COVID-19: News and Updates |
| Special #48 - June 30, 2020 |
| | Mark Your Calenders
Georgia Employers' Association's 2020 Annual Conference at The Westin Harbor Golf Resort and Spa
Conference will be held on September 27 – 29, 2020
Title: 2020 Vision - A Decade for Change
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| | | Articles and Updates Today
- Constangy.com News & Analysis - Hit the Reset Button: NLRB restores precedent on bargaining obligations for discretionary discipline By Graham Newsome / Macon Office
6.29.20
- Gov. Kemp Extends COVID-19 Executive Orders JUNE 29, 2020
- Constangy.com News & Analysis - Georgia legislature passes “COVID-19 Pandemic Business Safety Act” By Graham Newsome / Macon Office
6.29.20
- Constangy.com News & Analysis - Protests amid a pandemic: Part Deux You think you’ve got this? Think again. By Susan Bassford Wilson / St. Louis Office
6.30.20
- Constangy.com News & Analysis - Tracking employees in the age of COVID-19 By Frank Shuter / Atlanta Office
6.30.20
- Constangy.com Podcast - News & Analysis: Social Media + Employees = Hot Mess with Attorneys Susan Bassford Wilson & Cherie Silberman 6.30.20
- 366,This Week’s Update,(Jun. 29, 2020) What's New in the HR Compliance Library from GEA's HR answers now
- Georgia Department of Public Health COVID-19 Daily Status Report
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| | | Constangy.com News & Analysis - Hit the Reset Button: NLRB restores precedent on bargaining obligations for discretionary discipline
By Graham Newsome / Macon Office & David Phippen / Washington DC Metro Office
6.29.20
On June 23, the National Labor Relations Board issued a decision in Care One at New Milford, finding that employers have no statutory obligation to bargain before instituting discretionary employee discipline that is consistent with an employer’s past policy or practice. The decision is a hefty loss for organized labor, many of a series issued by the current Board. NLRB Chairman John F. Ring wrote the decision, joined by the other two Members, Marvin E. Kaplan and William J. Emanuel. All three are Republicans.
The decision overruled a 2016 decision to the contrary by the Obama-era Board, Total Security Management Illinois 1, LLC.
The case
In 2012, the Board certified the Service Employees International Union as the exclusive bargaining representative of non-professional employees at the Care One rehabilitation and nursing care facility. The employer challenged the certification, which was eventually upheld in 2017 by the U.S. Court of Appeals for the District of Columbia Circuit. While the challenge was pending, the employer consistently maintained a disciplinary policy that stated the following:
Disciplinary Action
If your conduct is unsatisfactory, your Supervisor may provide guidance and support to help you make the necessary corrections. The Center has developed a disciplinary action process that focuses upon early correction of misconduct, with the total responsibility for resolving the issues and concerns in your hands. Your Supervisor is there to provide support and coaching.
The following highlights a list of actions that the Center may use while administering discipline. Please note that these are guidelines only, and are not intended to imply a series of “steps” that will be followed in all instances. Any of the disciplinary actions described below, including termination, may be initiated at any stage of the process depending on the nature of the specific inappropriate behavior, conduct, or performance and other relevant factors.
✓ Verbal or Written Warning
✓ Suspension or Suspension Pending Further Investigation
✓ Final Written Warning
✓ Termination of Employment
In late 2016 and early 2017, the employer suspended three employees and terminated one other, pursuant to the policy and without bargaining with the SEIU. At the time, contract negotiations were ongoing, and the employer informed the SEIU about the discipline during a bargaining session. The Union later filed a charge alleging a violation of Section 8(a)(5) of the National Labor Relations Act for failure to bargain over the disciplinary actions taken against the employees.
The main question before the Board in Care One was whether to follow Total Security Management. In that case, the Democratic majority on the Board imposed a new statutory obligation on employers when a collective bargaining relationship commenced. In essence, when the employee was represented by a union but was not yet covered by a collective bargaining agreement, the employer was required to provide the union with notice and opportunity to bargain about discretionary elements of its existing disciplinary policy before it could impose discipline.
