Veterinarians are exposed to liability threats each time they encounter a potentially dangerous animal in a clinical setting. Fortunately, you have several weapons at your disposal to minimize your risk.
Written Warnings and Notifications
The first line of defense against liability is the use of written warnings and notifications. This encompasses warnings issued to staff members and pet owners, as well as compliance with statutory notification requirements, which are requirements imposed by California law. Examples of statutory notification requirements include:
Duty to inform law enforcement when you believe an animal has been a victim of abuse.
Duty to inform law enforcement when you believe an animal has been injured or killed in a staged fight.
Duty to report injuries occurring at rodeos.
Duty to report suspicions of a rabid animal or rabid animal bite.
Referrals
In some cases, referrals of dangerous animals can help protect against liabilities.
Prescriptions
Prescription medication can sometimes help with known behavioral problems. However, it is important to provide the animal’s owner with complete, detailed instructions any time medication is prescribed.
Insurance
Since you cannot possibly neutralize every threat of liability, strive to keep appropriate insurance policies in place to protect your practice. The type and amount of coverage you need will depend on the nature of your practice, your specialty and other factors. When selecting an insurance policy, remember to consider your own personal comfort or discomfort with risk, as well as the value of your business and personal property.
As a veterinarian with a complex practice, you can be subject to a number of different employment laws. Failure to follow these laws can result in expensive, traumatic incidents that have the power to destroy the practice you have worked so hard to build. To prevent these problems, you should take the time to familiarize yourself with the various employment-related legal issues that may affect your practice. Some of these laws include:
Discrimination – Federal and state laws prohibit you from discriminating on the basis of age, sex, disability, national origin, religion, race or other such characteristics. For example, it is illegal to exclude someone from consideration for a promotion because he or she is older than another candidate.
Sexual Harassment – Sexual harassment laws protect workers from unwanted advances, bullying and coercion of a sexual nature. These laws encompass a wide variety of incidents, from disparaging remarks about an individual’s sex in general to requests for sexual favors.
Whistleblower Claims – Multiple laws protect employees from retaliation when they report fraud or dangerous work conditions in good faith. For example, if an employee suspects fraud and reports his or her suspicions, you cannot take action against that employee.
Leave Laws – When an employee is absent, several leave laws may govern the employer’s actions, including the Americans with Disabilities Act, the California Family Rights Act and/or the Family Medical Leave Act. Different laws may apply depending on the nature of the absence.
Disability – Under the Americans with Disabilities Act, employers must identify employees with disabilities and make reasonable accommodations for these individuals.
Meal and Rest Periods – In California, unpaid meal periods must be at least 30 minutes long, and paid rest periods must be at least ten minutes long.
Worker’s Compensation – When employees are injured on-the-job, they can file workers compensation claims. Employers are unable to retaliate against employees who file these claims.
Independent Contractors – Employers aren’t required to satisfy as many legal requirements when dealing with independent contractors. However, attempting to classify employees as independent contractors when they don’t meet the qualifications is never a good idea.
Covenant Not to Compete – In general, California doesn’t allow non-compete agreements except in limited circumstances. While you can expect loyalty from employees during the term of their employment with your veterinary practice, you won’t be able to enforce any non-compete covenants after employment has been terminated.
Electronics, Technology and Social Media – Laws pertaining to social media, technology and related issues can be complicated, and further developments are expected in this area. However, employers should have clear policies with regard to technology that detail the rights and responsibilities of employees.
Veterinarians have a number of duties to satisfy in order to comply with the requirements of the law. Some of these duties include:
Providing Competent Care to the Patient
As a veterinarian, you have a responsibility to provide quality, competent care to every patient you encounter. This responsibility applies to every task you perform as you care for patients, including:
Physical exam
Diagnostic testing
Selecting a treatment
Performing procedures/Administering treatments
Aftercare
Recordkeeping
In order to discharge this duty, you must act competently at all times. Examples of negligence with regard to this duty include:
Failing to perform a thorough exam.
Misreading the results of diagnostic tests.
Selecting an inappropriate treatment.
Performing a treatment without consent.
Recording health-related information inaccurately
Supervise Staff
Veterinarians are responsible for their own actions, as well as the actions of their staff members. In fact, under a legal theory known as “respondeat superior,” you can even be held legally liable when your employees are negligent.
