Bulletin
The
AUGUST 2014
EMPLOYMENT LAW
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SURVEYS
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HUMAN RESOURCES
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TRAINING
Health Care Reform Compliance Series Part XXIII:
How a Part-Time Employee Can Cost Your Company $2 Million Peg McHugh, Human Resource Services Consultant, MA, SPHR, CEBS Page 1 Health Care Reform Compliance Series Part XXII: How a Part-Time Employee Can Cost Your Company $2 Million
Page 2 Tips for Managing Intermittent FMLA Leave and Reduced Leave Schedules
Page 3 The Importance and Benefits of Active Listening
Page 4 You Asked: What Qualifies an Employee for the Professional Exemption?
Page 6 Creating a Good Faith Defense Against Fair Labor Standards Act Claims
Page 7
Creating an Emotionally Intelligent Organizational Culture
Page 8 Focus on Retirement Plans – Audit Notice!
Page 10 Public Employers: Does Your Handbook State Your Intentions?
Page 11 Survey News
The Affordable Care Act (ACA) contains significant legal risks that few employers are aware of that have nothing to do with the structure or content of health insurance plans. Under the ACA, applicable large employers (50 or more “full-time” employees) must offer affordable, minimum-value coverage, to at least 70 percent of their full-time employees in 2015 (95 percent in 2016). Employers are not required to offer coverage to employees who work less than 30 hours a week (i.e., part-time employees). Failure to meet this 70-percent level of coverage can result in penalties of $2,000 per year for nearly each full-time employee, even those enrolled in the health insurance plan. For an employer with 1,000 full-time employees, the penalty is almost a $2 million non-tax-deductible expense. How can this happen? To illustrate, Lexicon Industries has 1,200 employees (1,100 full-time + 100 part-time. The company offers health insurance coverage to 70 percent of full-time employees (770) and no coverage to part-time employees. No penalty, no problem? Not exactly. If Lexicon misclassified only one employee as part-time, when the worker should be full-time under ACA standards, and that employee purchases health insurance coverage from an exchange and receives a subsidy, Lexicon has failed the 70-percent-coverage rule. The company offered coverage to 770 full-time employees, but actually had 1,101 full-time employees due to a single misclassification. Therefore, the company offered coverage to less than 70 percent of full-time employees triggering a tax penalty of nearly $2 million. While the Internal Revenue Service (IRS) can assess tax penalties against employers that do not offer compliant health insurance coverage to enough full-time employees, employees can “blow the whistle” on employers when they are denied coverage through the employer plan due to an erroneous classification. Congress amended the tax code to authorize payments to individuals who blow the whistle on businesses that fail to pay taxes owed. The $2 million tax penalty to the employer in this illustration could net the complaining employee $600,000. To minimize risk, employers should: 1. Correctly identify full-time employees using ACA standards, 2. accurately calculate part-time hours, and 3. review worker classifications to ensure they are compliant. Employers who try to use independent contractors rather than hire employees, or use a PEO, employee-leasing firm, temporary-staffing agency, or outsource functions to avoid ACA requirements may increase their potential liability. £
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Tips for Managing Intermittent FMLA Leave and Reduced Leave Schedules Denise Fazio, Human Resource Services Consultant, Ed.D., SPHR
Under the Family Medical Leave Act (FMLA), an employee may be eligible to take protected leave intermittently or on a reduced leave schedule—as opposed to weeks consecutively—when leave is based on a medical necessity or a qualifying military exigency. This means eligible employees may take leave in separate blocks of time due to a single qualifying reason (e.g., their own serious health conditions, or that of family members, the birth or placement of children). Or, employees may take leave based on a schedule that reduces the employee’s usual number of working hours each workweek, or their working hours per work day. In each case, the total amount of leave time taken cannot exceed 12 weeks within a 12-month period. Reduced leave schedules can be particularly challenging to administer. And, unfortunately, the FMLA does not consider any “hardship” the employer may experience in trying to maintain day-to-day operations while adhering to these requirements. Here are some suggestions for managing the process to balance the obligations and needs of the organization with the employee’s rights:
• Be proactive. Maintain ongoing two-way communications with the employee about planning, using, and
recording intermittent leave time, while being careful not to intrude into the employee’s personal medical history.
• Establish an expectation that the employee make a reasonable effort to schedule time away for medical treatments to avoid unduly disrupting your business operations—subject to the approval of the health care provider.
