of expected compensation. The appellate court found the trial court erred in not allowing Blue Cross to present evidence of the reasonable value of the services rendered by Children’s Hospital Central California. The court ordered the case retried and awarded Blue Cross its appellate costs.
The California Supreme Court recently issued a decision with widespread ramifications for employers. Previously, the Court determined that class action waivers in employment contracts may be enforceable as long as they were not unconscionable or violative of public policy. The California Supreme Court, following intervening U.S. Supreme Court precedent, determined that its prior decision was abrogated and reversed itself. Class action waivers in employment contracts are enforceable in California notwithstanding unconscionability or State public policy to the contrary.
In Iskanian v. CLS Transp. Los Angeles, LLC, 2014 WL 2808963 (June 23, 2014), an employee brought a wage and hour class action lawsuit. The employer sought to enforce an arbitration agreement whereby the employee had waived the right to proceed by class and representative proceedings. The lower courts ordered individual arbitration and dismissed the class claims with prejudice. Similarly, the California Supreme Court determined that the class action wavier was enforceable because the Federal Arbitration Act (“FAA”) does not permit States to refuse to enforce class action waivers on public policy or unconscionability grounds.
Individual arbitration of employee claims can be advantageous for employers. For example, it can prevent employees from aggregating otherwise small dollar claims that may not otherwise be economically feasible for an employee to bring as an individual claim. Employers will want to make sure their arbitration agreements do not contain overbroad language that could invalidate otherwise enforceable class action waivers (e.g. waivers of representative actions). PAGA representative actions cannot be waived as a condition of employment in any forum, including arbitration and state and federal court.
DID YOU KNOW…
The Equal Employment Opportunity Commission (“EEOC”) issued new guidance on the application of federal employment discrimination law under Title VII to religious dress and grooming practices, and what steps employers can take to meet their legal responsibilities in this area. The guidance can be viewed at: http://www.eeoc.gov/eeoc/publications/qa_religious_garb_grooming.cfm
Arbitration agreements are commonplace in California employment relationships. As with employee handbooks, employers may attempt to reserve the right to modify their arbitration agreements with employees. The reservation of this right may be unilateral, meaning that the employer can modify or terminate the agreement but the employee cannot change his or her mind about the agreement. Such modification clauses are not illusory because the law implies a promise by the employer to exercise its right in good faith and pursuant to fair dealings, and hence, these modification clauses may be enforced.
In Casas v. Carmax Auto Superstores California, LLC, 224 Cal.App.4th 1233 (2014), an employee sued his employer and the employer moved to compel arbitration pursuant to an arbitration agreement. The trial court refused to enforce the arbitration agreement based on the employer’s unilateral modification clause. The court of appeal reversed. In upholding the employer’s modification clause, the court of appeal noted that the arbitration agreement was separate from (and not lost within) an employee handbook and required notice to the employees by a date certain each year of any modifications. However, the court of appeal would not enforce a provision of the arbitration agreement applying the agreement in effect at the time the employer received the claim. Instead, the arbitration agreement in effect at the time the claim arose applied, notwithstanding any subsequent modification to the arbitration agreement by the employer after the claim arose. Nevertheless, the employer’s arbitration agreement contained a savings clause to modify the provision to comply with the law, so the employer’s modification clause
could be enforced.
California employers have some authority now for unilaterally reserving the right to modify or terminate their arbitration agreements with employees. Employers should make sure their arbitration agreements are not lost within other employment documents, and should include a savings clause to modify any arbitration provisions that conflict with the law to conform to the law. Employers should also consider providing advance notice to employees, though the failure alone to provide advance notice will not make the agreement illusory since employers must exercise their right to modify in good faith and pursuant to fair dealings with employees.
DID YOU KNOW…
Employees who are terminated for failing to fulfill important functions of their position cannot demonstrate that their employer’s reasons were untrue or pretexutal based simply on after-acquired evidence years after the termination that the employer was not damaged by their failure to perform. Serri v. Santa Clara University, 14 Cal. Daily Op. Serv. 5922 (Cal. Ct. App., May 28, 2014) (discrimination claim on motion for summary judgment).
