New misconduct standard set by NLRB gives employees significant leeway in tone of communications with management

By Kristofor L. Hanson

On May 1, 2023, the National Labor Relations Board returned to its prior standard for analyzing the legality of disciplining employee misconduct related to protected concerted activity. In Lion Elastomers LLC II, 372 NLRB No. 83, the Board overruled its decision in General Motors, 369 NLRB No. 127 (2020) and reverted to its pre-2020 standard for determining whether an employer may lawfully discipline employees whose actions and/or words cross the line into abusive conduct. General Motors applied the three-part Wright Line standard — under which the employer can lawfully discipline an employee if it can show it would have taken the same action absent the employee’s protected activity — in all abusive conduct circumstances. For employers, that standard lasted just three years and with its decision in Lion Elastomers LLC II, the Board will once again apply one of three different standards, depending on whether the conduct involves: 1) communication to management; 2) communication in social media posts or in conversations among employees; or, 3) picket-line conduct. As a result, employers must evaluate different standards in determining whether it can lawfully impose discipline based on the context in which the misconduct occurred.

This decision returns employers to an environment where offensive or abusive actions that go beyond the bounds of proper workplace conduct will be considered lawful in most instances if the conduct arguably occurs in the context of exercising protected activity (grievance meetings, collective bargaining, intra-employee communications, social media discussions about the employer, etc.). The decision also engenders workplace environments that lack professionalism among workers and places employers in the difficult position of risking unfair labor practice charges for disciplining unruly behavior or allowing such behavior and creating an atmosphere where such behavior is condoned.

As a result, employers must be cautious when disciplining employees who engage in behavior that they deem unprofessional or disrespectful. Therefore, employers would be wise to consult with labor counsel before taking any disciplinary action under such circumstances.

EEOC Issues Update Relating to Artificial Intelligence

By Alexandra “Sasha” Chepov

In recent years, employers have adopted a wide variety of algorithmic decision-making tools to assist them in making employment decisions such as recruitment, hiring, retention, promotion, transfer, performance monitoring, demotion, dismissal and referral. These tools have been increasingly utilized by employers in an attempt to save time and effort, increase objectivity, optimize employee performance and decrease bias.

On May 18, 2023, the EEOC issued guidance clarifying the potential risks employers may face if the artificial intelligence tool being used results in an adverse discriminatory impact under Title VII of the Civil Rights Act of 1964 (“Title VII”). The purpose of the EEOC’s publication is to ensure that the use of new technologies complies with federal EEO law by educating employers, employees and other stakeholders about the application of these laws to the use of software and automated systems in employment decisions.


  • Software: Refers to information technology programs or procedures that provide instructions to a computer on how to perform a given task or function.
    • Many different types of software and applications are used in employment, including automatic resume-screening software, hiring software, chatbot software for hiring and workflow, video interviewing software, analytics software, employee monitoring software, and worker management software.
  • Algorithm: An “algorithm” is generally a set of instructions that can be followed by a computer to accomplish some end. Human resources software and applications use algorithms to allow employers to process data to evaluate, rate, and make other decisions about job applicants and employees. Software or applications that include algorithmic decision-making tools are used at various stages of employment, including hiring, performance evaluation, promotion and termination.
  • Artificial Intelligence (“AI”): Some employers and software vendors use AI when developing algorithms that help employers evaluate, rate and make other decisions about job applicants and employees. Congress has defined “AI” to mean a “machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations or decisions influencing real or virtual environments.

Employers sometimes rely on various software platforms that incorporate algorithmic decision-making at a number of stages throughout the employment process. For example, resume scanners may be used to prioritize applicants using certain keywords; employee monitoring software may be used that rates employees on the basis of their keystrokes or other factors; “virtual assistant” or “chatbots” may be used to ask candidates about their qualifications and reject those who do not meet pre-defined requirements; video interviewing software may be used to evaluate candidates based on their facial expressions and speech patterns; and testing software that provides “job fit” scores for applicants or employees regarding their personalities, aptitudes, cognitive skills, or perceived “cultural fit” based on their performances on a game or on a more traditional test.

Title VII:

Title VII generally prohibits employers from using neutral tests or selection procedures that have the effect of disproportionately excluding persons based on race, color, religion, sex or national origin, if the test or selection procedures are not “job related for the position in question and consistent with business necessity.” This is called “disparate impact” or “adverse impact” discrimination.