• Question FMLA certification forms that are vague or include blanket statements, such as “intermittent
leave recommended”; request more specific information from the employee’s health care provider about the medical necessity for the time off and the expected duration. (Note: Only an HR professional, a leave administrator, or a management official, other than the employee’s direct supervisor, may contact the health care provider for clarification or authentication of a certification form.)
• Ask for a new certification form from the employee’s health care provider, if an employee’s requests for time off exceed the time stated on the FMLA certification form. (Note: Where you have reason to doubt the validity of the information provided in the initial medical certification form, you can require the employee to see a company-selected physician for a second opinion.)
• Consider temporarily transferring an employee to a position better-suited for recurring leave or part-time work, while ensuring the employee receives equivalent pay and benefits so he or she is not penalized by the transfer or dissuaded from taking leave. (Note: The alternative position does not have to have equivalent duties.)
• Determine what other laws apply and may need to be considered (e.g., Americans with Disabilities Act, worker’s compensation.)
• Make certain you understand your statutory obligations as an employer and consistently follow your own FMLA-compliant procedures. In addition, track usage; look for patterns to reduce improper usage; and investigate suspected abuse.
• Do not delay in seeking legal/professional advice if you are uncertain about your obligations as an employer and how best to meet them. £ 2 | The Bulletin | August 2014 | MSEC.org
The Importance and Benefits of Active Listening Bev Sinclair, Human Resource Services Consultant, MBA, SPHR-CA
Have you ever worked for a manager who did not take the time to listen to you? Picture this, you walk into your manager’s office and ask if you can speak with him. He says yes, but proceeds to pound away on the keyboard. You ask if he would prefer to speak another time and he says, “I’m listening!” How would you feel? You may feel unimportant, or, at the very least, you may feel that your manager does not care to hear what you have to say. Unfortunately, this scenario occurs all too frequently in the workplace and is detrimental to the manager-employee relationship as well as productivity and morale. Listening is said to be the earliest communication skill humans acquire, but the least understood. Active listening is the highest form of listening. How can managers become masters of active listening? We can make a conscious effort to do more than simply hear. We can:
1. Give the speaker our full attention. This means taking time out from our current task to show the speaker that we care about what they have to say.
2. Give good eye contact. 3. Listen for the speaker’s main points. 4. Show we are listening by leaning forward, nodding, or giving verbal signals for the speaker to continue such as, “yes” and “uh-huh.”
5. Don’t interrupt. If we are speaking, we cannot listen with our full attention. 6. Wait for the speaker to pause before asking clarifying questions. 7. Respond appropriately and recap main points to be sure you have a clear understanding of the message. 8. When listening to others, it is also important to listen without emotion and react only to the message. By practicing active listening, we can reduce errors, increase performance, improve teamwork, increase trust, resolve problems, and improve our manager-employee relationships—all of which will positively influence the bottom line of our organization. £
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What Qualifies an Employee for the Professional Exemption? Tina Harkness, Information Resource Manager, Esq., SPHR
This month we are discussing the Professional Exemption. This is perhaps the broadest exemption as it encompasses three groups: Learned Professionals, Creative Professionals, and Computer Professionals. To qualify for the Professional Exemption, an employee must: 1. Be paid on a salary basis at a rate not less than $455/week (see Salary Basis Exceptions below) 2. Be primarily engaged in professionally exempt work 3. Primary duty includes the consistent exercise of discretion and judgment in making independent choices in significant matters SALARY BASIS EXCEPTIONS: Computer Professionals may be paid on an hourly basis, if the hourly rate is $27.63 or greater. Some professionals can be paid on a fee basis if the fee is at a rate that would amount to at least $455/ week if the worker worked 40 hours. Learned Professionals perform work requiring advanced knowledge in a field of science or learning customarily acquired by a prolonged course of specialized intellectual instruction. This exemption is limited to professions where specialized academic training is a standard prerequisite like: • Law
• Engineering
• Medicine
• Architecture
• Theology
• Teaching
• Accounting
• Physical, chemical, and biological sciences
• Actuarial computation
• Pharmacy
Federal regulations list academic teachers in educational institutions, registered or certified medical technologists, registered nurses, dental hygienists, physician assistants, certified public accountants, chefs, certified athletic trainers, and licensed funeral directors and embalmers as positions that may qualify for the exemption, but exclude paralegals and legal assistants. WORDS TO THE WISE: The best evidence that an employee meets this requirement is possession of the appropriate academic degree. However, positions that allow workers to have one of multiple degrees may not qualify. Similarly, equivalent experience generally does not substitute for a degree. WORDS TO THE WISE: The work must be predominantly intellectual and varied in character so that the output or result is not standardized. For example, while technicians may possess a high degree of skill and intellectual capacity, the tasks they perform involve limited discretion or judgment and are usually non-exempt.