In overruling Total Security Management, Chairman Ring said that Total Security Management’s pre-disciplinary bargaining obligation (1) conflicted with Board precedent and the U.S. Supreme Court decision in NLRB v. Weingarten, Inc.; (2) misconstrued the unilateral change doctrine described in the Supreme Court’s decision in NLRB v. Katz; and (3) imposed a complicated and unwieldy bargaining requirement that did not mesh with general bargaining law and statutory practices. The conflict with Weingarten and misinterpretation of Katz were crucial to the current Board’s ruling.
In Weingarten, the Supreme Court held that a bargaining-unit employee has the right to request a union representative when the employee reasonably believes that an interview could result in discipline. The Court made it clear that that it was “‘not giving the Union any particular rights with respect to pre-disciplinary discussions which it otherwise was not able to secure during collective-bargaining negotiations.’” Similarly, in Katz, the Supreme Court held that, upon commencement of a bargaining relationship, but with no agreement in place, employers of union-represented employees are required to maintain the status quo. In other words, they must refrain from making material changes regarding any terms or conditions of employment that would be mandatory subjects of bargaining, unless notice and an opportunity to bargain is provided to the union.
In Care One, the current Board also focused on the many practical problems with an employer’s implementation of Total Security Management. The rule would consistently “interfere with legitimate employer prerogatives” by delaying disciplinary action, according to the Board. The Board also took issue with the requirement that an employer bargain after the decision to institute discipline had already been made, but before the discipline had actually been imposed. The Board found that this requirement unnecessarily interfered with an employer’s ability to manage its workforce.
Going forward
The Care One decision is certainly welcome and timely news for employers who may be engaged in initial contract negotiations during the COVID-19 pandemic and the reopening process. The decision provides some degree of certainty for employers who follow their policies or past practices when imposing discretionary discipline. Nonetheless, employers should always use caution in taking disciplinary action against employees during initial contract negotiations. During this phase, employer actions are under intense scrutiny from unions that are trying to flex their muscles with employees and employers alike.
For a printer-friendly copy, click here.
*Want to learn more about this ruling then join us for the below free webinar.
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| Free Live Webinar
July 1st, 2020 / 11 pm - 12 pm EDT
District Court puts Unions back in Business |
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Join GEA and Mel Haas, Jeff Thompson and Jonathan Martin from the Constangy, Brooks, Smith & Prophete,LLP law firm as we discuss unionization issues in the news and activity that is occuring in the Georgia area.
In addition, we will discuss ways to handle political and social unrest issues in a work environment.
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| July 1st, 2020 / 11 pm - 12 pm EDT
Registration is open up till the start of the webinar |
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Gov. Kemp Extends COVID-19 Executive Orders
JUNE 29, 2020
Atlanta, GA - Today Governor Brian P. Kemp signed two executive orders extending the Public Health State of Emergency and existing COVID-19 safety measures.
"As we continue our fight against COVID-19 in Georgia, it is vital that Georgians continue to heed public health guidance by wearing a mask, washing their hands regularly, and practicing social distancing," said Governor Kemp. "We have made decisions throughout the pandemic to protect the lives - and livelihoods - of all Georgians by relying on data and the advice of public health officials."
"While we continue to see a decreasing case fatality rate, expanded testing, and adequate hospital surge capacity, in recent days, Georgia has seen an increase in new cases reported and current hospitalizations. Given these trends, I am extending previous COVID-19 safety requirements and guidelines that were due to expire on June 30 at 11:59 PM. Dr. Kathleen Toomey and the Department of Public Health, along with our local public health partners, will continue to monitor ongoing cases and related data to ensure that we are taking appropriate measures moving forward. Together, we can win the fight against COVID-19 and emerge stronger."
Executive Order 06.29.20.01 extends the Public Health State of Emergency through 11:59 PM on August 11, 2020. The Public Health State of Emergency allows for enhanced coordination across government and the private sector for supply procurement, comprehensive testing, and healthcare capacity.
Executive Order 06.29.20.02 continues to require social distancing, bans gatherings of more than fifty people unless there is six feet between each person, outlines mandatory criteria for businesses, and requires sheltering in place for those living in long-term care facilities and the medically fragile. The order also outlines that the State Board of Education must provide "rules, regulations, and guidance for the operation of public elementary and secondary schools for local boards of education" in accordance with guidance from Dr. Kathleen Toomey, the Department of Public Health, and the American Academy of Pediatrics. The order runs through 11:59 PM on July 15, 2020.