Employees who resign sometimes sue their employer for constructive discharge. An employee is constructively discharged under California law when the employer intentionally creates or knowingly permits working conditions that are so intolerable that a reasonable person in the employee’s position would have been forced to resign. The conditions must be so objectively bad that the employee’s only reasonable option is to resign or quit. This situation may arise when employers fail to reimburse non-exempt employees for necessary work expenditures.
In Vasquez v. Franklin Management Real Estate Fund, Inc., 222 Cal.App.4th 819 (2013), Vasquez drove his personal vehicle as part of his job and earned $10 per hour. Vasquez resigned after his employer failed to reimburse him for vehicle expenses (e.g., gasoline and maintenance), and sued his employer for constructive discharge. Vasquez alleged he was unable to meet basic living expenses and effectively earned less than the state minimum wage because he had to apply his wages towards his vehicle expenses. Vasquez also alleged that he repeatedly asked for reimbursement from his supervisors, and that his supervisors were aware of his financial situation. The court of appeal allowed Vasquez to proceed with his claim because a reasonable trier of fact could find that an employee had no option but to resign when an employer passes on its operating expenses to a low wage worker by failing to reimburse the employee for the expenses.
Employers should be mindful that they are statutorily obligated to reimburse employees for necessary work expenditures. Failing to reimburse employees for expenses the employer should have covered will not generally be sufficient to pursue a constructive discharge claim. However, it may when the employee’s hourly wage is close to the minimum wage. (The minimum wage will increase from $8.00 per hour to $9.00 per hour beginning July 1, 2014.) More commonly, employees will seek recovery of unreimbursed expenses by filing a claim with the Labor Commissioner. Awards for reimbursement carry 10% interest.
DID YOU KNOW…
When an employee takes leave under the Family and Medical Leave Act (FMLA), employers must return the employee to work after receiving a certification from the employee’s health care provider that the employee is able to work. But, employers may require a fitness for duty exam thereafter if they have reason to question the health care provider’s opinion. White v. County of Los Angeles (Cal. Ct. App., Apr 15, 2014) 22 Wage and Hour Cas.2d (BNA) 676.
The California Labor Code Private Attorneys General Act of 2004 (“PAGA”) does not provide a basis for employers to remove PAGA actions from state to federal court. PAGA allows employees to bring claims on behalf of the State of California against their employers. PAGA claims seek statutory penalties for violations of the California Labor Code, such as overtime and meal and rest period violations. Under PAGA, employees can bring the action on their own behalf and on behalf of other aggrieved employees and recover twenty-five percent of the statutory penalties, in addition to attorneys’ fees and costs. (The State retains seventy-five percent of the statutory penalties.)
In Baumann v. Chase Inv. Services Corp., 2014 WL 983587 (9th Cir., March 13, 2014, 12-55644), Baumann sued his employer in California state court under PAGA based on statutory violations for withheld overtime pay. Baumann did not assert any federal claims. However, Baumann’s employer removed the action to federal court based on the federal Class Action Fairness Act of 2005 (“CAFA”), which confers original jurisdiction in federal courts for certain class actions. Baumann’s employer argued that the PAGA claims were a class action under CAFA. The district court found removal to federal court was proper. The Ninth Circuit Court of Appeal reversed. The Court of Appeal held that the district court did not have original jurisdiction over Baumann’s removed PAGA suit under CAFA. The Court of Appeal determined that PAGA actions are not sufficiently similar to federal class actions because they are not claims for class relief. Rather, they are enforcement actions “filed on behalf of and for the benefit of the state.” Accordingly, CAFA did not provide a basis for federal jurisdiction of the PAGA lawsuit.
When employers are served with a lawsuit by their employees, one of the first considerations for defending that lawsuit will be deciding venue for the action in state or federal court. Employees generally file employment actions in State court. Employers oftentimes prefer to defend employment lawsuits in federal court. Federal courts have stricter pleading requirements, expedited discovery schedules, and may even be considered more employer friendly. Employers need to establish a grounds for federal jurisdiction in order to remove a state action to federal court. PAGA will not provide grounds for removing an action from state to federal court. But, a federal court may allow a PAGA action to proceed in federal court if the federal court has other grounds for establishing federal jurisdiction.