If the use of an algorithmic decision-making tool has an adverse impact on individuals of a particular race, color, religion, sex, or national origin, or on individuals with a particular combination of such characteristics, then the use of the tool will violate Title VII unless the employer can show that such use is “job related and consistent with business necessity” pursuant to Title VII.

Employers that are deciding whether to rely on a software vendor to develop or administer an algorithmic decision-making tool should determine whether steps have been taken to evaluate whether the use of the tool causes a substantially lower selection rate of individuals with a characteristic protected by Title VII. A “selection rate” refers to the proportion of applicants or candidates who are hired, promoted or otherwise selected. A selection rate for a group of applicants or candidates is calculated by dividing the number of individuals hired, promoted or otherwise selected by the total number of candidates in the group.

As a general rule of thumb, the four-fifths rule is used to determine whether the selection rate for one group is “substantially” different than the selection rate of another group. The rule states that one rate is substantially different than another if their ratio is less than four-fifths (or 80%). However, the four-fifths rule may not be appropriate in certain circumstances. For example, smaller differences in selection rates may indicate adverse impact where a procedure is used in making a large number of selections, or where an employer’s actions have discouraged individuals from applying disproportionately on a Title VII-protected characteristic. In any event, the four-fifths rule may be used to draw an initial inference that the selection rates for two groups may be substantially different and prompt the employer to turn to additional information about the procedure or algorithm in question.

If an employer is in the process of developing a selection tool and discovers that use of the tool may result in an adverse impact on individuals of a particular protected characteristic by Title VII, an employer can take steps to reduce the discriminatory impact or select a different tool in order to avoid undertaking a practice that violates Title VII.  Failure to adopt a less discriminatory algorithm that was considered during the development process may give rise to liability.


Although not discussed in the EEOC’s May 18, 2023 publication, the EEOC has previously issued technical guidance on the use of AI and discrimination in the workplace under the Americans with Disabilities Act (ADA). The most common ways that an employer’s use of algorithmic decision-making tools could violate the ADA are:

  • Failure to provide a “reasonable accommodation” that is necessary for a job applicant or employee to be rated fairly and accurately by the algorithm.
  • Rely on an algorithmic decision-making tool that intentionally or unintentionally “screens out” an individual with a disability, even though the individual is able to do the job with a reasonable accommodation.
  • Adopt an algorithmic decision-making tool for us with its job applicants or employees that violates the ADA’s restrictions on disability-related inquiries and medical examinations.

Why does this matter? 

Where an employer administers a pre-employment test, it may be liable for any resulting Title VII or ADA discrimination, even if the test was developed by an outside vendor. Similarly, an employer may be held liable for the actions of their agents, which may include entities such as software vendors, if the employer has given them authority to act on the employer’s behalf.

If the vendor states that the tool should be expected to result in a substantially lower selection rate of individuals of a particular characteristic protected by Title VII or the ADA, then the employer should consider whether the use of the tool is job related and consistent with business necessity and whether there are any alternatives that may be implemented that reduce the disparate impact, yet still satisfy the employer’s needs. Even where a vendor is incorrect about its own assessment, and the tool results in either disparate impact or disparate treatment discrimination, the employer could still be liable.

For that reason, employers are encouraged to conduct an ongoing self-analysis to determine if the technology they are using could result in discrimination in any way or whether their employment practices have disproportionately large negative effects on a basis prohibited under Title VII or treat protected groups differently.


By Sally A. Piefer

Under Wisconsin law, an employee is disqualified from receiving benefits if the employee engages in misconduct or substantial fault. In 2013, the Wisconsin legislature changed the definition of misconduct. With the change, Wisconsin law explicitly recognized that an employee’s absenteeism/tardiness can constitute misconduct, and therefore disqualified an employee from receiving unemployment compensation benefits:

Absenteeism by an employee on more than 2 occasions within the 120-day period before the date of the employee’s termination, unless otherwise specified by his or her employer in an employment manual of which the employee has acknowledged receipt with his or her signature, or excessive tardiness by an employee in violation of a policy of the employer that has been communicated to the employee, if the employee does not provide to his or her employer both notice and one or more valid reasons for the absenteeism or tardiness.