Read Executive Orders 06.29.20.01 and 06.29.20.02
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| | Constangy.com News & Analysis - Georgia legislature passes “COVID-19 Pandemic Business Safety Act”
By Graham Newsome / Macon Office
6.29.20
During the final moments of the 2020 legislative session, the Georgia General Assembly approved the Georgia COVID-19 Pandemic Business Safety Act. The bill, primarily written by Sen. Chuck Hufstetler (R-Rome), would protect businesses against liability for certain claims relating to COVID-19. The Georgia Senate passed the bill along party lines with a vote of 34-16, and the House passed the bill 104-56. Gov. Brian Kemp (R) is expected to sign.
The bill would provide protection for “healthcare facili[ties]” and “any entity” or “individual” who face liability as a result of the “[t]ransmission, infection, exposure, or potential exposure of COVID-19 to a claimant.” Under the legislation,
- No healthcare facility, healthcare provider, entity, or individual, shall be held liable for damages in an action involving a COVID-19 liability claim against such healthcare facility, healthcare provider, entity, or individual unless the claimant proves that the actions of the healthcare facility, healthcare provider, entity, or individual, showed: gross negligence, willful and wanton misconduct, reckless infliction of harm, or intentional infliction of harm.
The pending law also provides a rebuttable presumption of assumption of the risk by the claimant when the individual or entity provides a
- receipt or proof of purchase for entry . . . in at least ten-point Arial font . . . stating the following: “Any person entering the premises waives all civil liability against the premises owner and operator for any injuries caused by the inherent risk associated with contracting COVID-19 at public gatherings, except for gross negligence, willful and wanton misconduct, reckless infliction of harm, or intentional infliction of harm, by the individual or entity of the premises.”
The rebuttable presumption is also available if the individual or entity has posted the following disclaimer in a sign at a point of entry in at least one-inch Arial font:
“Warning" “Under Georgia law, there is no liability for an injury or death of an individual entering these premises if such injury or death results from the inherent risks of contracting COVID-19. You are assuming this risk by entering these premises.”
The rebuttable presumption is also provided for health care facilities or health care providers as long as they take the same steps to warn individuals entering the premises.
The legislation would add Chapter 16 to Title 51 of the Official Code of Georgia Annotated and be codified at O.C.G.A. § 51-16-1 et seq. As already noted, Gov. Kemp is expected to sign the legislation into law. Moreover, if he does not veto the bill within 40 days after the end of the legislative session, which ended on June 26, the bill will become law on August 7. The law applies only to actions that accrue before July 14, 2021.
For a printer-friendly copy, click here. |
| | | | Constangy.com News & Analysis - Protests amid a pandemic: Part Deux You think you’ve got this? Think again.
By Frank Shuter / Atlanta Office
6.30.20
As we have reported, a state court judge in California recently issued a Temporary Restraining Order prohibiting the reopening of a business until the employer complied with nearly one dozen COVID-19 safety-related requirements. The allegations of the public nuisance lawsuit leading to that TRO were egregious and, if true, reflected a conscious disregard for the health and safety of employees. For example, the lawsuit alleged that the employer failed to inform employees that they had been exposed to COVID-19, and failed to implement social distancing or cleaning protocols.
But, that’s not you. You’ve provided information to employees. You’ve implemented safety protocols. You’re covered. Well, think again.
We also reported on a judge in Illinois, who ordered an employer to do more to protect its employees from contracting COVID-19. The judge specifically noted that the employer had “the right idea,” and had implemented safety protocols designed to protect workers, like providing and requiring the use of protective gear and washing stations. But, according to the judge, more needed to be done because “the procedures [implemented by the employer]... are not working [and the employees’] right to work free from exposure to a highly contagious and deadly disease is being substantially and unreasonably interfered with.” As a result, the judge ordered the employer to strictly enforce its mask policy and retrain employees on proper social distancing and cleaning requirements.
These two cases, half a country apart, highlight two critical lessons that every employer trying to navigate its way through this crisis needs to learn. First, trying to do the right thing matters. Second -- and this lesson cuts across everything we do in the world of employment litigation -- an employer is no better than its lowest level managers. How those front-line managers supervise employees, and implement company policies, governs the way that their employers will be viewed by both judge and jury. Implementing well-crafted, legally compliant policies and procedures is a required starting point. It reflects “the right idea” and may well provide protection from claims of willful and reckless disregard for the safety of employees.