For example, assume an inexperienced and unsupervised employee is instructed to administer medication to a patient in Room 1 but accidentally administers the medication to a patient in Room 2. In this case, both patients may suffer side effects, and you can be held responsible for any and all of the consequences. Thus, it is essential to supervise staff members responsibly at all times.
Maintain Safe Business Operations and Facilities
As a veterinarian, you are both a clinician and a business owner. Thus, you are vulnerable to all of the same liabilities as other business owners, including on-site injuries sustained by clients, staff members and visitors. For example, if a visitor to the facility falls on a wet floor, trips over an animal’s carrier or is attacked by an improperly restrained animal, you may be held responsible for any resulting injuries.
To protect yourself and your practice, it is important to:
Develop procedures and protocols for keeping the premises safe.
Teach staff members to identify and resolve threats to safety when they occur.
Title VII of the Civil Rights Act of 1964 (“Title VII”) prohibits discrimination on the basis of sex. The U. S. Equal Employment Opportunity Commission (“EEOC”) is the federal agency charged with enforcing Title VII’s prohibition of employment discrimination on the basis of sex, and it recently determined that prohibited sex discrimination under Title VII includes discrimination based on “sexual orientation.”
In Complainant v. Foxx, E.E.O.C. Appeal No. 0120133080 (July 16, 2015), the employee alleged that he was not promoted because he was a gay man. The EEOC determined that the employee successfully stated a claim for sex discrimination under Title VII. In its ruling, the EEOC determined that sexual orientation discrimination is a form of sex discrimination for three reasons. First, because “sexual orientation” cannot be defined without referring to sex, sexual orientation discrimination is sex discrimination “because it necessarily entails treating an employee less favorably because of the employee’s sex.” Second, sexual orientation discrimination constitutes sex discrimination because it is a form of associational discrimination-treating an employee differently because the employee associates with a person of the same sex. Finally, sexual orientation discrimination is sex discrimination since it is based on gender stereotypes. The idea that a man should only be attracted to women and vice versa is the ultimate gender stereotype.
Federal courts generally defer to EEOC decisions, but do not have to follow them. A number of federal courts of appeal, before the EEOC’s decision, determined that Title VII does not encompass discrimination based on sexual orientation. Regardless of whether federal courts follow the EEOC’s decision, employment discrimination based on sexual orientation is specifically prohibited under California’s Fair Employment and Housing Act. The EEOC’s recent decision presents an opportunity for employers – especially employers who operate in other states besides California – to review their discrimination policies and practices to ensure compliance with the state and federal discrimination laws in each state where they operate, particularly with respect to sex and gender discrimination (e.g., gender, gender identity, gender expression, and sexual orientation).
DID YOU KNOW…
Employers who fail to provide meal and rest periods are required to pay premium pay (an additional hour of pay) for each workday that their employees miss meal or rest periods. Their employees are automatically entitled to premium pay without having to request it, and the employer’s failure to pay such premium pay may constitute an unfair business practice. Safeway, Inc. v. Superior Court of Los Angeles County, 238 Cal.App.4th 1138 (2015) (upholding class certification for violation of Unfair Competition Law based on employer’s failure to pay premium pay when due).
The Veterinary Medical Board’s “Cite and Fine” Program was first implemented in 1990 to aid in the processing of complaints made against veterinarians. “Cite and Fine” issues can be the result of a number of problems, ranging from inadequate recordkeeping to violations in another state. These issues can not only cost your practice money, but they can also lead to more serious disciplinary actions in some cases. For these reasons, strive to protect yourself from “cite and fine” issues as much as possible. To protect your practice, follow these tips:
Keep detailed records.
Failing to keep adequate records on every patient is a common cause of “cite and fine” incidents. Not only can inadequate recordkeeping result in a citation on its own, but it can also complicate other cases that rely on complete records for evidence.
Prevent problems associated with inadequate recordkeeping by creating detailed, complete records for every patient you treat. Establish clear record keeping procedures, educate your staff with regard to these procedures, and make sure that everyone follows these systems at all times and that you and your team amend and refresh them as necessary (for instance, when your office changes locations or gets new computers).