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You Asked! continued
Creative Professionals perform work requiring invention, imagination, originality, or talent in a recognized field of artistic or creative endeavor, such as: • Music
• Acting
• Writing
• Graphic arts
Examples include actors, musicians, composers, conductors, soloists, painters, cartoonists, essayists, novelists, short story and screen play writers, but generally exclude animators, copyists, or retouchers of photos. Journalists may be included if their work is original and involves creativity rather than collecting, organizing, and reporting publicly available information. Computer Professionals perform work requiring: • Application of systems analysis techniques and procedures, including consulting with users, to determine hardware, software or system functional specifications; • design, development, documentation, analysis, creation, testing or modification of computer systems or programs, including prototypes, based on and related to user or system design specifications; • design, documentation, testing, creation, or modification of computer programs related to machine operating systems; or • a combination of the duties above. Computer systems analysts, computer programmers, software engineers, or other similarly skilled workers may qualify for this exemption. WORDS TO THE WISE: Workers engaged in technical support, the operations of computers or in the manufacture, repair, or maintenance of computer hardware and related equipment do not qualify. Next month, we will cover the Outside Sales and Highly Compensated Employee Exemptions. £
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Creating a Good Faith Defense Against Fair Labor Standards Act Claims Lorrie Ray, Director of Membership Development, Esq., SPHR
We all know that the Fair Labor Standards Act (FLSA) requires payment of minimum wage and overtime. You may not be aware that employers who fail to pay minimum wage and overtime may be required to pay not only back wages, but also liquidated damages equal to back wages owed. It is also true that willful violations of the law can create a three-year period of liability. Still, there are ways to avoid FLSA liability employers should be familiar with and understand. First, if the employer acts, ”in good faith in conformity with and in reliance on any written administrative regulation, order, ruling, approval, or interpretation, of the [the Administrator of the DOL Wage and Hour Division], ” the employer can avoid any liability. To meet this definition, the employer must be able to prove:
• an opinion letter signed by the Administrator of the Department of Labor (DOL) Wage and Hour Division— not someone who reports to the Administrator—exists; and,
• the employer meets all aspects of the description in the opinion letter. Assuming even one of the factors is not applicable will render the employer’s practice outside the opinion letter.
Second, even if the employer does not have an absolute defense, it can still avoid liquidated damages if it can convince a judge that the violation was committed in good faith, and the employer had reasonable grounds for believing it was following the law. This occurs when the employer either follows the advice of an attorney or information in a manual well known to provide advice and counsel on FLSA practices. Of course, if the employer fails to follow the advice of an attorney, or relies on an out-of-date manual, this undercuts the defense. This is a protection for employers under section 11 of the Portal-to-Portal Act passed in 1947—the FLSA passed in 1938—when legislatures began to understand how difficult it was to follow the law. Third, employers should know that willful violations that create three years of back liability are rare. The U.S. Department of Labor considers a violation willful if the employer was previously investigated for the violation and is subsequently found in violation of the law for the same reason. Most employers take care not to repeat violations, and this is great protection against a willful violation. FLSA compliance will continue to challenge employers as the current administration focuses on minimum wage issues, as well as promised changes to FLSA exemptions. If you have questions about how to follow this endlessly complicated law, please call MSEC or attend our wage-and-hour class to learn what you need to know to avoid liability. £
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Creating an Emotionally Intelligent Organizational Culture Anitra Lesser, Organizational Development and Learning Consultant, M.Ed