But unless front-line managers implement and enforce those policies and procedures, exposure (to both the disease and large jury verdicts) still exists. Requiring the use of masks, and social distancing between employees, are best practices. But they are of little value unless enforced, and ensuring such enforcement requires vigilance, regular follow-up, and regular training.
As we work our way through this national crisis, the federal government (and various state governments) may provide immunity to employers with respect to certain COVID-19-related legal claims. Don’t hold your breath waiting for that to happen. And even if it does, any legislation will probably exclude claims based on conduct reflecting a willful, wanton, or reckless indifference to the safety of employees. In the past several months, multiple lawsuits have been filed against employers, all of which seek to skirt the workers’ compensation system and win substantial damages from employers, based on such alleged conduct.
Doing the right thing, by implementing appropriate COVID-19 safety protocols, is a crucial first step. But you can’t stop there. Front-line managers must be trained on those protocols. Diligent follow-up on that training is required. Enforcement of the protocols is crucial. Having a mask policy is meaningless unless front-line managers correct employee failures and, if necessary, discipline employees for failing to comply. So, you think you’ve got this? Think again.
For a printer-friendly copy, click here.
Attorneys: Frank Shuster
Practice Areas / Employment Litigation Prevention & Defense
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| | | | | Constangy.com News & Analysis - Tracking employees in the age of COVID-19
By Susan Bassford Wilson / St. Louis Office
6.30.20
Monitoring employees isn’t a new or novel idea. Companies have long debated the merits of video surveillance in the workplace, tracking employee vehicles with GPS, or monitoring employee movements via a smartphone application. However, some employers are taking another look at employee monitoring as a means to help ensure employee safety and hinder the spread of COVID-19.
Overview of workplace monitoring laws
Federal laws governing workplace monitoring are fairly sparse. For example, the Electronic Communications Privacy Act (which amends the Wiretap Act) protects certain oral and electronic communications from unauthorized interception, use, and disclosure. The Stored Communications Act protects wire and electronic communications and records, though it doesn’t apply to communications stored on a company’s system if the company’s policy authorizes access to those communications. GPS tracking is often contested in criminal matters because of the Fourth Amendment’s prohibition on unreasonable searches or seizures. However, the Fourth Amendment applies to public employers and governmental action, not to private employers.
Instead, an employee’s right to privacy is often driven by widely varying state laws. For example, many states have wiretapping laws that encompass workplace surveillance. Other states like California, Tennessee, and Texas have laws limiting an employer’s ability to use GPS or other tracking devices. States such as Connecticut and Delaware prohibit monitoring employees in areas where people have a reasonable expectation of privacy, like restrooms and locker rooms. Further, in addition to statutory protections, employee monitoring can also trigger common law privacy claims like invasion of privacy and intrusion into seclusion.
Privacy rights can also vary based on the type of technology being used. Unsurprisingly, there is more regulation of older forms of technology like telephones than there is about newer options such as tracking employees via an access badge. However, the analysis concerning older forms of technology is often helpful in evaluating newer, high-tech options.
Pros and cons of monitoring or tracking employees
Monitoring employees at work requires striking a delicate balance between reasonable employee concerns and legitimate business interests. First, employers who have or are considering a monitoring program should be cognizant of employee privacy concerns. Monitoring employees outside the workplace can be particularly invasive because it can intrude into an employee’s private life. For example, GPS tracking of a company car may reveal information about the employee’s location or activities after hours. Employee tracking programs could also present opportunities for misuse by other employees. Further, monitoring could hurt employee morale. Employee monitoring may also create issues related to the National Labor Relations Act, whether or not the workplace is unionized. Overly broad surveillance could infringe on the ability to engage in protected concerted activity or create an unfair labor practice claim under the NLRA.
Employee tracking may also be an issue in class or collective actions. For example, one putative class and collective action recently filed in California alleged that, among other things, the employer tracked its company vehicles via GPS to measure the length of client visits and ensure that the cars were not driven for personal reasons. The suit specifically sought relief for a subclass of employees who purportedly had unauthorized paycheck deductions taken each month for the alleged personal use of those vehicles.
