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good morning everyone greetings and welcome to today's webinar attention multi-state employers state employment laws right for change presented by Quarles and Grady my name is Otto mo and I lead our Florida labor and employment group over my career I have counseled and represented employers and a wide variety of workplace related litigation hmm I advise HR professionals in all levels of management on myriad workplace decisions and practices including workforce management issues involving the Family and Medical Leave Act the Americans with Disabilities Act and other federal state and local fair employment and anti-discrimination statutes compliance immigration and workplace investigations I also provide training sessions for my clients on topics covering all areas of Labor employment law I am very pleased to be with you today before we begin the presentation we have a few housekeeping items to go over we will be applying for one hour of CLE credit if you are an attorney and would like to receive CLE credit for it attending today's program please fill out the CLE forum located at the back of the materials found in the handouts panel of the webinar dashboard please complete the form and return it to the contact listed at the bottom of the document there is also an HR attendance certification form in the dashboard materials for human resource professionals to use in self reporting we have muted all phone lines for those dialing in and for participants listening to audio via computer so you will not be able to speak we are in listen-only mode we would like you to be aware that this presentation is being recorded and an electronic survey will be emailed to you after the program if any webinar participants have a question please type your question in the chat box located in the upper right corner of the webinar dashboard and submit every effort will be made to answer questions near the end of our time together today a recording of the presentation and the PowerPoint slides will also be available after the presentation on the labor and employment events tab at quarrel comm so today we're going to be talking about the increasing trend of employment law regulation at the state level the driving force behind the state's actions has been inaction by the federal government and in fact a reversal of positions in several important areas that has led states to move forward with protecting workers within their jurisdictions in addition last year the me2 movement increased the publicity of sexual harassment claims and that has led states to change the way companies litigate settle and disclose claims of sexual harassment so the major areas that we're going to be covering today are state changes to minimum wage laws state increased minimum salaries to be exempt from overtime requirements state requirements for anti harassment training prohibition of confidentiality clauses and settlement of sex harassment claims prohibition of requiring arbitration of sex harassment claims non-disclosure and labor provisions and employment contracts that prospectively limit or preclude disclosure of sex harassment claims and some other changes to the interactive process at the state level and some some state specific laws that are a little out of the ordinary including time offer victims of crime and permissive changes of schedule due to personal events so we all know that the federal minimum wage came about as a result of the fair labor standard act which is now more than 80 years old the initial minimum wage in the United States was set at 25 cents per hour and was in effect in 1938 over the years they've been many increases and listed here are the most recent increases and what is of note is that there has not been an increase in the federal minimum since 2009 so we're almost 10 years into the minimum wage at the federal level due to this lack of action on the federal level states have taken the issue into their own hands and implemented increases with the state level we have 29 states that have minimum wages that are higher than the federal minimum and 21 of those states are increasing their minimum wage for 2019 I will not read every one of these states but as you can see they range from a low of eight dollars and 46 cents in Florida up to a high of 14 dollars in the District of Columbia with a number of states clustering in at $12 per hour in addition to increasing the minimum wage many cities and municipalities have even higher minimum wages that are in excess of the state minimum and some jurisdictions assign minimum wage based on the size and location of the employer the takeaway on this issue is that if you have minimum wage workers you should be checking both the state and locality in which they are employed to make sure that you do not run afoul of a higher minimum wage in addition hmm under both federal and state law employees who work over 40 hours per workweek are entitled to overtime pay unless they are exempt and part of the exemption test is minimum salary requirement that has been set at twenty-three thousand six hundred and sixty dollars annually for more than ten years as you may recall there was an effort to increase that to about forty six thousand dollars a couple of years ago by the outgoing administration that effort was struck down by a federal court last year and we are anticipating a new regulation from the Department of Labor that was calendered to be released in mid-march whether that will be delayed due to the government shutdown is not known at this point but at the federal level we are still at a ten year old salary basis requirement so some states have enacted their own minimum salaries new york for example has as of December 31st last year a requirement that employers in most of the state must pay at least forty three thousand two hundred and sixty four to have an exempt employee and that goes up to a high of 58 thousand five hundred for large employers meaning those with eleven or more employees in New York City similarly California has a standard that requires the employee to be paid at least twice the state minimum wage based on full-time employment and their minimum wage is set to increase annually over the next few years this is for all employers in California this chart lists the year and the sizes of employees required to trigger the different standards as you can see as of this year it is a low of forty five thousand