PERM ad

Screening of U.S. Applicants Based on Job Requirements

There was a recent case involving a Las Vegas resort seeking to hire someone in their Human Resources department that discusses how employers can permissibly screen out applicants lacking the minimal qualifications for the job at issue. In this case, BALCA reversed a denial based on an employer’s failure to interview two applicants who had considerable experience but did NOT hold the required degree (in HR). The main idea is that employers are not required to interview applicants who lack a primary job requirement. In this case, it was a specific degree, but really it could be anything (a license, other specific capabilities, etc.).

The Parball decision can be found here. Here is the main quote:

In this case, we recognize that the two applicants, and in particular P.R.1, have substantial job-related experience which could support a conclusion that they might qualify for the position even absent the specified degree and therefore, superficially, it might seem that further inquiry was warranted. That, however, is not what the case law requires. As first enunciated in Gorchev, the obligation to interview is triggered when the U.S. applicant meets the principal requirements for the position but lacks some subsidiary skill that might not be listed on the resume or could be learned through a reasonable period of on-the-job training. These are not the facts here. These two applicants lacked a specified bachelor’s degree and therefore no further inquiry was required. Accordingly, the CO erred in denying certification in this matter.

So, in other words, one of the applicants was almost certainly “qualified” using the real world definition, but not the PERM definition of that word; the law is clear that educational requirements set by employers (or other requirements) can be taken as firm and anyone failing to meet them may lawfully be screened out.

We originally published this blog entry here: https://www.permlabor.com/blog/screening-of-us-applicants-based-on-job-requirements

Work From Home Arrangements

Recent BALCA decisions have not really touched on issues important to our clients meaningfully, but I also did not want to go too long without posting something new one here, so we’ll take an issue that is potentially relevant to a lot of employer’s in today’s economy.

The case involves an application filed by Thomas & Betts Corp. for a sales position where the person travels extensively in the US and internationally. The application listed the employee’s home address in Atlanta - as opposed to corporate HQ in Memphis - as the primary worksite. The DOL then misapplied its own previous guidance on “unanticipated worksites” (called the Farmer Memo) and said the application should be denied because the wrong address was listed.

The decision of the DOL officer was reversed on appeal, which I agree was the correct call. The employer went to great lengths to make sure everything was done properly here (newspaper ads in two major metro areas) and they did list the proper address since it was not so much an “unanticipated worksites” case as one where the incumbent could telecommute and work-from-home.

The key commentary in the decision, in my opinion, is:

While there may well be sound administrative reasons for requiring an employer to treat a position that allows an employee to work from home as having a worksite location at the employer’s headquarters for PWD and recruitment purposes, OFLC has not clearly or consistently notified employers of this requirement. As the Employer correctly notes, the guidance provided during the March 15, 2007 Stakeholder’s Meeting stated that in the case of a telecommuting position where the employee is not required to live in a location specific to the job, the worksite is the employee’s home, and the PWD and recruitment would be for the worksite, not the employer’s headquarters . . . Since nothing in the PERM regulations or in any guidance adequately notified employers of a requirement that an employer must use its headquarters as the worksite location for job opportunities that offer the employee the unrestricted opportunity to work from a home location, we conclude that the CO erred by enforcing such a requirement on the unsuspecting Employer. See Infosys Ltd., 2016-PER-00074, slip op. at 11 (May 12, 2016).

We originally published this blog here: https://www.permlabor.com/blog/work-from-home-arrangements