City of Pittsburgh v. FOP Fort Pitt Lodge No. 1

CourtCommonwealth Court of Pennsylvania
DecidedJanuary 22, 2025
Docket1174 C.D. 2023
StatusUnpublished

This text of City of Pittsburgh v. FOP Fort Pitt Lodge No. 1 (City of Pittsburgh v. FOP Fort Pitt Lodge No. 1) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Pittsburgh v. FOP Fort Pitt Lodge No. 1, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

City of Pittsburgh, : : Appellant : : v. : No. 1174 C.D. 2023 : Argued: May 23, 2024 Fraternal Order of Police : Fort Pitt Lodge No. 1 :

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE MATTHEW S. WOLF, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE WOJCIK FILED: January 22, 2025

The City of Pittsburgh (City) appeals from an order of the Court of Common Pleas of Allegheny County (trial court), which upheld the arbitration award issued by Jane Desimone (Arbitrator) in favor of the Fraternal Order of Police, Fort Pitt Lodge No. 1 (FOP). The Arbitrator found that the City overcharged retired police officers for their healthcare subsidies by $257,333.32 and $233,089.78 in 2017 and 2018, respectively, and awarded corresponding reimbursements in the same amounts. On appeal, the City argues that the Arbitrator lacked jurisdiction to award a reimbursement pertaining to the retirees’ City-paid subsidy and that the arbitration failed to observe due process. Upon careful review, we affirm.

I. Background The Arbitrator summarized the relevant facts of this case as follows:

Going back to the January 1, 2003 - December 31, 2004 collective bargaining agreement [(CBA)], the City provided healthcare coverage at no cost to employees. This changed on December 29, 2003, when the City entered Act 47 protection as a financially distressed local government. Pursuant to the Act 47[1] Plan, a minimum of 15% employee contribution for healthcare was mandated. At the beginning of the January 1, 2005 - December 31, 2009 [CBA], the City was self-insured for healthcare benefits. This self-insurance continued until January 1, 2008, at which time the City returned to a fully insured contract of insurance. This fully insured status then continued until January 1, 2016, at which time the City returned to self-insurance, which has remained to the present. The City remained fully insured for vision and dental insurance.

Along with this history is a record of contractual language and interpretations. When rates were adjusted in 2007, the [FOP] challenged the calculation of the new rates via the grievance procedure. In an Award dated March 22, 2007, Arbitrator Michael Zobrak sustained the grievance, determining what the City could and could not include in calculating employee contribution rates. Thereafter, the City retained the right to choose between full and self- insured options. In an agreement dated February 17, 2010, Section 14.B.l.1 of the Working Agreement was amended to add the following language[]:

The City has the right to purchase fully insured healthcare plans or to self-insure for purposes of health care coverage.

An Interim Health Care Arbitration Award was then issued on December 23, 2011, that included the following provision:

The [FOP’s] health care consultant shall be afforded access to all of the information and data available to the City’s health care consultant during the entire process, including but not limited to, claims data for all employees and direct access to

1 Act of July 10, 1987, P.L. 246, as amended, 53 P.S. §§11701.101-.712. 2 representatives of the current carrier and participating bidding carriers.

***

Effective January 1, 2016, the City became self-insured for healthcare purposes. The City has remained fully insured for vision and dental benefits, for which the City paid the full cost of the basic plans. Arbitrator’s Decision, 10/5/2018, at 3-4; Reproduced Record (R.R.) at 365a-66a. Following the expiration of the CBA on December 31, 2014, the City and the FOP were unable to resolve their negotiations culminating in a July 25, 2016 Interest Arbitration Award under Act 1112 (Miller Award). R.R. at 69a. Regarding active officer insurance, the Miller Award stated:

Beginning January 1, 2017, Officers shall contribute fifteen percent (15%) of the premium for health insurance, vision care, and the dental plan. Beginning January 1, 2018 and thereafter, Officers shall contribute seventeen and a half percent (17.5%) of the premium for health insurance, vision care and the dental plan. In addition, the following language should be added to the Working Agreement to provide the City with flexibility to respond to market competition and to reduce the overall cost of coverage:

The City shall have the right to change the existing medical, surgical, and hospitalization insurance plan, which is comparable to the coverage presently provided. The [FOP], however, retains the right to grieve the City’s determination that the plan is comparable. . . . . Arbitrator’s Decision, 7/25/16, ¶12; R.R. at 81a. Although the active officers’ contribution towards their health insurance functions as a premium, the parties do not refer to it as such. Rather, because the City became self-insured, the parties refer to this contribution as the premium equivalent rate.

2 Act of June 24, 1968, P.L. 237, No. 111, as amended, 43 P.S. §§217.1-217.12. 3 Relevant here, the Miller Award also left intact any unchanged provisions of the expired CBA (also referred to as the Working Agreement). As a consequence, Section 14.B.II.9 of the Working Agreement continued to govern retiree health insurance. It provides:

Any employee who retires after January 1, 2002, provided he or she was hired before January 1, 2005, will be allowed to continue his or her medical insurance coverage for himself/herself and spouses only, through the City. The City shall contribute towards the cost of this husband and wife coverage, for each employee so electing, an amount equal to the amount charged for such insurance by the carrier providing such coverage on the date of his/her retirement. The plan(s) that the City will provide are the same plan choice provided to active employees . . . . Arbitrator’s Decision, 4/21/23, at 3. Thus, since becoming self-insured, the City provides for retirees’ health insurance by paying for the retirees’ health care but deducting the premium equivalent rate from the year of the retirees’ retirement. The parties refer to this obligation toward retirees as the subsidy. On January 20, 2017, the FOP filed the instant grievance alleging the following:

In a series of emails sent by [FOP] President Robert Swartzwelder to the City [] and numerous [] City Officials carbon copied (cc’d) on the email[,] President Swartzwelder has requested from the City [] the premium equivalent rates regarding healthcare from its three primary health providers, namely Aetna, Highmark, and UPMC. To date those rates have not been supplied. Furthermore, the [Miller Award] clearly states that Pittsburgh Police Officers are responsible for paying 15% of the premium[s] for Health Care, Vision and Dental Benefits. At a minimum[,] the City has unilaterally imposed inflated rates for both Dental and Vision benefits which exponentially exceed the 15% premium costs for Vision and Dental Benefits. Regarding Health Care

4 premium rates, the City is clearly in violation of the [Miller Award] . . . .

The series of emails sent by President Swartzwelder requesting the premium equivalent and comparable rates between the City’s selected health care carriers are dated November 16, 2016, December 8, 2016 and January 16, 2017. To date neither the FOP [n]or President Swartzwelder ha[ve] received the requested information and thus cannot adequately and realistically “compare” existing medical, surgical, and hospitalization information that the City refuses to supply to the [FOP]. The City is in further violation knowing that it unilaterally implemented the proposed new plan without providing the FOP or President Swartzwelder with the requested comparison information in spite of three requested email[s . . .] to do so.

REMEDY

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Bluebook (online)
City of Pittsburgh v. FOP Fort Pitt Lodge No. 1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-pittsburgh-v-fop-fort-pitt-lodge-no-1-pacommwct-2025.