seven sixty-four employers with fewer than 25 and in three years it would go up to sixty two thousand four hundred for employers with twenty-six or more employees so again a lot of activity at the state level on the notion of exempt employees something to keep an eye on with regard to anti-harassment training many states have enacted laws requiring particular anti-harassment training by employers right now the list includes California Colorado Connecticut Maine New York and New Mexico and some states have requirements for state workers and all states either recommend or encourage training but do not require it so what is required in some of the states with specific training requirements in California the training has very specific the requirements are very detailed the rule for companies with 50 or more employees is to provide training to all supervisors within six months of hire or promotion into a supervisory position those people must be retrained every two years the training itself must be effective and interactive which means that it has to be live training whether that is by webinar or in-person training it has to be interactive so that the participants have an opportunity to ask questions and to answer questions the new requirement as of last year includes coverage of anti harassment focusing on gender identity gender expression and sexual orientation in Connecticut that companies with 50 or more employees must provide training to all supervisors within six months of hire or promotion they are encouraged to retrain every three years but not required by law to do so the training must be at least two hours long and must include experiential exercises and discuss the perpetual and communicational differences among all persons so again some specific requirements for employees in Connecticut such that sort of generally applicable harassment training may be insufficient in Delaware employers with 50 or more employees must provide harassment training to new employees within one year of their hire and to existing employees within one year of the effective date of the act and every two years thereafter in Maine the requirement is for any employer with more than 15 employees and the law in Maine requires that they be that the training covers sexual harassment and take place within one year of the commencement of employment supervisors and managers must get additional training within one year of assuming their positions New Mexico requires primary and secondary education providers so both government and private entities to train all school personnel at least once a year New York has a very newly enacted as of October 19th requirement for all employers regardless of size to give annual sex harassment training and have a written sexual harassment policy the content of that policy is also set within detail and generally varies from the standard policy that you often see in employee handbooks or sample handbooks and has some specific requirements particular to New York that have to be covered the legislation has a model policy but the model policy it may not fit within the the theming of an employee handbook and so should be reviewed carefully before being adopted still on the topic of the me2 movement and related legislation at the federal level the tax law changes at the end of 2018 contained a provision prohibiting employers from taking a deduction for attorneys fees and costs incurred in any sexual harassment or sexual abuse case if the settlement agreement includes a nondisclosure provision we are awaiting further regulatory guidance as to the total scope of that and again no great expectation that that's going to be forthcoming any time soon given the current state of affairs Washington California not surprisingly as another leader in this area and as of the 1st of this year has ruled that settlement agreements including provisions precluding an individual from disclosing factual information related to claims of sex assault or harassment or discrimination will not be permitted the claimant can request such a confidentiality provision but the accused has no similar protection the amount of a settlement can remain confidential but the facts relating to the claims cannot in New Jersey there is currently under consideration legislation that would ban the use of confidentiality provisions in any settlement agreement that attempts to conceal discrimination retaliation or sex harassment if the employer includes a confidentiality provision it must include a prominent notice that the clause is unenforceable again this is not yet the law but it is progressing in the New Jersey Legislature in addition it prohibits retaliation for refusing to sign a nondisclosure clause in New York confidentiality clauses and settlement agreements relating to claims of sex harassment are prohibited unless they are preferred by the complainant and I see in this slide that there's a typo that will be corrected when the PowerPoint is posted it requires a 21-day consideration period and seven-day revocation so just like the requirement to obtain a valid waiver for an age discrimination claim to the extent an agreement is proposed that would contain confidentiality provisions in New York taking with New York arbitration clauses relating to sex harassment are prohibited this is [Music] contrary to the expanded use of arbitration agreements that has recently been approved by the US Supreme Court and the general preference for non court resolutions and a number of states as we will see have followed this idea and so mandatory arbitration in New York cannot include sex harassment claims again in New Jersey pending legislation makes any provision in an employment contract that waives any substances or procedural right of remedy relating to a claim of discrimination retaliation or harassment unenforceable so this would go beyond an arbitration provision and would render unenforceable a wide variety of mechanisms for alternative dispute resolution or waiver of jury trials for some other form of alternative dispute resolution in Vermont the prohibition is on employment agreements that require claims of harassment to be resolved through arbitration so similar to New York California kind of provision Washington voids the ability to enforce contracts or agreements that waive an employee's right to publicly file complaints regarding sex harassment and sexual assault in Maryland effective October 1st a new law precludes