COMMONWEALTH v. COMMONWEALTH EMPLOYMENT RELATIONS BOARD & another.

101 Mass. App. Ct. 616
CourtMassachusetts Appeals Court
DecidedSeptember 2, 2022
StatusPublished
Cited by4 cases

This text of 101 Mass. App. Ct. 616 (COMMONWEALTH v. COMMONWEALTH EMPLOYMENT RELATIONS BOARD & another.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
COMMONWEALTH v. COMMONWEALTH EMPLOYMENT RELATIONS BOARD & another., 101 Mass. App. Ct. 616 (Mass. Ct. App. 2022).

Opinion

COMMONWEALTH EMPLOYMENT RELATIONS BOARD, COMMONWEALTH vs., 101 Mass. App. Ct. 616

COMMONWEALTH vs. COMMONWEALTH EMPLOYMENT RELATIONS BOARD & another. [Note 1]

101 Mass. App. Ct. 616

June 9, 2022 - September 2, 2022

Court Below: Commonwealth Employment Relations Board

Present: Meade, Rubin, & Sullivan, JJ.

No. 21-P-411.

Commonwealth Employment Relations Board. MassHealth. Commonwealth, Collective bargaining. Labor, Bargaining unit, Collective bargaining. Public Employment, Collective bargaining. Telephone. Statute, Construction. Administrative Law, Agency's interpretation of statute.

Substantial evidence supported the conclusion of the Commonwealth Employment Relations Board that the Commonwealth engaged in a unilateral change in terms and conditions of employment in violation of G. L. c. 150E, § 10 (a) (1) and (5), when MassHealth managers surreptitiously listened to employees' telephone conversations with members of the public without first providing notice to the union representing those employees, and an opportunity to bargain to resolution or impasse, where MassHealth did not utilize the telephone system's feature that enabled managers to listen to telephone calls between employees and the public prior to 2019, neither the employees nor the union were informed that managers would be listening to employees' telephone calls, and the existing policy governing the use of Commonwealth-owned devices did not state that telephone conversations would be monitored [623-625]; and where MassHealth's new practice implicated a mandatory subject of bargaining, in that it directly affected the productivity and performance measures by which employees were assessed and resulted in an increased likelihood of discipline [625-627].


Appeal from a decision of the Commonwealth Employment Relations Board.

Cassandra Bolanos, Assistant Attorney General, for the Commonwealth.

Lan T. Kantany for Commonwealth Employment Relations Board.

Ian O. Russell for the intervener.


SULLIVAN, J. The Commonwealth appeals from a decision of the Commonwealth Employment Relations Board (CERB or board), concluding that the Commonwealth engaged in a unilateral

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change in terms and conditions of employment in violation of G. L. c. 150E, § 10 (a) (1) and (5), when MassHealth managers surreptitiously listened to employees' telephone conversations with members of the public without first providing notice to the intervener, AFSCME-SEIU/SEIU Local 509 (union), and an opportunity to bargain to resolution or impasse. The Commonwealth contends that CERB erred in concluding that MassHealth had engaged in a prohibited practice because it had authority to do so under existing policies and contract provisions, and the decision to use the previously unused feature of the telephone system did not impact terms and conditions of employment. We conclude that CERB's decision was supported by substantial evidence and was not arbitrary, capricious, an abuse of discretion, or otherwise contrary to law.

Background. We recite the relevant facts as found by CERB based on the parties' written statements of stipulated facts and the stipulated exhibits.

The Commonwealth, acting through the Secretary of Administration and Finance, is a public employer within the meaning of G. L. c. 150E, § 1. The Alliance, AFSCME-SEIU, AFL-CIO (Alliance) is the exclusive bargaining representative for employees in Statewide bargaining units two, eight, and ten. The union is an employee organization within the meaning of G. L. c. 150E, § 1. A member of the Alliance, the union represents employees in unit eight who hold the job title of Benefit Eligibility Referral Specialist (BERS) A/B at MassHealth. BERS D staff, who are also bargaining unit members, oversee BERS A/B staff, and all BERS staff report to team managers. BERS A/Bs are subject to performance evaluations, known as Employee Performance Reviews, and may be disciplined for performance related reasons.

BERS A/B staff typically work in an environment akin to a call center and are assigned to cubicles. The cubicles are equipped with Commonwealth-owned computers and an integrated telephone system. BERS A/B staff answer telephone calls from members of the public who are seeking information and assistance.

The BERS A/B staff log into the telephone system through the Commonwealth's computer system. The system tracks whether a BERS A/B's telephone line is busy or available to take the next call in the queue. A dashboard shows managers status indicators that include "Ready," "Talking," "Not Ready," and "On Hold," and the duration of the status.

In early 2019, MassHealth officials monitoring the dashboard noticed what they believed was a high volume of calls with low

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call duration. During February and March 2019, MassHealth began an investigation into the conduct of specific BERS A/Bs. MassHealth did not inform the union (or the BERS A/Bs) of the investigation.

Unlike many call centers, MassHealth does not record customer calls. Before February 2019, MassHealth had not used a feature of its telephone system that permitted team managers to listen to telephone calls without the knowledge of the BERS A/Bs (or the callers). [Note 2] When the investigation began, MassHealth managers listened to telephone calls between the identified BERS A/Bs and members of the public and took notes. MassHealth did not provide notice to the union that managers would be listening to telephone calls between BERS A/Bs and members of the public.

On or around April 20, 2019, MassHealth directed eleven BERS A/B staff to attend investigatory interviews. During one of the investigatory interviews the union learned that MassHealth had been listening to calls. Between June and August 2019, MassHealth disciplined eleven BERS A/Bs. [Note 3] The union grieved all eleven disciplinary actions.

No BERS A/Bs had been disciplined for their handling of telephone calls in the past. Nor had any BERS A/Bs been disciplined based upon review or monitoring of "status indicators" related to the employees' call status or the passing observations of managers. [Note 4] MassHealth had received complaints about the conduct of BERS A/Bs from the public and informed the relevant BERS A/B staff member, but MassHealth had not pursued discipline.

On May 24, 2019, the union filed a charge of prohibited practice with the Department of Labor Relations (DLR) alleging that the Commonwealth, via MassHealth, had engaged in prohibited practices in violation of G. L. c. 150E, § 10 (a) (5), and, derivatively, § 10 (a) (1), when MassHealth managers monitored BERS A/B telephone calls without first providing the union with notice and an opportunity to bargain to resolution or impasse. The DLR issued a complaint of prohibited practice on September 13, 2019, alleging that by monitoring telephone calls, the Commonwealth "had changed the criteria by which it evaluates productivity and performance and imposes discipline without giving the union prior notice and an opportunity to bargain to resolution or impasse about the decision and the impacts of its decision in violation of [§ 10 (a) (5)]." Pursuant to 456 Code Mass. Regs. § 13.03(1)(b) (2016), the Commonwealth filed a petition, which CERB granted, requesting that CERB decide the matter on a stipulated record in the first instance. [Note 5]

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101 Mass. App. Ct. 616, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-commonwealth-employment-relations-board-another-massappct-2022.