The ADA and Michigan Persons with Disabilities Civil Rights Act – Differences Matter!

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By: Claudia D. Orr, Attorney, Plunkett Cooney 

 

The ADA and Michigan Persons with Disabilities Civil Rights Act – Differences Matter!

We often lump together state and federal civil rights laws but there are some major differences. For example, I recently advised readers that the US Court of Appeals for the Sixth Circuit just held that the tender back rule does not apply to federal civil rights claims. But that doctrine is still valid under state civil rights laws. As a reminder, the tender back rule requires the return of the consideration given for a release of claims at or before the time the release is challenged and a lawsuit if filed.  I am still upset with the 6th Circuit’s ruling, but I digress.

Other differences include whether there can be individual liability (state yes, federal no) or punitive damages which are intended to punish (state no, federal yes), whether an administrative charge must first be filed with a civil rights agency (state no, federal yes), whether you can shorten the limitations period by contract (state yes, federal maybe if it is drafted correctly) and some of the prima facie cases/burdens of proof, to name a few.

Today’s case, Cook v DTE Energy Corp Serv, LLC, an unpublished decision of the Michigan Court of Appeals released this month, demonstrates some differences when it comes to state and federal disability civil rights laws. Let’s look at what happened and then I will tell you what caught my eye in this case.

Plaintiff Cook began working for Mich Con in 1980 and became a DTE employee after the merger. She was a business support specialist and was expected to submit weekly production schedules documenting her work. Specialists are evaluated based on their productivity (90-120% “fully meets expectations”, 80-89% “meets many”, below 80% “does not meet”). The ratings are calculated based on days the specialist actually worked and did not reflect time off.  In addition, Cook constantly failed to turn in her production reports (which also adversely affected her production numbers), and this became a major issue.

Cook also had a history of taking time off from work. She had intermittent leave under the Family and Medical Leave Act (“FMLA”) in 2010 and 2011 to care for her father, and she had various injuries and illnesses that caused her to take additional time off during periods when she did not have an active, approved FMLA leave.

From late 2013 through October or November 2014 Cook missed over 150 hours during the “rolling” 12 month period, which burdened other employees. Cook was instructed she should minimize her sick time. After Cook had been given a coaching and a documented verbal warning for attendance, she wrote on the warning notice that she would pursue an intermittent FMLA leave for her absences.

Following her evaluation for 2013, Cook was placed on a performance improvement plan because her production reports failed to provide sufficient detail. By April 2014, Cook showed improvement in her production, but still failed to provide sufficient detail in her production reports.  Cook successfully completed the performance improvement plan in July 2014, but was warned that if she failed to maintain her level of performance, she could be terminated. Cook failed to do so. Her mid-year performance review in September 2014 indicated that Cook’s production had already dropped to 36% the very next month following the performance improvement plan and she had stopped submitting her production reports.  Cook’s 2014 evaluation indicated that she was “at risk” and “off track”.

In September 2014, Cook suffered three strokes and was hospitalized. Because of confusion and vision impairment, her doctor said she was not fit for work.  Cook took a leave of absence from work.  The leave was extended through December 2014, and her doctor provided a tentative return to work date of March 2, 2015. While her doctor opined that she was totally disabled, an independent medical examination on January 13, 2015, determined that there were no medical conditions that would prevent her from returning to work. DTE sent Cook a letter asking her to return to work on January 27, 2015 and she returned on February 3, 2015.

Cook failed to report to work on March 3, 2015.  Cook said she thought she had informed “someone” that she was not going to be in on that day, but DTE terminated her employment determining that this absence was a no call/no show.

Cook initiated a lawsuit under the Michigan Persons with Disabilities Civil Rights Act (“MPDCRA”) in March 2016.  We can only assume that she sued under state law because she had failed to timely assert a charge with the Equal Employment Opportunity Commission within 300 days as required under the Americans with Disabilities Act.

There were various claims asserted under MPDCRA (discrimination because of disability or perceived disability), harassment and hostile work environment because of disability and retaliation for taking medical leave. What puzzles me though is why a claim under FMLA was not pursued.  Cook also alleged that DTE failed to promote her because of her race in violation of the Elliott-Larsen Civil Rights Act, but she later voluntarily dismissed that claim (perhaps because of her documented performance issues). Eventually, all of her claims were dismissed when the trial court granted DTE’s Motion for Summary Disposition finding Cook failed to prove one or more elements of each claim.