Maintain adequate insurance coverage.
Even with preventative measures in place, you may still encounter VMB complaints. Protect your practice from financial loss by maintaining an appropriate insurance policy. The exact type and amount of insurance you will need depends on the nature of your practice, your specialty and your level of exposure, so it is wise to consult an insurance agent for guidance before you select a policy.
Consult an attorney when necessary.
When an incident occurs or a claim is filed, consult a qualified attorney early in the process. Attempting to deal with these issues on your own may lead to unnecessary financial loss, damage to your reputation and other such consequences. On the other hand, an attorney who has experience dealing with VMB cases can help you gather the evidence you need to defend yourself against the accusations and minimize the likelihood of a citation or more significant disciplinary action.
Health care service plans licensed under the Knox-Keene Health Care Service Plan Act of 1975, as amended, (the “Knox-Keene Act”) are categorized as either full-service or specialized health care service plans. A full-service license is issued to an entity that provides, at minimum, six basic health care services (e.g., physician services, inpatient hospital services, home health services, etc.). Examples of full-service health care service plans include Kaiser and HealthNet. A specialized license is issued to an entity that provides health care services in a single area such as dental, vision, or mental health. One such example is Vision Service Plan (VSP).
Although, it isn’t clear from the Knox-Keene Act or the regulations issued by the Department of Managed Health Care (the “DMHC”), a subcategory exists: a restricted (full-service or specialized) Knox-Keene license. A restricted licensee is “restricted” to provider contracting, and is not permitted to contract directly with employer groups and individuals. This means that the licensee does not create its own products nor does it participate in marketing. Instead, the entity subcontracts with other health care service plans or contracts directly with government payors, such as Centers for Medicare & Medicaid Services or CMS, in which products have already been developed.
Naturally, certain supplemental information to the application (called an “exhibit”) does not apply to the restricted licensee and is not required in the licensee’s filing. This includes exhibits related to marketing and group and individual contracts. The exhibit requirements further deviate depending on the type of product offered: Medicare, Medi-Cal (Medicaid), or commercial.
Generally, the application process for a restricted license still requires a fairly thorough review of network adequacy, quality of care processes, grievance procedures, and so forth. This is the case for both Medi-Cal and commercial offerings because the regulation of Medi-Cal (Medicaid) and commercial products is widely left to the states. Since the regulation of Medicare is a function of the federal government (CMS), the DMHC is limited in its review of Medicare products. As a result, the DMHC will spend most of its time reviewing the applicant’s financial viability as opposed to a more encompassing review that would include network adequacy and quality of care processes.
Of course, to some degree, the exhibits that the DMHC would require in any given filing may change based on the current state of the law. To the extent that you may have any questions, feel free to contact myself or my colleague, Michael G. Polis.
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The term “duty of care” refers to the way in which you must interact with your clients and patients in order to satisfy the requirements of the law. For California veterinarians, this amounts to:
Being a competent care provider.
Being humane.
Providing care that is consistent with the current veterinary practice standards.
Since “current” veterinary practice standards are continuously evolving, the duty of care evolves as well.
Negligence
When a veterinarian fails to meet the required standard of care, he or she may be guilty of “negligence.” In order to establish veterinary negligence, a plaintiff must show that:
The veterinarian had a responsibility to care for the animal (duty of care).
The veterinarian didn’t act in accordance with the appropriate standard of care.
The veterinarian’s failure to provide adequate care was a proximate cause of injury, which means that the injury occurred as a direct result of the action and would not have occurred if the veterinarian had acted appropriately.
Examples
1. A client brings her cat Lucy in for her annual shots. An inappropriately high dosage is administered, and the animal dies as a result. In this case, the client can sue for negligence because the veterinarian:
Was responsible for providing care to the animal.
Did not act in accordance with pertinent standards of care.
Was the direct cause of the animal’s death.
2. A client brings his dog Fido in for a checkup. After collecting the necessary information and obtaining consent to treatment, the veterinarian administers an appropriate heartworm prevention medication at the correct dosage. The animal has a severe and highly unusual reaction to the medication. In this case, the veterinarian is not guilty of negligence. Even though the veterinarian’s actions were a cause of the animal’s injuries, he or she was acting in accordance with accepted standards of care, and most other veterinarians would have made the same choices.