This particular provision was challenged Wis. Dep’t of Workforce Dev. v. Wis. Labor & Indus. Review Comm’n, 2017 WI App 29, ¶ 4, 375 Wis. 2d 183, 895 N.W.2d 77 (“Beres”). The employee in Beres worked for an employer whose written attendance policy stated that it could discharge an employee during the probationary period if the employee failed to call in at least two hours prior to the employee’s scheduled shift. The employee – Beres – was absent due to an illness and failed to comply with the employer’s 2-hour call in procedure during her probationary period. She was terminated for failing to follow the procedure.

When Beres applied for unemployment benefits, DWD concluded she was disqualified from receiving benefits because she violated her employer’s attendance policy. The Department of Workforce Development (DWD) determined the employer could enact a stricter attendance policy than the one outlined in the statute, and that Beres was not entitled to unemployment benefits because she violated her employer’s stricter requirement. When Beres appealed, the Commission reversed DWD’s decision and awarded unemployment benefits, concluding that an employee could not be denied benefits on the basis of an employer’s attendance policy that was stricter than the absenteeism policy in the statute. DWD appealed this decision, and the Circuit Court agreed with DWD’s interpretation of the law. The Wisconsin Court of Appeals then reversed the Circuit Court’s opinion and adopted the Commission’s position. The case went to the Wisconsin Supreme Court.

The sole issue before the Wisconsin Supreme Court was as follows:

Does Wis. Stat. § 108.04(5)(e) allow an employer to adopt an attendance or absenteeism policy that differs from that set forth in § 108.04(5)(e) such that termination of an employee for violating the employer’s policy results in disqualification for unemployment compensation benefits even if the employer’s policy is more restrictive on the employee?

The Court answered the question in the affirmative, finding that:

[T]he plain language of Wis. Stat. § 108.04(5)(e) allows an employer to adopt its own absenteeism policy that differs from the policy set forth if § 108.04(5)(e), and that termination for the violation of the employer’s absenteeism policy will result in disqualification from receiving unemployment compensation benefits even if the employer’s policy is more restrictive than the absenteeism policy set forth in the statute.

Because Beres was terminated for not complying with her employer’s absenteeism policy, she was not entitled to unemployment benefits. The Court explicitly stated that its interpretation of Wis. Stat. § 108.04(5)(e) “makes clear that an employer can opt out of the statutory definition of ‘misconduct’ and set its own absenteeism policy, the violation of which will constitute statutory ‘misconduct.’” The Court concluded that “an employee will be considered to have been terminated for ‘misconduct,’ and thus disqualified from obtaining unemployment compensation benefits, if the employee violates the statutory definition of absenteeism, except if the employee adheres to the employer’s absenteeism policy specified in the employment manual of which the employee acknowledged receipt” through a signature.

Immediately following the Beres decision, the Labor & Industry Review Commission (LIRC) repeatedly interpreted unemployment compensation law in accordance with Beres. Beginning in 2019, shortly after Tony Evers, a Democrat, took office, LIRC began to backtrack on this position. Initially, LIRC concluded that an employee who was terminated for violating an employer’s attendance policy was not discharge for misconduct, but instead was terminated for substantial fault.

In July 2022, LIRC issued a decision in which it found that an employee who was terminated for violating his employer’s attendance policy did not constitute either misconduct or substantial fault. On appeal, the Circuit Court in Waukesha County issued a decision reversing LIRC’s decision. The employer had its own attendance policy, which was published in the employee handbook. The employee had notice of the policy. Under the policy, the employee received points for certain attendance violations. Employees who exceed a certain number of points are subject to termination. The employee at issue had a history of attendance violations, and was eventually terminated after exceeding the threshold number of points for a second time.

The Circuit Court concluded that the statutory provision which discusses misconduct in connection with an employer’s own attendance policy was not ambiguous, and that the Wisconsin Supreme Court’s decision in Beres was controlling. In addition, the Court stated that Beres was decided in June of 2018, and that if the legislature believed Beres was wrongly decided, it had nearly five years to signal the decision was incorrect. The Circuit Court concluded the employee was terminated for misconduct and therefore ineligible for benefits. Stay tuned for further developments on this front—both LIRC and DWD have filed appeals and the case will now be decided by the Wisconsin Court of Appeals.


By Samantha J. Wood

Due to precautions surrounding the COVID-19 pandemic, in March 2020, the Department of Homeland Security (“DHS”), announced flexibilities regarding Form I-9 compliance. Specifically, employers who hired employees to work exclusively in a remote setting were temporarily exempt from physically inspecting employee identification and employment authorization documents in the employees’ physical presence. Documents could be inspected remotely, such as over video link, fax, or email.