provisions in employment contracts that waive rights to future claims of sex harassment or retaliation or retaliation for reporting sex harassment it's not clear exactly what the purpose of that law is because it's generally not possible to waive claims that have not yet occurred but there's another part of the Maryland law that will talk about him in a second in Tennessee new legislation prohibiting the requirement that employees or prospective employees be required to sign or renew non-disclosure agreements regarding sex harassment in the workplace as a condition of employment Washington state prohibits signing non-disclosure agreements regarding sex harassment and sex assault as a prerequisite for employment so again carving out of what would be generally applicable and permissible agreements between an employer and an incoming employee to modify the form and venue in which claims can be brought and this is something that is ongoing and under consideration elsewhere as well Maryland we're coming back to in addition to the prohibition on the waiver is requiring mandatory disclosure of harassment in the workplace it requires employers with 50 or more employees to disclose the number of settlements made after sex harassment allegations the number of settled allegations of sex harassment against the same employee and the number of settlements of sex harassment that included non disclosure provisions these are the reports we are to be made in 2022 the Maryland Commission on civil rights and the aggregate information for the employer will be posted on its website and the individual survey reports will be made available by the Commission upon request so that's quite a broad and far-reaching question required in Maryland and employers with sufficient employees and operations should be taking this in due care all right in another area of expanding protections for employees we're going to talk a little bit about employment applications and pre hire information and we'll start by talking about criminal history information these are the questions that were typical on employment applications that had some variation of if you have been convicted or pled no contest to a crime or to a felony you had to disclose that as part of the initial application process this over the last few years has come under increasing scrutiny both at the federal level with the EEO C's guidance on the proper treatment of criminal history information and on the state and local level with the short name of banned the Box this is the restriction on whether you can ask or at what point you can ask an applicant to disclose prior conviction information presently 31 states have statewide laws or policies regarding inquiries into an applicant's criminal records until sometime later in the hiring process not the initial application the idea being that this will give people a fair chance to have their skill ability experience and credentials considered before the information about a criminal history comes out and the momentum for this has grown exponentially in the last couple of years so far presently 11 states have mandated removal of conviction history questions from job applications those being California Connecticut Hawaii Illinois Massachusetts Minnesota New Jersey Oregon Rhode Island Vermont and why ten more in addition other states have imposed that requirement on state or local contractors so peopl who are doing business with a state or locality may have a restriction on their pre-employment criminal history inquiry and more cities and states are considering this all the time this is another area that is rapidly evolving and is one that is worth monitoring if if an employer decides to continue to ask the question in the initial application process and so if you do not have operations in any of the states where it is improper to do so you still should be keeping your eyes open for additions to this list in it another area of application restriction in in the last year or so there have been a number of states that have restricted asking about an applicant's salary history the idea being that to a certain extent it is considered to perpetuate what might have been underlying discrimination from years ago if applicants are required to sort of live with their salary history as they move from one employer to another so salary history is prohibited in Massachusetts Connecticut and Hawaii California provides that salary the prior salary alone cannot by itself justify a pay disparity but doesn't provide quite as high a level of protection as the other three states cities with restrictions include New Orleans New York City Philadelphia and Pittsburgh and this is an area that is is again rapidly developing and gaining greater traction so the following states are actively considering passing laws that would restrict inquiries into salary history and it's a pretty substantial list there 18 additional states where this is under consideration and so it would be prudent to take a look at these states if you have operations to make sure that if the laws are enacted that your application and interview practices are in keeping with the restrictions because you know it has been traditionally common to ask for prior compensation as part of an application work history section and employers do find it relevant to establishing whether the the range for the position they have in mind is likely to be too low for a particular candidate again if you're operating in one of these states flag it and keep up with any additional requirements turning nail to family leave the baseline federal act is of course our old friend the federal Family Medical Leave Act which is 12 months of 12 weeks during and 12 weeks of unpaid leave during a 12-month period for certain covered reasons care for a newborn adoption or foster child and applies to employees of 50 or more other states and again this is unpaid leave paid family leave so far is in effect in California New Jersey New York Rhode Island and Washington State and the states take a different approach to the paid family leave and we'll go through those just to cover some of the approaches in California to be eligible an employee must have worked for an employer for at least 12 months and have twelve hundred and fifty hours of service during the 12 months prior to leave so that's the same as the FMLA requirement they receive in California up to six weeks of paid leave to care for a seriously ill child spouse