However, there are many benefits of a thoughtfully formulated employee monitoring program. In the age of COVID-19, employee monitoring could be used to ensure that employees are following the company’s directions regarding social distancing. It could also be used to determine who an infected employee came into contact with for purposes of notification and to tailor decisions related to a partial facility shutdown designed to stop the spread of the infection. GPS tracking of employees could help detect when a traveling employee has been in an accident. Monitoring can help protect against or investigate allegations of employee misconduct. Tracking can also be used to increase employee productivity by highlighting the need for training or ensure the appropriate use of employer resources. Employee monitoring may be used to ensure that unauthorized individuals do not access secure rooms. Workplace surveillance can also deter employee theft, violence, and other prohibited behaviors.
Practical tips for employee monitoring or tracking
Employers that have or are contemplating employee monitoring should consider the following tips:
- Balance employee privacy rights with legitimate business and safety concerns. Before implementing a tracking program, employers should consider what legitimate business purpose employee monitoring serves and determine whether there is a less invasive option that would achieve the same or similar results. Further, employers should consider the scope of the monitoring, and be cautious about tracking employees who are off the clock. For example, if the primary business interests are ensuring social distancing and reducing operational bottlenecks within the facility, using a proximity badge that only tracks and reports information about an employee’s location within the facility is less invasive than requiring all employees to install an app on a personal device that records and reports employee location data 24/7.
- Create a clear and thoughtful policy. Like so many other areas of employment law, a thoughtful policy that is compliant with applicable federal and state law is invaluable. Improperly implemented or sloppily operated monitoring or tracking programs can expose employers to a variety of legal risks. At a minimum, the policy should clearly describe the purpose of the tracking, when such monitoring will occur, and how the data will be used; identify which employees will be able to access the data; explain the terms and length of the retention of that data; and describe the consequences for misuse or unauthorized access. Further, the policy should reiterate that employees have no expectation of privacy when using the company’s equipment or within public areas of the company’s facility.
- Know the law. As previously mentioned, the law in this area is state-specific and changes often. Regularly review the law in all the states in which you operate to ensure that your thoughtful policy remains compliant.
Give employees notice and obtain advance consent. Many states prohibit surveillance or GPS tracking without prior notice to the person being recorded or tracked. Thus, employers who implement a surveillance or tracking program should explain the program to employees in advance and provide employees with a copy of the company’s policy on it. Further, written consent to monitoring is always a good idea. Not only is it required in some states, but it is also an affirmative defense to many statutory and common law claims.
Regardless of whether employee monitoring is an old program or a new idea that you are exploring due to COVID-19, now is the best time to ensure that your company’s procedures and policies are useful and lawful.
For a printer-friendly copy, click here.
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| | | | Constangy.com Podcast - News & Analysis: Social Media + Employees = Hot Mess with Attorneys Susan Bassford Wilson &
Cherie Silberman
6.30.20
Can you discipline or fire an employee because of his or her social media posts? Do employees have a constitutional right to say whatever they want online or at a protest? What blowback might companies face due to negative social media publicity? Join us as we discuss everything from the First Amendment to The Princess Bride.
This podcast is made available for educational purposes only, to give you general information and a general understanding of the law, not to provide specific legal advice or to establish an attorney-client relationship. This podcast should not be used as a substitute for competent legal advice from a licensed attorney in your state.
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| | | 366,This Week’s Update,(Jun. 29, 2020) What's New in the HR Compliance Library from GEA's HR answers now
Here’s a brief listing of what is new and what has changed in the HR Compliance Library:
Coronavirus. The “Communicable Diseases” topic under the Safety, Security, Risk Management category was updated to reflect the following developments related to the coronavirus (COVID-19) pandemic:
- Under the Families First Coronavirus Response Act (FFCRA), group health plans and health insurance issuers offering group or individual health insurance coverage must provide (without cost-sharing or prior authorization) benefits for certain items and services related to COVID-19 testing and diagnosis. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) amended the FFCRA to include a broader range of diagnostic items and services that plans and issuers must cover. To provide guidance on these requirements, the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury have issued a second set of frequently asked questions (FAQs) about the FFCRA, the CARES Act, and other health coverage issues related to the coronavirus. The FAQs, which address coverage of COVID-19 testing, telehealth, wellness programs and more, are noted in the Analysis and Guidance at ¶71,074.
