The National Labor Relations Board has held that an employer’s obligation to deduct union dues ends when the collective bargaining agreement containing the checkoff provision expires. Valley Hospital Medical Center, Inc. d/b/a Valley Hospital Medical Center, 368 NLRB No. 139 (Dec. 16, 2019).

The NLRB overruled Lincoln Lutheran of Racine, 362 NLRB 1655 (2015), in which the Board held an employer continues to have an obligation to deduct union dues from employee paychecks despite the expiration of a collective bargaining agreement containing a dues check-off provision on which the deductions were based.