parent or registered domestic partner or to bond with a new child and the amount they received is about 55 percent of their weekly wage during that six weeks of paid leave this is funded through payroll taxes New Jersey's paid family leave applies to employees who've worked 20 calendar weeks or who have earned at least a thousand times the state minimum wage during the 52 weeks prior to the leave they receive up to two thirds of their wages up to a maximum of five hundred and twenty-four dollars were the six weeks of paid leave this paid leave would run concurrently with federal FMLA or EndWar New Jersey family leave which have some areas of overlapping coverage but not complete overlapping coverage and so New Jersey is a complex state to administer leave New York has recently enacted a broad paid family leave for all private employers who are you prefer employees who are fuller part-time and who work twenty six or more consecutive weeks for a covered employer and public employers can opt in the maximum leave allowed during a 52-week period increases annually and it started with 8 weeks and as of this year it is 10 weeks the maximum benefit is 50% the lesser of the employees average weekly wage or the state average weekly wage and it increases this year to 55% and next year to 60% paid family leave in New York is very broadly available and has led many employers to seek some outside administration for eligibility and benefits determinations and so this has been an area that for insurers has been a new area of coverage but one that has led to a number of questions as the regulations in New York are not as thoroughly developed as the fine questions require rhode island provides paid family leave to all private sector employees and public sector employees who whose employers have opted into the program the benefit is less in rhode island than in some of the other states we were just covering providing four weeks of paid leave for birth adoption or fostering of a new child or to care for a family member with the serious health condition and up to thirty weeks of paid leave for a workers own disability so a different approach in Rhode Island the maximum benefit is quite high seven hundred and fifty dollars per week based on the employees earning and is again funded through payroll taxes Washington State requires employers to provide twelve weeks of paid time off for the birth or adoption of a child or for the serious medical condition of the employee where the employees family member some states have requirements for paid sick leave for state employees these include Arizona California kinnetik Maryland Massachusetts New Jersey Oregon Rhode Island Vermont Washington State and Washington DC so public sector employers in those jurisdictions have paid family leave requirement school related parental leave has become an increasingly common thing to see in States and the following have enacted legislation allowing parents leave to participate in children's educational activity so again no surprise to see California at Massachusetts you know leading in this area but in addition we also have Colorado Washington DC Illinois Louisiana Minnesota Nevada North Carolina Rhode Island and Vermont again not an area that is terribly common for employers to have to comply with but if you have operations in those states it would be very easy to run afoul of this if the supervisor or location manager denies a request for leave that is vectorially available so we've seen some recent changes to the interpretation of sexual orientation and gender identity discrimination in Michigan the governor's issued an executive directive Orange state employers from discriminating against public employees and applicants on the basis of sex which is defined to include sexual orientation and gender identity or expression and in Wisconsin an executive order January 7th banned discrimination against state workers on the basis of sexual orientation or gender identity some less common forms of legislation in New York City as of May of last year employers in the city must allow use of paid leave for employees if that the employee or a family member has been a victim of any act or threat of domestic violence unwanted sexual contact stalking or human trafficking and it applies to employers with five or more employees it requires 40 hours per year of safe time or sick leave for victims of the covered crimes again one where the on-site management may not realize this is a requirement and inadvertently violate the law in New York City Vermont on a statewide basis provides time off for employees who are the victims of crime as do many municipalities throughout the United States so again this is a topic that's worth checking in the jurisdictions in which you have operations another less common law but one that may be gaining traction is the idea of employees who can request a temporary change in their work schedule up to twice a year due to a personal event that would include the need to provide care for a minor child or care recipient to attend legal proceedings where a hearing for subsistence benefits any circumstances that would be the basis for save time or sick leave under the urn save time and sick time Act so employees can alter their hours reporting times or locations for a limited period of time this is sort of a novel approach and again New York is is reading the way but it remains to be seen how much traction this will get nationally New York also has an enhanced dialogue regarding accommodations employers being required to engage in cooperative dialogue regarding requests for reasonable accommodations for victims of domestic violence individuals with pregnancy or related conditions religious needs or disabilities so it expands the notion of the interactive process applicable under the Americans with Disabilities Act to other areas and imposes the same obligation for a good faith interaction prior to denying a request so yet another special provision in New York City that employers should be familiar with because these you know many of these areas would not be ones where there was a perception of a requirement to have some form of an interactive process if you fail to engage in the dialog that would be considered an unlawful discriminatory practice in violation of the New York City human rights law in Massachusetts there is a requirement for veterans to receive paid or unpaid leave on Memorial Day or Veterans Day if you