_______________________________________________________
DID YOU KNOW…
Employees have one year from the date of an allegedly wrongful act to file a complaint with the Department of Fair Employment and Housing under the Fair Employment and Housing Act (FEHA). Parties to a contract can agree to shorten statutes of limitation as long as the shortened period is reasonable, BUT employers probably cannot shorten the FEHA statute of limitations. Ellis v. U.S. Security Associates, 14 Cal. Daily Op. Serv. 3098 (Cal. Ct. App., Mar. 20, 2014) (six-month period not enforceable).
______________________________________________________
As an attorney who practices primarily in the construction defect arena, I read Dr. Craner’s commentary1 with particular interest. My practice includes both prosecution as well as defense of owners and developers in residential and commercial property cases, many of which have a “mold” component. Indeed, my deposition of Dr. Bruce Kelman in the Kerruish v. Kimball Hill Homes case is cited in Craner’s article.
In my many years of experience on both the plaintiff and defense sides of the “mold” debate, i.e., whether and to what extent indoor mold arising in water-damaged buildings is a valid, diagnosable, treatable, and preventable environmental health disorder, I have, since its publication, consistently observed defense experts relying upon the ACOEM’s statement on “Adverse Human Health Effects Associated with Molds in the Indoor Environment”2 as the “final” scientific word on the issue. Plaintiff experts, on the other hand, are routinely challenged to defend and prove the scientific basis of their affirmative opinions as a rebuttal to the ACOEM Statement.
Those of us who practice in this area have long suspected that the heretofore concealed process by which the ACOEM Mold Statement was created was flawed and biased, not only in its content and balance as an “evidence-based” guideline, but especially in its tone, which blatantly comes across as a “defense argument” to any attorney willing to read it. How can any advocate come away with any other impression when the same experts who were profiting from defense medical/legal consultations and testifying in mold-related litigation were incredibly selected by ACOEM to be the primary authors of its organizational position statement on this subject?
Dr. Craner’s critique has finally brought some light and balance to the issue. Construction defects and resultant litigation related to indoor mold will go on, but I strongly suspect the ACOEM Mold Statement will no longer receive the same level of reliance or respect that it has been unduly given up to this point by attorneys and experts. ACOEM, as an organization, has major credibility problems as a result of this document and would do well to follow Dr. Craner’s recommendations to restore organizational integrity and respect.
References
1. Craner J. A critique of the ACOEM statement on mold: undisclosed conflicts of interest in the creation of an “evidence-based” statement. Int J Occup Environ Health. 2008 Oct-Dec;14(4): 283-98.
2. Adverse Human Health Effects Associated with Molds in the Indoor Environment. Journal of Occupational and Environmental Medicine:Volume 45(5): 470-478 (2003).
Wilke Fleury successfully obtained licensure for its dental disability insurance client, Premier Access Insurance Company, in six states. Wilke Fleury Partner Michael G. Polis obtained licensure for Premier Access in New York, Kentucky, Florida, New Jersey, Pennsylvania and Virginia. The licensure allows Premier Access to operate as a dental insurance company for PPO and indemnity dental products throughout the eastern seaboard. Previously doing business only on the west coast, these additional licensures significantly expand the scope of Premier Access’ offerings.
This website uses cookies to improve your experience. We'll assume you're okay with this, but you can opt-out if you wish. Cookie SettingsACCEPT
Privacy & Cookies Policy
Privacy Overview
This website uses cookies to improve your experience while you navigate through the website. Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may have an effect on your browsing experience.
This website uses cookies to improve your experience while you navigate through the website. Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may have an effect on your browsing experience.
Necessary cookies are absolutely essential for the website to function properly. This category only includes cookies that ensures basic functionalities and security features of the website. These cookies do not store any personal information.
Any cookies that may not be particularly necessary for the website to function and is used specifically to collect user personal data via analytics, ads, other embedded contents are termed as non-necessary cookies. It is mandatory to procure user consent prior to running these cookies on your website.