On July 31, 2023, DHS will end these COVID-related flexibilities, and require employers to inspect employee identification and employment authorization documents in-person.  Additionally, employers must complete in-person physical document inspections for employees whose documents were previously inspected remotely by August 30, 2023.

DOL Issues Opinion Letter Relating to Holidays for Employees on FMLA

By Alexandra “Sasha” Chepov

The Department of Labor (DOL) recently issued an opinion letter providing clarification as to how an employer is to calculate an employee’s leave entitlement under the Family and Medical Leave Act (FMLA) when such leave is taken during a week that includes a holiday.

The FMLA entitled eligible employees of covered employers to take unpaid job-protected leave for a qualifying family and medical reason with continuation of group health insurance coverage under the same terms and conditions as if the employee had not taken leave. Eligible employees are eligible to take up to 12 workweeks of leave in a 12-month period for various qualifying reasons, and up to 26 workweeks of leave in a single 12-month period to care for a covered servicemember. 29 U.S.C. § 2612(a)(1), (2). Under certain circumstances, an employee may use FMLA leave intermittently, meaning, the employee may use such leave in separate blocks of time, or on a reduced leave schedule by reducing the time worked in a day or week. 29 U.S.C. § 2612(b)(1); 29 C.F.R. § 825.202(a).

Where an employee takes FMLA leave for less than one full workweek, the amount of FMLA leave used is determined as a proportion of the employee’s actual workweek. For example, if an employee who would otherwise work 40 hours per week takes off 8 hours, the employee uses one-fifth (1/5) of a week of FMLA leave. 29 C.F.R. § 825.205(b)(1).

When a holiday falls during a week than an employee is taking a full workweek of FMLA leave, the entire week is counted as FMLA leave. 29 C.F.R. § 825.200(h). For example, an employee who works Monday through Friday takes leave for a week that includes the Fourth of July on Thursday would use one week of leave, rather than 4/5 of a week. However, if a holiday falls during a week when an employee is taking less than full workweek of FMLA leave, then the holiday is not counted as FMLA leave, unless the employee was scheduled and expected to work on the holiday and used FMLA leave for that day.

In sum, the DOL opinion letter clarifies that the actual workweek, for purposes of calculating FMLA leave taken, includes the day of the holiday. If a holiday were to be subtracted from the workweek when calculating the amount of FMLA leave used in a partial week of leave, this would result in an impermissible reduction of the employee’s leave entitlement because the employee would have to use a larger amount of FMLA leave when needed.

Therefore, under the FMLA, the employee’s normal workweek is the basis for the employee’s leave entitlement. If the holiday occurs during an employee’s workweek, and the employee works part of the week and uses FMLA leave for part of the week, the holiday does not reduce the amount of the employee’s FMLA leave entitlement unless the employee was required to report for work on the holiday. If the employee was not expected or scheduled to work on the holiday, the fraction of the workweek of leave used would be the amount of FMLA leave taken (which would not include the holiday) divided by the total workweek (which would include the holiday).


By Laurie A. Petersen

Federal government contractors and subcontractors, as part of their obligation under Section 503 of the Rehabilitation Act and 41 CFR Part 60-741.42, are required to invite applicants (pre and post offer) and employees (including every five years) to self-identify as an individual with a disability on a form approved by the Office of Federal Contract Compliance Programs (OFCCP).

On April 25, 2023, the OFCCP published a revised form.  While that form does not substantively change the contractor’s obligations, it updates the following:

  • The preferred language used for disabilities;
  • Additional examples of disabilities; and
  • More description on some of the previous examples of disabilities.

Contractors must implement the new form by July 25, 2023, and continue to use the previous form until implementing the new form.  The only portion of the form that contractors may modify or delete is the “For Employer Use Only” section.

NLRB Says that Non-Compete Agreements Should Be Deemed Unlawful

By Kristofor L. Hanson

Continuing a very aggressive employee- and union-friendly agenda, on May 30, 2023, NLRB General Counsel Jennifer Abruzzo sent a memo, GC 23-08, to all Regional Directors, Officers-in-Charge, and Resident Officers, setting forth her view that the offer, maintenance, and enforcement of non-compete provisions in employment contracts and severance agreements violate the National Labor Relations Act (NLRA) except in limited circumstances.