One of the most common calls we receive as Organizational Development Consultants is a request for support (often an immediate or urgent need) with an individual contributor, manager, high-level leader, department, leadership team, or entire organization experiencing ongoing, unresolved conflict. This conflict often manifests in individuals stonewalling the efforts of others, covert or overt sabotage, cultures of lack of accountability, increasing dissention and disengagement, mounting interpersonal tensions, and ultimately a loss in production, collaboration, and revenue. According to an article by the Institute for Health and Human Potential, “Executive SummaryThe Business Case for Emotional Intelligence”: • The main reasons organizations lose customers and clients are 70 percent related to a lack of emotional skills by customer representatives. • Seventy-five percent of careers are derailed for reasons related to emotional competencies, including inability to handle interpersonal problems; unsatisfactory team leadership during times of difficulty or conflict; or inability to adapt to change or elicit trust. • After a Motorola manufacturing facility provided training in stress management and emotional intelligence, productivity increased for 93 percent of employees. Statistics like these abound. Essentially, the business compass points to a rapidly growing need for organizations, small and large, to invest in Emotional Intelligence competence building. Research consistently shows that over 80 percent of the competencies that differentiate top performers are tied directly to Emotional Intelligence skills and capabilities. Emotional Intelligence (abbreviated as “EQ” or “EI”) is a term popularized by Daniel Goleman and refers to a well-developed ability to identify the source and impact of and then regulate one’s own emotions, and subsequently the ability to understand and effectively influence the emotions (and thus behaviors) of others. Taking this theory from idea to an engrained habit necessitates commitment to employee development and embedding EQ into the organization’s culture. Investigative reporter, researcher, and author, Charles Duhigg, “The Power of Habit: Why We Do What We Do in Life and Business,” cites Starbucks as an example of an organization that chose to make the practice/habit of EQ a way of life for their employees. Starbucks is known for investing millions for research and development into training their workforce in how to regulate their emotions and cultivate self-discipline and resilience. This has helped Starbucks build an empire with revenues over $10 billion a year. How might an organization take steps toward making EQ a workplace habit?
1. Work with Organizational Development consultants to do a cultural assessment about the current health and engagement of the workforce to determine employees’ needs and readiness.
2. Identify realistic goals, timeframes, and strategies for implementing EQ training and support. 3. Commit to creating a culture that consistently rewards employees for instituting EQ business practices. Neuroscience research shows that new habits are formed when the reward/payoff for new behaviors is greater than rewards of previous, long-standing behaviors.
4. Identify a guiding vision and motto. Howard Behar, former president of Starbucks said, “We’re not in the coffee business serving people. We’re in the people business serving coffee.”
What kind of business and culture are you creating? 7 | The Bulletin | August 2014 | MSEC.org
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Focus on Retirement Plans – Audit Notice! Peggy Hoyt-Hoch, Employment Law Services Attorney, SPHR, CBP, GBA Both the U.S. Department of Labor (DOL) and the Internal Revenue Service (IRS) are actively auditing employer retirement plans to both protect workers and educate managers and fiduciaries as to their plan oversight responsibilities. What can you expect if you receive a notice from a federal agency saying your company’s 401(k) or 403(b) plan has been selected for audit? The notice will introduce the auditor, set a deadline to respond, and provide an attachment listing the many documents you will need to produce. You may wonder, “Why was our plan selected?” Most often, “random selection” is the answer from the agency. In reality, there are a few possible reasons for selection. The first reason is one of your employees or former employees who participated in your plan reported some discrepancy or concern about their benefit. A second common reason for selection is you filed your Form 5500 late in a prior year. Even though you probably followed the now fairly smooth process for filing a late Form 5500, the mere delay will often pull the plan into an audit pool. The third, and hopefully less common reason, is the audit was triggered by feedback from a different arm of one of the agencies about another area of your organization that was recently audited, for example, a payroll or tax audit, a wage/hour audit, or even a health-plan audit. Least common is the truly random selection of a plan for audit. Upon receipt of the notice, the best advice is to schedule time to prepare yourself, your plans, your plan documents and financials, as well as your plan committee members (or board members) to present your plan in the best light possible.
• Notify your plan committee, provider, and plan counsel of the documents and reports needed. • Respond to the agency as promptly and courteously as possible, even if it is just to make introductions. • Request additional time if needed. Be prepared to explain the business reasons why you need more time.
As examples, you may have to gather the documents from various sources, or perhaps key members of your committee have overseas business trips scheduled during the requested timeframe.
• The agency typically asks you to schedule interviews with individual plan committee or board members.
Their ability to demonstrate knowledge and commitment to their fiduciary responsibilities and accurate plan management will go a long way in making a favorable impression on the agent.