The Veterinary Medical Board’s “Cite and Fine” Program was first implemented in 1990 to aid in the processing of complaints made against veterinarians. These guidelines are used to address violations of the law that are not serious enough to warrant criminal prosecution or the suspension or revocation of a veterinarian’s license to practice. In these cases, the VMB issues a citation, and the veterinarian must pay a fine.
Common “Cite and Fine” Issues
Examples of issues that may result in a citation and fine include:
Discipline of license in another state
Unprofessional conduct
Animal abuse or cruelty
Failure to keep premises and/or equipment clean and sanitary
Record keeping violations
Record confidentiality violations
Of these issues, one of the most common citations veterinarians encounter is inadequate recordkeeping. This issue can result in a citation on its own, or it can complicate other actions initiated against the practice. In general, the VMB holds to the belief that information not contained in the records cannot be taken as fact. Thus, this issue often acts as a jumping-off point for more extensive disciplinary actions.
For example, assume a client brings action against your practice on the basis that you did not provide competent care to her pet. Even if the client’s story is misleading, embellished or completely inaccurate, you won’t have a leg to stand on if you don’t have detailed records to support your side of the story. The VMB won’t simply take your word as fact if you have no written documents to back up your position. Thus, you may find yourself facing unnecessary penalties simply because you failed to keep adequate records.
David has extensive and broad experiencein the areas of complex civil litigation, with particular emphasis on the representation of residential and commercial property owners in construction-related disputes. David represents homeowners, homeowner associations, developers and contractors in real estate cases, as well as complex construction defect claims involving multiple single-family residences and multi-unit developments.
Ernest James Krtil – Closely Held Companies and Family Business Law
Jim’s depth of experience in his practice emphasizes business law including mergers and acquisitions, nonprofit organization law and taxation, as well as estate planning and probate and trust administration, including trust and estate disputes.
Employment agreements commonly include a provision designating the place or forum where any employment related-claims must be litigated. Ordinarily, the party opposing a forum selection clause has the burden to demonstrate that the clause should not be enforced. However, the burden is reversed when the underlying claims are statutory rights that may not be waived, such as California Labor Code provisions concerning employee compensation. In such cases, the party seeking to enforce the forum selection clause must demonstrate that the forum selection clause will not diminish the statutory rights; otherwise, the clause will not be enforced.
In Verdugo v. Alliantgroup, L.P., 237 Cal.App.4th 141 (2015), the employer was headquartered in Harris County, Texas, and had regional offices in other states, including California. The employer hired an employee to work at its California office, and required her to sign an employment agreement. The employment agreement included a forum selection clause designating Harris County, Texas as the forum for litigation. The employee filed a lawsuit in California based on various provisions of the California Labor Code concerning proper pay, meal and rest breaks, and wage statements that the Legislature declared cannot be waived by private agreement. The employer moved to stay the action based on the forum selection clause. The employer did not demonstrate that Texas would have applied California law, or, that Texas provided the same or greater rights as California. As a result, the California court of appeal did not stay the action and the lawsuit continued in California.
Employers with California employees should review their forum selection clauses because forum selection clauses that violate California’s public policy on employee compensation will not be enforced. Employers desiring to litigate employment related claims outside California should determine the likelihood that the clauses will be enforced. Provisions designating California law as the applicable law (choice of law provision) may make it more likely that the forum selection clause will be enforced, provided that the forum state would enforce the provision and apply California law. Or, employers may just need to consider alternative forums for claims by their California employees.
DID YOU KNOW…
Generally, prevailing parties in civil litigation are entitled to an award of their litigation costs. Not necessarily so with respect to claims under the Fair Employment and Housing Act, or FEHA. In FEHA cases, the California Supreme Court recently ruled that prevailing employees should ordinarily receive their costs (and attorney fees), but prevailing employers should not be awarded costs (or attorney fees) unless “the action was objectively without foundation when brought, or the [employee] continued to litigate after it clearly became so.” Williams v. Chino Valley Independent Fire Dist., 61 Cal.4th 97, 115 (2015).