Though overbroad non-compete agreements are generally viewed as unlawful and subject to invalidation, the GC memo explains that within the context of the NLRA, overbroad non-compete agreements are unlawful because they chill employees from exercising their rights under Section 7 of the National Labor Relations Act. Section 7 protects employees’ rights to take collective action and engage in protected activity to improve their working conditions. Specifically, the memo explains that such agreements interfere with employees’ ability to:

  1. concertedly threaten to resign to secure better working conditions;
  2. carry out concerted threats to resign or otherwise concertedly resign to secure improved working conditions;
  3. concertedly seek or accept employment with a local competitor to obtain better working conditions;
  4. solicit their co-workers to go work for a local competitor as part of a broader course of protected concerted activity;
  5. seek employment, at least in part, to specifically engage in protected activity, including union organizing, with other workers at an employer’s workplace.

“Non-compete provisions reasonably tend to chill employees in the exercise of Section 7 rights when the provisions could reasonably be construed by employees to deny them the ability to quit or change jobs by cutting off their access to other employment opportunities that they are qualified for based on their experience, aptitudes, and preferences as to type and location of work,” said General Counsel Abruzzo. “This denial of access to employment opportunities interferes with workers engaging in Section 7 activity in a number of ways—for example, workers know that they will have greater difficulty replacing their lost income if they are discharged for exercising their statutory rights to organize and act together to improve working conditions; their bargaining power is undermined in the context of lockouts, strikes and other labor disputes; and their social ties and solidarity leading to improvements in working conditions at workplaces are lost as they scatter to the four winds.”

The memo preserves limited circumstances pursuant to which non-compete agreements could be lawful if the provisions clearly restrict only individuals’ managerial or ownership interests in a competing business, or true independent-contractor relationships. Moreover, there may be circumstances in which a narrowly tailored non-compete agreement’s infringement on employee rights may be justified by special circumstances.

Although General Counsel memos are not binding on employers, they reflect the Board’s prosecutorial intent. Accordingly, all NLRB regional offices are required by the GC to submit cases concerning “arguably unlawful” non-compete agreements, as well as special circumstances defenses, to the NLRB’s Division of Advice. The memo directs NLRB regions to seek make-whole relief for employees subject to unlawful provisions who can show lost employment opportunities as a result of such provisions. Once complaints issue, the GC will seek to convince the members of the NLRB to adopt her theory that such provisions violate the Act.

Employers, whether unionized or not, should consult with experienced labor counsel to thoroughly assess non-compete and non-solicitation agreements and severance agreements in light of Section 7 and the GC’s memo.


By Sally A. Piefer

Wage and hour cases in Wisconsin and across the country have been on the rise. A large percentage of wage and hour cases are filed as class action lawsuits. Often, unsuspecting employers are the targets of lawsuits, or a claim is filed as a result of an employee seeking legal advice on another employment-related topic. Wage and hour cases may not be covered by Employment Practices Liability Insurance (EPLI), and while a single employee claim can be a nuisance, a class-action claim can be very costly for employers, since an employer will be liable not only for the unpaid wages, but also an equal amount in liquidated damages, and attorney’s fees for the plaintiff.

In late 2022, the Ninth Circuit Court of Appeals, which has jurisdiction over much of the west coast, reversed a summary judgment decision which dismissed a lawsuit brought on behalf of a group of call center employees who alleged that the pre-shift and post-shift time they spent booting up and shutting down their computers was compensable.

The employees had to boot up their computers before they could clock into the employer’s timekeeping program, and also had to clock out of the timekeeping program before they could shut down their computers at the end of the day. They alleged that logging into the computer was “integral and necessary” and that following the call center’s protocol resulted in not being paid for all time they worked, which in turn resulted in unpaid overtime. The employees further alleged that the lost time was not de minimis.

The trial court dismissed this aspect of their claims, finding that booting up and shutting down computers was not a principal activity of the jobs of the call center employees. Rather, the employees were hired to answer customer phone calls and assist the customers. The trial court also determined that booting up and shutting down computers was also not integral and indispensable to the employee’s duties because they did not have to log in (or out) of the computer to take a customer’s call. The court likened the activity to an employee who was standing in line to clock in or out, which is normally not compensable.