• Where monthly payroll records, deposit advices, plan activity statements, trustee reports, reconciliation
reports, and the like are requested, it may be worth your time to hire a CPA to compile, review, format, and identify any key missing documents before the auditor arrives. Here the form and thoroughness of the presentation of documents also may reduce the amount of detail the auditor requests on follow up.
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MSEC strongly suggests that you complete this preparation well before the agency notice ever hits your desk. Advance preparation begins when your organization decides to adopt or to sponsor a qualified retirement plan. Before adopting a plan, the organization should understand the serious responsibilities it is accepting, and answer key preparatory questions early on like:
• Why do you want to sponsor a plan? • What are our real plan objectives? • Who will be the responsible plan committee members? • What sort of insurance and indemnification should the plan sponsor provide? • Who will come to conduct fiduciary training for the appointed committee members? • How will we communicate properly with employees? • Should we individually design our plan document, or adopt a prototype/volume submitter plan document from one of the turnkey plan providers or insurance companies?
• Should we conduct a full request for proposal (RFP)? • What are the advantages, risks, and costs of each type of plan? • What will be our internal processes? • How often will we conduct an internal or self-audit of the plan? Another key consideration is the annual audit, by a public accountant, which all plans with more than 100 participants must conduct and file with the DOL. A thorough audit is vital to protect your plan and organization. It is in your best interest to maximize the results of your plan’s audit with a well-qualified auditor who will properly determine whether the plan assets covered by the audit have been valued fairly and whether the plan’s obligations are accurately stated and described. For smaller plans, best practice recommends an internal review or self-audit of plan operations, administration, and compliance. At a minimum, you will want to review whether:
• Employee contributions to the plan were timely deposited and credited to participants; • payments, such as loans, hardship withdrawals, rollovers or final distributions, were all made in accordance with plan terms;
• participant accounts are fairly stated; • summary Plan Descriptions (SPDs), Summary Material Modifications (SMMs), Summary Annual Reports (SARs), and other mandatory participant disclosures are current, consistent, and properly distributed;
• various required non-discrimination tests were accurately conducted and passed, or if not, timely corrections were made;
• the performance of plan partners, e.g. third party administrators (TPAs), investment managers, trustees,
record keepers, auditors, attorneys and others met contractual agreements and plan sponsor expectations;
• any others issues were identified that may impact the plan's tax status; and • whether any transactions prohibited under ERISA were properly identified. Future Bulletin articles on retirement plan compliance and operations will cover related topics, best practices, fiduciary education and pointers, and correction methods available to prepare your plan for audit well before you receive an agency notice. £
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Does Your Handbook State Your Intentions? Lorrie Ray, Director of Membership Development, Esq., SPHR
I have looked at enough public sector handbooks over the years to know that when creating a handbook we tend to take from other handbooks we have seen, and involve elected officials involved in the process. Handbooks are seen as a way for the government entity to state its intentions. While these intentions are honorable, they may not serve the public sector employer well from a legal standpoint. Take the recent case of a fired police chief and patrol officer in Decherd, Tennessee. Freeze v. City of Decherd (6th Cir. 2014). The pair sued the City and won, arguing that the handbook provided a property interest in continued employment. The City clearly did not expect such an outcome, and had no idea the employee handbook would be the predominant cause. Terry Freeze and Earnest Colvin claimed the City fired them summarily, without written notice, any explanation, or any meaningful opportunity to respond. In Tennessee, as in most states, this would be fine because employment is at-will and either party may end the relationship at any time and for any reason. The City clearly relied on this principle when terminating Freeze and Colvin. The court, however, looked carefully at the handbook. It found a change to the handbook language from 2000, which the Decherd Board of Mayor and Aldermen approved under a resolution. The changed language plainly stated, “Discipline shall be for cause and follow the basic concepts of due process.” One wonders if those passing the resolution had any idea what the impact would be. This is unlikely since other language in the handbook stated the department would use a progressive-discipline system only where “practicable.” It becomes more and more important to understand what consequences handbook language can have on your organization. Remember that a handbook review is part of MSEC membership, and avoid startling outcomes like this case in Tennessee. £
A poorly written handbook can increase an employer’s liability. Make sure you aren’t unknowingly creating liability by what is included or omitted from your handbook. Your MSEC membership grants you access to staff expertise, sample handbooks, and employee handbook planning guides. Take advantage of this great membership benefit!