Cook appealed and the Michigan Court of Appeals in a detailed analysis affirmed the trial court’s dismissal of each claim for various reasons.  But those reasons are not what this article is about.

Two things caught my attention in this case and reminded me of some basic differences between the MPDCRA and the ADA. First, the appellate court found that, while Cook had shown she had various medical conditions, she failed to prove she had a “disability”. This required a showing that she was substantially limited in her ability to perform some major life activities. The court noted that while Cook had discussed the fact that she had suffered strokes causing her to be unable to return to work for a period of time, the appellate court found that she failed to make this argument in “that portion of her response in which she argued that … she had a qualifying disability” under the act.

Second, the court also emphasized that a disability must not prevent the employee from performing the duties of her position, with or without an accommodation.  MCL 37.1103.  The court found that DTE had plenty of documentary evidence (from Cook’s physician, the Social Security Administration and the Unemployment Agency) showing that Cook was disabled and unable to work during the “relevant time period”.

So, think about this.  While the court recognized that Cook had medical conditions, it found that she failed to prove she had a disability, but the court also found she was “disabled” and unable to work during the “relevant time period.”

Would a court’s focus and findings on these two issues be the same under the Americans with Disabilities Act (“ADA”)? Probably not today.  Back in the “good ole days” before the ADA was amended, the act required plaintiffs to walk a fine line between being sufficiently incapacitated to rise to the level of a disability, but not so disabled that the person could not perform the essential functions of their position with or without a reasonable accommodation. This was a very difficult balance to achieve for plaintiffs.

But the amendment to the ADA in 2008 changed this.  Now, the EEOC and some courts find temporary injuries (such as a torn tendon) rise to the level of “disability” under the ADA. In addition, when an employee is unable to perform the essential functions of their position even with an accommodation, the employer must now consider whether a leave of absence to permit the employee time to recover is a reasonable accommodation.

This combination is very difficult for employers. The ADA was passed with the intent of removing barriers for individuals with disabilities (such as being blind, deaf or paraplegic) so that they could perform the essential functions of their job. Now, a person who is injured and unable to walk temporarily may be entitled to a leave of absence under the ADA.

But there is hope for employers. Recently, the US Court of Appeals for the Seventh Circuit reaffirmed that the ADA is not a law intended to provide an employee with a leave of absence but assistance to disabled workers so they can work. Severson v Heartland Woodcraft, Inc, 872 F3d 476 (CA 7, 2018).  Granting an extended leave does not enable an employee to perform all of the essential functions of his job, but rather enables the person to avoid performing all of the functions.  An occasional or short term leave may be permitted under the ADA when, for example, an employee needs time off for a flare up of lupus so painful that the employee must stay home. But, “[l]ong-term medical leave is the domain of the FMLA… recognizing that employees will sometimes be unable to perform their job duties….In contrast, ‘the ADA applies only to those who can do the job.’”  Id at 481. Please keep in mind that this is not the rule in our federal circuit. This split in the federal circuits may eventually set the issue up for a ruling by the US Supreme Court.

Contrast that to the MPDCRA.  Because Cook was unable to perform the essential functions of her position during “the relevant time” (even with reasonable accommodation), she did not have a disability under the MPDCRA.  Since 1999, providing a leave of absence, or a “reasonable time to heal”, has not been required under our state law.  Lamoria v Health Care & Retirement Corp, 233 Mich App 560 (1999)

In addition, under the ADA, “accommodations” are only limited by imagination and the employer’s ability to prove an “undue hardship” (which becomes more difficult to prove as the employer’s financial and human resources increase).  However, our state law lists the specific accommodations that are required and, based on the size of the workforce, indicates the amount that must be spent by the employer before it is an undue hardship.

So, what should an employer do?  First, make sure that the employment application gives notice to applicants (and future employees) that requests for accommodations under the MPDCRA must be made in writing within 182 days of the day the need was known (or should have been known).

Second, make sure the employment application contains a 180-day limitations period that is properly worded to avoid being struck as to federal claims which must start with a charge at the EEOC.

Third, seek advice from an experienced employment attorney (such as the author) as disability issues arise.  Whether state or federal law is involved, these are the most complex legal issues faced by employers.  An attorney can advise concerning such things as how to lawfully seek further information about the disability and engage in the interactive process, and how to structure severance payments so that a release of claims will be honored despite the new tender back rule issue. There are differences between the state and federal disability civil rights laws and knowing how to properly navigate the legal mine field with both is key to avoiding liability.