On appeal, the Ninth Circuit concluded that the trial court erred in considering whether loading the timekeeping program to clock in was integral to the employee’s duties. The Ninth Circuit stated that the correct inquiry was whether “engaging the computer, which contains the phone program, scripts, customer information, and email programs, is integral to the employee’s duties.” Stated alternatively, the Ninth Circuit stated that the court should evaluate “the importance of booting up the computer to the employees’ primary duties of answering calls and scheduling rather than to their need to clock in using the electronic timekeeping system.” The Ninth Circuit reversed the dismissal of this claim and remanded the case back to the trial court to evaluate this question.

On remand, the trial court addressed whether the time the employees spent booting up and shutting down was de minimis. Activities under the Fair Labor Standards Act (FLSA) are considered de minimis when “the matter in issue concerns only a few seconds or minutes of work beyond the scheduled working hours.” This doctrine is generally concerned with the administrative practicality of recording small amounts of time.

The trial court again dismissed the plaintiffs’ claims, primarily because most of the employees testified it took mere seconds or a few minutes to turn the computer on and off. Therefore, the court determined the time was de minimis. If employees experienced some sort of delay in booting up or shutting down, the record contained evidence that employees sought to have their timecards adjusted.

The plaintiffs have again appealed the dismissal of their claims. Stay tuned for further developments on this issue, but employers should make sure they implement policies prohibiting off the clock work, and evaluating whether their time-keeping procedures comply with the FLSA and applicable state law.


By Samantha J. Wood

On June 27, 2023, the Pregnant Workers Fairness Act (“PWFA”) will go into effect.  This law, which was previously discussed here, extends the protections for pregnant workers by requiring employers with 15 or more employees to provide reasonable accommodations for pregnant employees and prohibits employment practices that discriminate against qualified employees affected by pregnancy, childbirth, or related medical conditions. The Act makes it unlawful for employers to take any of the following adverse actions:

  • Refuse to make reasonable accommodations to known limitations related to pregnancy, childbirth, or related medical conditions of a qualified employee, unless such accommodation would impose an undue hardship on the operation of the business;
  • Require a qualified employee to accept an accommodation other than a reasonable accommodation arrived at through an interactive process;
  • Deny employment opportunities to the employee if such denial is based on the need to make reasonable accommodations;
  • Require the employee to take paid or unpaid leave if another reasonable accommodation can be provided that would enable the employee to continue working; or
  • Take an adverse employment action against the employee because the employee requested or used a reasonable accommodation.

The EEOC has issued FAQs and a workplace poster, which are available here. The EEOC will begin accepting charges under the PWFA on Tuesday, June 27, 2023.

Also, the Providing Urgent Maternal Protections for Nursing Mothers (“PUMP”) Act, which was signed into law at the same time as the PWFA, went into effect on December 29, 2022. This law expanded workplace protections for employees who need to express breast milk following the birth of a child by requiring employers to provide to both exempt and non-exempt employees reasonable time to express breast milk in a private location other than a bathroom. The PUMP Act applies to all employers covered by the Fair Labor Standards Act, regardless of the size of their businesses. Employers with fewer than 50 employees are only exempt from the requirements of the PUMP Act if they can demonstrate that compliance with the provision would impose an undue hardship. The U.S. Department of Labor (DOL) recently released guidance on the PUMP Act, which is available here.

Covered employers must post a notice explaining employee’s rights under the PUMP Act.  The Wage and Hour Division has published an updated FLSA poster that reflects current pump at work requirements.

Employers should update their policies, procedures, and postings and advise management of these changes to ensure immediate compliance with these laws.

Kids’ Chance of Wisconsin Educational Conference

Kids’ Chance of Wisconsin is holding its annual education conference on Thursday, May 11, 2023, at the Renaissance Milwaukee, Hotel – Wauwatosa. Kids’ Chance is a non-profit organization that provides scholarships to children of seriously injured workers in Wisconsin.

Chelsie Springstead is a Kids’ Chance of Wisconsin Board Member and Doug Feldman is a Past President and current Ambassador.

Whether you are an Attorney, Employer, Safety/HR Manager, Claim Representative, or Nurse Case Manager, this is a must attend event! Please join us for a dynamic half-day seminar and networking opportunity.

If you are interested in attending or sponsoring this event, click here for more information 2023_Kids_Chance_of_WI_Seminar_Registration_Materials.pdf.