Suppose you’ve just been audited by Office of Labor-Management Standards and your closing letter says your local union “did not retain adequate documentation for lost wage reimbursement payments to the Treasurer and Vice President totaling at least 53 times.”  OLMS informs you that your lost wage voucher needs to be updated so that you can describe the union business conducted during each time lost wages are claimed by an officer or steward.  So, exactly what information do you need to obtain for each lost wage claim?  And more importantly, if you haven’t already done so, what sort of policy on lost wages should your union have? 

First of all, to avoid a recordkeeping violation, OLMS requires that you maintain adequate documentation for all claims for lost wages.  Such claims, at a minimum, must be supported by the following:

1.       The date(s) wage loss actually occurred

2.      The number of hours of actual wage loss on each day claimed

3.      The rate of pay that applies to each day wage loss is claimed

4.      The specific union business purpose involved in each claim of wage loss.  It is not sufficient to record “union business”; more specificity is required.

OLMS recommends you use a lost wage voucher for each loss wage claim.  A sample voucher, along with recommendations for developing a lost wage policy can be found on OLMS’s Union Lost Time Payments Compliance Tip, located at http://www.dol.gov/olms/regs/compliance/CompTipLostTime.pdf. 

OLMS also recommends you develop a lost wage policy to promote transparency and accountability, as well as consistency.  While OLMS does not recommend any one best lost time policy or voucher, the Compliance Tip provides a detailed framework for a policy, including who is eligible to receive lost time and under what circumstances, what rate of pay applies, who approves lost wage claims, and when and how they must be documented.

John Lund is the Director of the Office of Labor-Management Standards.