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Believe it or not, it’s almost time to start the 2015 budget planning process! Part of this process includes determining pay increases for employees in the upcoming year. What are other employers budgeting for 2015 pay increases? Participate in the 2015 MSEC Planning Packet questionnaire to report your organization’s projected 2015 pay increases. Your organization should have received an email to participate in the survey in late July. If not, go to survey questionnaires at msec.org and select the Planning Packet questionnaire to download. Results of the survey will be available in late September.
2014 Arizona and Wyoming Benchmark Compensation Surveys are Available! All data are extracted from the Benchmark Compensation Survey for Arizona, Colorado, and Wyoming Employers. The Arizona survey includes data from 39 organizations where data are displayed by geographic location (Metropolitan Phoenix, Tucson, Other Arizona, All Arizona, and All Colorado) for each job classification. The Wyoming survey includes data from 30 organizations, and displays data geographically as well (Casper, Cheyenne, Other Wyoming, All Wyoming, and All Colorado). General Information – Includes data for average percentage increases in pay and pay ranges for 2013 and projections for 2014 and 2015. Also included are hiring rates for inexperienced, entry-level personnel and for temporary personnel. The average ratio of human resource employees to organization employment size is displayed along with the type of human resource service model used by organizations. Summary of Surveyed Positions – The Denver/Boulder, Colorado extract of all surveyed positions in the 2014 MSEC Benchmark Compensation Survey are included in these reports. These data can be used to calculate average salaries in other Arizona and Wyoming cities using the cost-of-living and salary comparison data from the Economic Research Institute.
2014 Information Technology Survey: Arizona, Colorado, and Wyoming The 2014 Information Technology Survey is now available. This survey collected data from 345 organizations on 82 benchmark positions. Data in this survey are reported by Information Technology Department Size and Regional Geographic Location. The 2014 survey incorporates Denver/Boulder, Northern Colorado, Southern Colorado, Colorado Western Slope, Colorado Resort areas, Wyoming, and Arizona. Displayed in the report are individual data lines for each location as well as an All Front Range, All Colorado, and Total Responses data line. This survey gathered base wages effective March 1, 2014. Included in the Survey: Annual Incentive – Participants were asked to provide annual incentives for the past fiscal/calendar year. Data reported are average incentives paid and number of employees receiving an incentive. Target Percentage Incentive – Participants were asked to provide targeted percentage figures for additional compensation, not earned income for the current year. Exemption Status – Displays percentage of organizations reporting their matched position as exempt or non-exempt. The General Information section of the report contains data for average pay increases in pay for 2013 and projections for 2014. Also displayed are miscellaneous compensation practices including 2013 separation rate, average length of time to fill IT positions, the amount paid for successful referrals, and the ratio of IT employees to users.
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2014 Public Employers Compensation The 2014 Public Employers Compensation Survey is now available on MSEC’s website. The 2014 edition of the survey contains two separate reports (Individual and Aggregate). The two reports were necessar6y in order for us to publish all of the data required from this survey out of our new survey system. The Public Employers Compensation Survey: Individual Organization Report contains data displayed by individual organization for City and County governments, Parks & Recreation Districts, and Fire Department/Districts only. In addition, this report includes the general information data such as pay practices for police and fire positions, as well as other position specific data. The Public Employers Compensation Survey: Aggregate Report contains data displayed by aggregate re sults for City and County governments, Public and Private Utility, Parks & Recreation Districts, Fire Department/District and Other organizations. This report does not contain general information data.
2014 Utilities Compensation for Public and Private Employers The 2014 Utilities Compensation for Public and Private Employers Survey contains data extracted from the Public Employers Survey. This survey includes extracted data from 100 organizations for 76 benchmark positions. The compensation data are displayed by an aggregate data line for city, county, public utility, and private utility as well as by geographic location. Aggregate data lines are displayed when three or more participants reported a job match. ÂŁ
Special Studies Chain Restaurant Positions 3 organizations. 21A/14
Work from Home Policy 8 organizations. 29A/14
Certified Wound Care Nurse 11 Health Care organizations. 30A/14
Want to participate?
If you would like to participate in any of the above surveys and have not received a questionnaire, please call the Surveys Department. You can also download the questionnaire from our website at MSEC.org. As always, it is the participation of our members that helps make MSEC surveys the number-one data source for the region. Thank you! To request copies of the surveys, please contact the MSEC Surveys Department. Copies of these resources are available to authorized personnel of MSEC members. Call 800.884.1328, email surveys@msec.org, or go online to MSEC.org.
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