This article was written by Claudia D. Orr, who is Secretary of the Board of Detroit SHRM, a member of the Legal Affairs Committee, and an experienced labor/employment attorney at the Detroit office of Plunkett Cooney (a full service law firm and resource partner of Detroit SHRM) and an arbitrator with the American Arbitration Association.  She can be reached at corr@plunkettcooney.com or at (313) 983-4863. For further information go to: http://www.plunkettcooney.com/people-105.html.    

Detroit SHRM encourages members to share these articles with others, inside and outside their organization, as long as its name and logo, and the author’s information, is included in the re-post of the article. October 2018.

Nov 6-7 Conference: Speaker Spotlight – David Pauer

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By: Michigan Wellness Council 

 

speaker spotlight

Nov 6-7 Conference
Exploring Pathways to Positive Workplace Culture

 

David Pauer
Director of Wellness for the Employee Health Plan
The Cleveland Clinic

speaker spotlight

David Pauer, is the fourth speaker of the MWC’s upcoming conference on Nov 6-7. The presentation is entitled “What can small business learn from one of the largest employee wellness programs in the world?”.

David is Director of Wellness for the Employee Health Plan (EHP) of Cleveland Clinic. EHP covers healthcare and wellness expenses for more than 100,000 Cleveland Clinic employee Caregivers and their family members. He has been with Cleveland Clinic for 12 years, first as a manager with the Employee Wellness department, and since 2010 with the EHP.

David has dedicated his career to nonprofit health organizations. He previously was the executive director of the Ronald McDonald House of Cleveland, the executive director of the Herb Society of America, and executive vice president of the American Diabetes Association, Ohio Affiliate.

Pauer earned a Master of Nonprofit Organizations degree, specializing in healthcare organizations, from the Weatherhead School of Management at Case Western Reserve University, and a Bachelor of Science in Community Health Education from The Ohio State University. David spent a year studying Spanish language, culture, and public health in Madrid, Spain in a program through Bowling Green State University.

 

 

Learn more about this presentation
and the full agenda

 

 

Register for the Conference – November 6-7, 2018
Conference Sponsorship Opportunities

Want to save on the cost of MWC events? Renew your MWC membership (or become a member) to get discounts.

Are you student? Contact us for student rates.

Enjoy your day!
Contact: Rita Patel, Executive Director

 

 

 

11/6 Training: Workplace Wellness that Works – Conversation Laura Putnam

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By: Michigan Wellness Council

 

WellBites Interview: Laura Putnam

Get to know Laura and more about her upcoming 11/6 training Workplace Wellness that Works can impact the success of your wellness programs.

 

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register for the training

November 6, 2018:
Workplace Wellness That Works

(Day 1 Of Two-Day Conference)

Training Sponsored by   MARSHmclennan

Laura Putnam is the award-winning author of the #1 Amazon Hot New Release in HR & Personnel Management book, Workplace Wellness That Works, and founder of Motion Infusion, a leading provider of well-being and human performance speaking and training services. Her work has been covered by MSNBC, The New York Times, US News & World Report, Entrepreneur, Business Insider, and NPR. Learn more about Laura at her website and follow her on LinkedIn.

Register for the Conference – November 6-7, 2018
Conference Sponsorship Opportunities

Want to save on the cost of MWC events? Renew your MWC membership (or become a member) to get discounts.

Are you student? Contact us for student rates.

Enjoy your day!
Contact: Rita Patel, Executive Director

 

 

 

United States, Canada and Mexico Reach Agreement on New Trade Pact; Labor Mobility Provisions Are Largely Unchanged

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By: Alexandra LaCombe, Fragomen, Del Rey, Bernsen & Loewy LLP

 

United States, Canada and Mexico Reach Agreement on New Trade Pact; Labor Mobility Provisions Are Largely Unchanged

At a glance

The labor mobility provisions of the United States-Mexico-Canada Agreement are expected to be implemented consistent with existing practices under NAFTA, though each country continues to have the authority to interpret the agreement with respect to the cross-border movement of businesspersons, professionals, intracompany transferees, traders and investors.

 A closer look

Canada, Mexico and the United States have reached agreement on a new trilateral trade pact to replace the North American Free Trade Agreement (NAFTA). The agreement will be known as the United States-Mexico-Canada Agreement, or USMCA.