The National Labor Relations Board (“NLRB”) enforces the federal National Labor Relations Act (NLRA), which applies to most private employers. Periodically, the General Counsel of the NLRB releases reports to clarify issues that arise in the workplace. One of the more recent reports discusses the lawfulness of employee rules found in a number of different employee handbooks. Section 7 of the NLRA protects the rights of all employees, not merely unionized employees, to communicate with one another or third parties at or away from work regarding terms and conditions of employment. Section 8 of the Act makes it unlawful for employers to interfere with, restrain or coerce employees in the exercise of their Section 7 rights.
Many of the examples of unacceptable employee handbook language were provisions containing broad, general language that would encompass Section 7 rights, whether or not that was the employer’s intention. Section 7 allows employees to be critical of their employer and management. Consequently, a handbook provision requiring employees to “[b]e respectful of others and the Company” would violate Section 7 because the rule would prohibit employees from criticizing working conditions and labor policies. Similarly, employers cannot institute general prohibitions on “negative” or “inappropriate” discussions among employees, but could more narrowly ban harassment of employees or prohibit the “use of racial slurs, derogatory comments, or insults” by employees.
Policies requiring employees to direct or refer all inquiries from the media or government to a particular person in the company would also violate Section 7 because employees have a right to speak about employment matters and labor concerns. Employers have a right to present their official position, but employees also have a right to communicate with the media, government and other third parties on their own behalf.
A handbook provision instituting a general prohibition on the use of company logos without permission would also run afoul because Section 7 protects non-commercial use of company logos by employees on protest materials, such as picket signs or leaflets. Section 7 would not protect employees in disparaging the employer’s product or customers, though.
The NLRB appears to be taking a greater interest in non-unionized workplaces under Section 7, and non-unionized employers should take note. Ultimately, whether a provision will be permissible will depend on how employees would interpret the clause, and context matters. Clauses that would otherwise be impermissible may be fine if employees would understand them to be limited in scope so as not to interfere with their Section 7 activity. Employers should review their policies (including email and social media policies), arbitration agreements, and handbooks to ensure compliance with Section 7 and the NLRA’s recent guidance. Otherwise, they could face an unfair labor practice charge prompting an investigation and an administrative action to remedy any unfair labor practice.
DID YOU KNOW…
The U.S. Supreme Court recently ruled that an employer may not discriminate against a job applicant’s religious beliefs during the hiring process under federal law (Title VII), even if the employer does not have actual knowledge of the need for a religious accommodation. E.E.O.C. v. Abercrombie & Fitch Stores, Inc. (2015) 135 S.Ct. 2028, 2031 (failure to hire Muslim applicant who wore a headscarf because the headscarf conflicted with company dress code).
* Kathryne is currently a law student at The University of the Pacific, McGeorge School of Law and was hand-selected for a 2015 summer clerkship with Wilke Fleury. She is also a member of McGeorge’s Nationally Ranked Mock Trial Team and is President of the McGeorge Women’s Caucus.
Twelve of Wilke Fleury’s attorneys have been listed as 2015 Northern California Super Lawyers and Rising Stars. The firm’s Super Lawyers are Dan Baxter, Philip Birney, Daniel Egan, George Guthrie, Ronald Lamb, Stephen Marmaduke, Thomas Redmon and Robert Tyler. The firm’s Rising Stars are Anthony Eaton, Samson Elsbernd, Bianca Watts and Steve 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.
The California Healthy Workplaces/Healthy Families Act of 2014 has been operative since January 1, 2015 even though employees have not yet begun to accrue sick leave pursuant to the law. Employees will only begin to accrue sick leave pursuant to the law on July 1, 2015.
The California Healthy Workplaces/Healthy Families Act of 2014 requires that employers, subject to very limited exceptions, provide paid sick leave to their employees. The new law covers exempt and non-exempt (including part-time, per diem, and temporary) employees. Employees who have worked in the State for 30 or more days within a year from the start date of their employment will accrue paid sick leave at the rate of one hour for every 30 hours worked, and may use their accumulated leave beginning on the 90th day of employment.