have employees who are veterans they're entitled to that day off in Massachusetts and in Delaware their version of the state WARN Act which is the federal planet closing and mass layoff law requires employers with 50 employees to sixty days notice to affected employees the Delaware Department of Labor and the Delaware workforce board if there's going to be a mass layoff plan closing a relocation that will cause employment loss I'm so greater coverage than the federal wine act and that brings us to our question and answer session let me see if we have received any questions okay one one of my questions okay a first question is our office and almost all of our employees are in one state we have a few remote employees who work from their homes in other states specifically Minnesota Illinois Arizona and New Jersey do we use our homes we use our home state laws through the employees or the laws for the state they reside or conduct work the answer to that question is in general you would use the law that is the most favorable to the employee and so if you are located in a state and the company is headquartered in a state with a requirement that maybe does the law that is applicable or if the employee works in the state with a greater protection then you would follow that law subject to in some jurisdictions there are a minimum number of employees in the jurisdiction in order to trigger coverage but many states such as New Jersey do not have a minimum so if an employer is covered because they have enough employees anywhere in the country then the employees who work in New Jersey or who regularly receive assignments in New Jersey are covered by the New Jersey we've received another question which says personal six time we already provide and for example in New York it may be that annex the company's existing policy meets the obligation to provide the minimum amount of paid leave and so that would not be in addition to but it's prudent to make sure that the implementation and the requirements for the use of paid personal or sick time comply with the obligations of the New York paid time off whether that's for victims were for sick leave because it would be in general and under federal law permissible to have a greater requirement for example to take a medical leave if you're going to pay for it then would be required under the Family and Medical Leave Act and so while this is not in addition to necessarily the leave that you're making available ensuring that you are making it available in a manner that is compliant with New York or whatever States requirements is necessary a similar question to our first one - the laws apply to employers that have an employee that may work remotely in any of the states that our headquarters is located elsewhere and again many of the laws will apply to any employee within that state even if there are only a few and even if they are working remotely and so the question would be whether the company is itself a covered employer as defined by the particular state law I will believe those are all the questions [Music] that appears to be the end of the questions if anyone has an additional question I will be happy to take that and we'll leave a little bit of time with that okay is okay i we are getting some additional questions so get to those they're with me for one moment please okay okay the next question will the webinar be recorded and sent to the attendees afterwards um it is being recorded and but will not be automatically sent to the attendees it will be available on our website Quarles comm at the under the Labor and Employment Practice Group tab events section both the recorded program and the powerpoints will be made available on that basis the next question regarding school related parental leave how broad is the criteria for educational related activities that's quite it depending on the state it can be quite broad and so to attend a parent-teacher conference to participate as a volunteer and a class program to attend a performance you know quite broad in terms of how the activities are defined okay next question please expand on the ability to discuss compensation during interviews can we still ask what compensation with the applicant require the answer to that specific question is yes asking for the applicants expectation or requirement for salary is fine even in the states that have banned the history of salary questions or that subject from interviews and that's actually the way that in those states it is preferred to be approached and in those states it is also permissible for the applicant to disclose their compensation if they are using it for the purpose of negotiating the salary level the next question how do we stay in compliance with all the laws and attending a program like this is a good start but I would say you should make a list of the states and localities in which you have operations and review on a regular basis some of the compilations available for state law updates so for example HR professionals are familiar with the Society for Human Resource Management and there are also some some paid services that will provide updates on additional state or local requirements the specific question how do we we have a nationwide sales force and again how do we remain in compliance and that would be the method you really if you have employees in every state you you may find that it's necessary to have someone dedicated to monitoring developments many nationwide employers have a compliance function specifically within the HR department that tracks the new legislation as well as the proposed legislation and you also can consider resources that are again available either with a membership in a professional organization or some other fee based serve such as Westlaw another question okay here's the next question what if the employer is in multiple states and has more than 50 employees does the Maryland disclosure of sex harassment allegations just for those in Maryland or an aggregate of all all their locations and the answer to that is if you are a covered employer in Maryland you would have to report but only on the events that have taken place in Maryland so you may be covered and you may not have very much to report and so an additional question is the presentation available to view again and the answer is yes it will be on our website and you can both listen to the audio again and you will have the powerpoints available is there common