The American Hospital Association and its American Society for Healthcare Human Resources Administration on Feb. 22 joined other members of the Coalition for a Democratic Workplace to submit comments on a proposed National Labor Relations Board rule that would require 6 million employers covered by the National Labor Relations Act to post a notice describing employee rights under the Act. “This is a massive and unprecedented assertion of the Board’s jurisdiction in millions of workplaces where employees have not elected to be represented by a union and where there is no allegation of any unfair labor practice,” the letter states.
Among other concerns, the coalition notes that the proposed rule would impose significant penalties for failure to post the notice, which under the proposed rule would constitute an independent unfair labor practice. “The Board simply does not have authority to impose these obligations and penalties against an employer when there has been no finding (or even an allegation) of an unfair labor practice,” the letter said.
