Wa State Nurses Assoc, Resps V. Multicare Health System, App

CourtCourt of Appeals of Washington
DecidedSeptember 18, 2023
Docket84660-4
StatusPublished

This text of Wa State Nurses Assoc, Resps V. Multicare Health System, App (Wa State Nurses Assoc, Resps V. Multicare Health System, App) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wa State Nurses Assoc, Resps V. Multicare Health System, App, (Wash. Ct. App. 2023).

Opinion

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IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

WASHINGTON STATE NURSES No. 84660-4-I ASSOCIATION, UFCW 3000 and SEIU HEALTHCARE 1199NW on DIVISION ONE behalf of certain of the employees they represent, PUBLISHED OPINION

Respondent,

v.

MULTICARE HEALTH SYSTEM,

Appellant.

DÍAZ, J. — After a hack of its payroll system, MultiCare Health System

(MultiCare) implemented a “business continuity plan,” which resulted in overpaying

some of its employees. MultiCare sought to recover those overpayments pursuant

to WAC 296-126-030, which permits an employer unilaterally to recoup

overpayments if the overpayments were “infrequent” and “inadvertent.” The

Unions representing MultiCare’s employees sued, claiming MultiCare violated that

regulation, and the trial court granted summary judgment in their favor. We reverse

because there are genuine issues of material fact as to whether the overpayments

were “infrequent” and “inadvertent” in at least one sense of each of those defined

terms. We further hold that federal law does not preempt the Unions’ claims, nor For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 84660-4-I/2

are the Unions estopped by positions they took in prior proceedings. We, thus,

remand this matter to the trial court for further proceedings.

I. FACTS

A. Factual background

MultiCare is a not-for-profit health care system operating several health care

facilities throughout Washington. MultiCare has approximately 20,000 employees.

Many of MultiCare’s employees are unionized. 1 During the time in question,

MultiCare utilized a payroll system from Ultimate Kronos Group, Inc. (Kronos),

which integrates an employee’s claimed hours of work with MultiCare’s payroll

process. The Kronos system calculates a given employee’s pay based on the

hours the employee claims (and their supervisor confirms) they worked, and the

applicable rate of pay. Using Kronos’ data, MultiCare issued payments to

approximately 19,500 employees on a bi-weekly basis.

On December 12, 2021, Kronos was subject to a criminal ransomware

attack. 2 For eight weeks, Kronos was inoperable. Kronos’ inoperability meant that

MultiCare was unable to calculate the hours its employees worked or rate of pay

in the manner it had previously.

In response, while Kronos was inaccessible, MultiCare continued to pay its

1 MultiCare employees are represented by Washington State Nurses Association,

Service Employees International Union Local No. 1199NW, and United Food and Commercial Workers Local No. 3000. For simplicity’s sake, we refer to them as the “Unions” throughout this opinion. 2 MultiCare did not discuss the specific nature of the ransomware attack except

that it rendered Kronos inoperable. Generally, a ransomware attack involves “malware that requires the victim to pay a ransom to access encrypted files.” MERRIAM-W EBSTER ONLINE DICTIONARY, https://www.merriam- webster.com/dictionary/ransomware (last visited Aug. 28, 2023). 2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 84660-4-I/3

employees, not based on the hours they claimed they worked, but generally based

upon what they earned in the previous pay period immediately before Kronos was

attacked. Specifically, MultiCare’s “business continuity plan” consisted, first, of

paying employees an amount equal to the gross pay (minus one-time payments

and taxes) they received on the last paycheck before the Kronos outage. That pay

period covered November 21 to December 4, 2021, and included the Thanksgiving

holiday. An employee attested that “MultiCare expected that, by this method, each

employee would either receive the correct payment, be overpaid, or be underpaid.”

MultiCare implemented this system for four (4) two-week pay periods, namely,

between December 5, 2021 and January 29, 2022.

As a second part of its business continuity plan, MultiCare directed

employees temporarily to enter their time in a different program (TimeStamp).

MultiCare advised its employees that, when Kronos was back online, MultiCare

would “true-up” (or “reconcile”) an employee’s pay by comparing the time logged

in TimeStamp and how much an employee had already been paid. It stated, “it is

possible that some staff may receive more or less pay as an advance than they

are actually owed during downtime. . . . This means that [a hypothetical

employee’s future] paycheck(s) will be lower [or higher] to account for the fact that

he received more pay than what was owed to him during downtime.” MultiCare

communicated a similar message to its employees several times during the Kronos

outage.

In late January 2022, after Kronos became usable again, MultiCare began

its “true-up” process. Where an employee was owed funds, MultiCare paid the

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 84660-4-I/4

employee the balance owed between February 8 and 14, 2022. And on February

17, 2022, MultiCare emailed employees who had been overpaid, notifying them

that they had been overpaid and how it would recoup the overpayments. MultiCare

indicated it would deduct amounts from subsequent paychecks until the

overpayments were recovered, starting on March 18, 2022. 3

The three unions representing MultiCare employees sought to bargain the

effects of the implementation of the true-up or “adjustment” process. MultiCare

contended (at that time) that state law required it to begin recouping the

overpayments by March 18, 2022, i.e., within 90 days of its discovery. By that

date, MultiCare made its first deduction from employee paychecks to recoup the

overpayments resulting from the Kronos outage.

B. Subsequent procedure

The Unions filed unfair labor practice charges (ULP) with the National Labor

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