criteria that makes a company a covered employer in States and the answer is yes it is generally the number of employees and it has nothing to do with the type of operation or the volume of business but employing people in one of the states is the the main criteria for determining whether t ere is coverage and the states may have a minimum of a certain number of employees within the state in order for there to be coverage of some of these laws or it may look to the company's total work force and apply coverage just to the employees within that state if the employer reaches the minimum so for many of the things we looked at today there was a minimum of 50 employees and so in in many of the states once you have 50 employees anywhere in the United States you would be covered by that state's law with regard to employees who are working in the particular state right and participant very helpfully noted that the requirement for California for the mandatory training for supervisors is two hours as we said and there's one hour of mandatory training for non supervisory employees in California another question in California for school related parental leave is it required to be paid time off and and the answer is now there's a number of questions that are similar to two that we already answered about company being headquartered in one jurisdiction but have employees working in other states and I think we covered that another question if my US parent company has around 300 employees throughout the US and some numbers in different states do the laws apply to each entity or just those with the number of employees at that site and the answer to that is that depending on the relationship between the operating companies some of the laws might apply regardless of being a separate company or they might not a general rule is that to the extent the multi company operations still have common control over day-to-day employment matters then they would generally be considered a single entity different laws in different states use different tests for determining joint employment rate for single employment or integrated employment and so the the watchword is who's making decisions about the day-to-day HR functions and if that is centralized were common between one or more of the companies you would add those numbers together and then the employees in each of the companies would be considered to work for the company as a whole so that would be where you might have three companies with all together 55 employees but no single company with 50 and depending on how the company is structured and managed it could be a covered employer for all the different entities even though none of them individually employ enough people another question if an employer in Washington DC already offers paid time off in excess if they're required paid sick leave law do they need to make any changes to their time off program and the question if the answer to that question is they should make sure that the procedures and requirements for obtaining their internal paid time off meet the requirements of the paid time off statute so you know for example if an employer said you must request time off in a certain amount of advance notice you know with a certain amount of advance notice that that may not be sufficient to comply with a particular state or localities requirement question how do we apply for sure FCP credits pretending in the handout section of the webinar dashboard you will see a form for HR organization self reporting and you can use that to report the credits I see that we are now at 12 o'clock and I to be respectful of everyone's time if you would like to add we'll end the webinar now I will stay on the line to answer questions for a few additional minutes but we will consider the webinar to be concluded at this point thank you very much for your participation so for those who have remained another question FMLA requirements are 50 employees within a 75-mile radius of one location does this cover all employees in the US if one location meets the guideline the answer to that is no under the federal Family and Medical Leave Act an individual employee seeking leave must work in a location at which there are at least 50 employees within a 75-mile radius so small location operations are not covered by the Family and Medical Leave Act that is one of the the driving forces behind the state enactment of paid or unpaid leave that are broader than that and would cover smaller location operations so the answer is but you may need to make leave available under a state law that is not required under the FMLA question do you have any advice from Maryland sick and safe leaves specifically notifying employees about the benefit that's something that you would want to include in your employee handbook and any periodic updates to that that are either electronically distributed or posted another question - the minimum wage laws apply to people who work on Commission and so under federal law in order to be exempt from the minimum wage part of the Fair Labor Standards Act for a commissioned person they have to be qualified as an outside salesperson and so if those requirements are met then the federal minimum wage does not apply each of the states has a different or potentially has a different way of looking at Commission and so that I would say as a technical question that is worth having reviewed on a state-by-state basis because many states do not have as broad an exemption for commissioned salespeople as is available under federal law another question or the follow up presentations coming in the near future we have a full schedule of webinars in the labor and employment area that will be coming out between now and over the next six months and so I would invite you to look at the upcoming events listing to see the topics I would anticipate that there will be another update on state laws within a year as as things continue to develop at the state level it's clear that that's where all the action is and many employers are you know as we've seen from the questions headquartered in one location and with operations in many locations there is a question are there CPE credits available for CPAs and I I must tell you I don't know the answer to that but if you would whoever asked that I could send me an email I will get you the answer to that and I believe that is it for the question so once again thank you very much and I hope you make it a great day