Paid Sick Leave law went into effect on January 1
Since January 1, California employers have been obligated to post the Labor Commissioner’s Healthy Workplaces/Healthy Families Act poster in a conspicuous location in the workplace. The information about the new law is also contained in the revised Notice to Employee, which is the Labor Commissioner’s form for newly hired non-exempt employees that contains employment-related information, such as pay rates and entitlement to sick leave. Employers have been using this revised form for non-exempt employees who are hired after January 1, 2015. As to non-exempt employees hired pre-January 1, 2015, employers already provided written notice of the sick leave law information on a revised Notice to Employee or in another writing, or will provide such notice by July 8, 2015, depending on date of implementation of their policy or the new law’s requirements.
Employees begin to accrue sick leave pursuant to the Paid Sick Leave law on July 1
Starting July 1, employees will accrue paid sick leave either pursuant to the Healthy Workplaces/Healthy Families Act only or pursuant to employer sick leave policies. Employees who simply accrue paid sick pursuant to the minimum requirements of the new law will accrue approximately 8 days (69 hours) of paid sick leave each calendar year, with accrued, unused paid sick leave carrying over to the following year.
Conversely, employees may accrue paid sick leave pursuant to employer sick leave or paid time off (PTO) policies. Employers, through sick leave or PTO policies, may cap the accrual and use of paid sick leave available to their employees pursuant to the Healthy Workplaces/Healthy Families Act. For example, company paid sick leave policies may limit full-time employees to using 3 days (24 hours) of paid sick leave in each year of employment. Accrued but unused paid sick leave must carry over from year to year unless employers simply advance the full 3 paid sick days at the beginning of each year. Employers may cap total accrual of paid sick leave at 6 days (48 hours).
Before employers simply fall back on their written paid sick leave or PTO policies, though, they should ensure that those policies satisfy the accrual, carryover, and use requirements of the Healthy Workplaces/Healthy Families Act. In other words, employer policies must meet the minimum requirements of the new paid sick leave law, and if they do, then employers do not have to provide additional sick leave. If they do not, employers must either modify their polices or allow their employees to accrue paid sick leave pursuant to the new law. Of course, employer policies may also exceed the minimum legal requirements of the new law.
Finally, employers should also be aware that the new law imposes record keeping requirements concerning sick leave, including requiring employers to provide written notice of the amount of sick leave available on the employee’s itemized wage statement or in another writing, and to maintain records concerning sick leave for 3 years.
The California Fair Employment and Housing Act (“FEHA”) protects employees from employment discrimination based on mental disability. “Mental disability” is broadly defined under FEHA, and includes mental disorders and conditions that limit major life activities, like working. This is broader than the federal Americans with Disabilities Act, which requires that mental impairments “substantially limit” major life activities. Still, not all mental impairments rise to the level of a “mental disability” under FEHA.
In Higgins-Williams, No. C073677, 2015 WL 3451590 (Cal. Ct. App. May 26, 2015), an employee was diagnosed by her physician as suffering from anxiety and stress due to her normal interactions with her supervisor and the human resources department. The employer was aware of the diagnosis and granted the employee leaves of absence, including leave under the FEHA as a disability accommodation. The employer eventually terminated the employee when she failed to provide information as to when she could return to work or that additional leave would effectuate her return, and the employee sued alleging various causes of action, including disability discrimination. The trial court granted the employer’s motion for summary judgment on all causes of action and the court of appeals affirmed, largely because an inability to work under a particular supervisor because of anxiety and stress related to the supervisor’s standard oversight of job performance is not a mental disability recognized under the FEHA.
This case reaffirms that while FEHA’s definition of “mental disability” is broad, it is not limitless. Other impairments that are not considered mental disabilities include “sexual behavior disorders, compulsive gambling, kleptomania, pyromania, or psychoactive substance use disorders resulting from the current unlawful use of controlled substances or other drugs.” (Gov. Code section 12926(j)(5).) This case is also a good reminder for employers that a leave of absence may be a reasonable accommodation. However, an employer does not have to wait indefinitely for an employee’s return.
DID YOU KNOW…
It is unlawful for an employer to willfully misclassify an individual as an independent contractor. (Lab. Code § 226.8.) This prohibition applies to the employer making the misclassification, and to any joint employer who is aware that the co-employer has willfully misclassified their joint employees. Noe v. Superior Court, No. B259570, 2015 WL 3463006, at 1 (Cal. Ct. App. June 1, 2015).
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