- The Occupational Safety and Health Administration (OSHA) has issued new guidance to help employers and workers reopen nonessential businesses and return to work during the evolving pandemic. Employers can use the recommendations to develop policies and procedures that ensure the safety and health of their employees. OSHA’s return-to-work information, discussed in the Analysis and Guidance at ¶71,075G, focuses on the need for employers to develop and implement strategies for basic hygiene, social distancing, identification and isolation of sick employees, workplace controls and flexibilities, and employee training.
OSHA has published its respirator poster, Seven Steps to Correctly Wear a Respirator at Work, in 14 additional languages. Aside from English and Spanish, the poster is now available in Arabic, Brazilian Portuguese, Chinese (Simplified), Chinese (Traditional), French Creole, Hmong, Korean, Kunama, Polish, Russian, Somali, Tagalog, Thai, and Vietnamese. Find out more in the Sample Document at ¶71,140B. - The respirator poster is now available in 16 different languages: English, Spanish, Arabic, Brazilian Portuguese, Chinese (Simplified), Chinese (Traditional), French Creole, Hmong, Korean, Kunama, Polish, Russian, Somali, Tagalog, Thai, and Vietnamese ( 10). To access the posters in alternative languages, visit OSHA’s poster webpage.
Nondiscrimination in health programs. HHS has finalized changes to its regulations implementing Sec. 1557 of the Patient Protection and Affordable Care Act (ACA), which prohibits discrimination in federally funded health programs. The final rule eliminates the previous rule's definition of “on the basis of sex,” which had included “gender identity” and “termination of pregnancy.” Instead, it prohibits sex discrimination based on biological sex only. Notably, this contradicts the U.S. Supreme Court’s recent interpretation of similar language in a different federal law, Title VII. The new rule is projected to save over $2.5 billion in regulatory costs, mainly by eliminating the mandate for entities to send patients and customers “notice and tagline” inserts in 15 foreign languages — something that has not effectively accomplished its intended purpose, according to HHS. For more information, refer to the Analysis and Guidance at ¶14,400 in the Benefits category under the “Health Benefits and Insurance” topic.
Mental health benefits. The DOL has proposed revisions to its Mental Health Parity and Addiction Equity Act (MHPAEA) self-compliance tool. The tool, originally released in 2018, helps group health plans, plan sponsors, plan administrators, health insurance issuers, and other parties determine whether a group health plan or a health insurance issuer complies with the provisions of the MHPAEA and additional related requirements under ERISA. The proposed update, which is required every two years under the 21st Century Cures Act, includes new information and examples to demonstrate how a plan or issuer may comply with the law. See the Analysis and Guidance at ¶16,130 and the Tool at ¶16,190, both located in the Benefits category under the “Mental Health Parity” topic.
Compensation costs. Employer costs for employee compensation for civilian workers averaged $37.73 per hour worked in March 2020 (wages and salaries averaged $25.91 per hour, while benefits averaged $11.82 per hour). Results from the government’s latest quarterly study of compensation costs are reported in the Analysis and Guidance at ¶20,850 in the Compensation category under the “Economic Indicators” topic.
Employer tax returns. The IRS has reissued the 2020 version of Form 941, Employer’s Quarterly Federal Tax Return, which is used by employers to report withheld income and Social Security taxes. The new version, which incorporates employment tax relief related to the coronavirus, is reproduced in the Sample Document at ¶25,714 in the Compensation category under the “Payroll Taxes and Withholding” topic.
Visas. Certain nonimmigrant visa programs authorizing employment in the United States pose an unusual threat to the employment of American workers given the economic contraction brought about by the COVID-19 outbreak. To protect American workers, a new proclamation by President Trump suspends temporary work visas — including H-1B visas, H-2B visas, J visas (to the extent the alien is participating in an intern, trainee, teacher, camp counselor, au pair, or summer work travel program), and L visas. The suspension also applies to individuals who accompany or follow later to join an applicant. The presidential action also extends a previous suspension on immigrant entry until December 31, 2020. The proclamation is discussed in the Analysis and Guidance at ¶84,133, and noted in the Analysis and Guidance at ¶84,093 and ¶84,100 — all located in the Staffing category under the “Immigration and Visas” topic.
* If you have any questions about compliance issue from this article please call us or email chris@georgiaemployers.org. |
| | | | Georgia Department of Public Health COVID-19 Daily Status Report For: 06/03/2020 Updated 3pm daily
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Georgia Employers' Association |
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