The labor mobility provisions of the new pact – which ease the cross-border movement of businesspersons, certain professionals, intracompany transferees, traders and investors – are largely the same as those of NAFTA.  Canada’s agreement late on Sunday, September 30, 2018 to join the pact negotiated by Mexico and the United States earlier in September ensured that the mobility system established by NAFTA could continue.

What’s next for the USMCA

The leaders of the three countries are expected to sign the agreement within 60 days.  It must be ratified by the legislatures of the three countries before it can take effect.  Ratification is expected to take place in 2019.

What the revised agreement means for employers and foreign nationals

The three countries are expected to implement the labor mobility provisions of the USMCA consistent with existing practices under NAFTA.  Until the new agreement takes effect, the NAFTA mobility provisions are expected to remain in place without interruption.

This should put to rest the concerns of the U.S. employers that they are in danger of losing their Canadian and Mexican employees who hold the TN visa status.  The TN is a visa category under which citizens of Canada and Mexico have been able to work in the U.S. in certain specific professional categories which primarily require a Bachelor degree.  Many of these categories are in the STEM fields.

Each country maintains the authority to interpret the provisions of the USMCA, and country-specific policies and application procedures related to businesspersons, intracompany transferees, professionals, traders and investors cannot be ruled out.  For example, Canada currently requires intracompany transferees to be currently employed with a foreign subsidiary outside Canada, in addition to having been employed for one year within the previous three years for that entity.  The United States recently announced a pilot program to test new intracompany transferee procedures for certain Canadian applicants and imposed stricter interpretations of the TN Economist category.

If you need assistance with this, or any other immigration issue, please contact the author, Alexandra LaCombe, at (248) 649-5404 or alacombe@fragomen.com. Alexandra is a Member of the Legal Affairs Committee of Detroit SHRM and a partner at Fragomen Worldwide.

Detroit SHRM encourages members to share these articles with others, inside and outside their organization, as long as its name and logo, and the author’s information, is included in the re-post of the article. October 2018.

 

Nov 6-7 Conference: Speaker Spotlight – Shawn Premer

michigan

By: Michigan Wellness Council

speaker spotlight

Nov 6-7 Conference
Exploring Pathways to Positive Workplace Culture

 

Shawn Premer
Chief Human Resources Officer
Consumers Credit Union

shawn.jpgShawn Premer, is the third speaker for our upcoming conference on Nov 6-7. The presentation is entitled “Creating a world-class wellness program as an employee engagement strategy”.

Shawn Premer, SPHR, SHRM-SCP, Chief Human Resources Officer, Consumers Credit Union – Consumers Credit Union has 300 employees, over $900 million in assets and is headquartered in Kalamazoo MI. Shawn is responsible for providing leadership in establishing and implementing human resource strategies. Shawn’s primary focus is on employee and member engagement. Consumers is proud of its 98% member satisfaction rate, it’s over 11 years of recognition as one of West Michigan’s 101 Best & Brightest Companies and 4 years of being recognized Nationally as a 101 Best & Brightest Company!  In addition, Consumers has been honored as a 101 Best & Brightest in Wellness Employer in Michigan and a Healthiest 100 Employer Nationally.

Shawn holds a bachelor’s degree in business Management from Northwood University and an MBA with a focus in Global Business Studies from Cornerstone University.  Shawn also holds SPHR, SHRM-SCP, and Certified Corporate Wellness Specialist (CCWS) certifications.

A wife of 24 years and a mother of three, Shawn is also an avid runner and yogi.  In 2016 she was honored as Michigan’s Top HR Professional by the Michigan Chapter of Society of Human Resource Management (SHRM).  She also serves on the executive council for Michigan Chapter of SHRM, the board of Southwest Michigan First, the advisory board for Kalamazoo Valley Community College’s Groves Facility, and the board of Senior Services of Southwest Michigan where she chairs the Human Resource Executive Committee.  In addition to the organizations listed above Shawn also founded and chairs the Kalamazoo Area Wellness Networking group, which includes 20 area organizations who come together to share wellness best practices.

Learn more about this presentation
and the full agenda

Register for the Conference – November 6-7, 2018
Conference Sponsorship Opportunities

Want to save on the cost of MWC events? Renew your MWC membership (or become a member) to get discounts.

Are you student? Contact us for student rates.

Enjoy your day!
Contact: Rita Patel, Executive Director

 

 

American Society of Employers (ASE) announces the Michigan HR Executives of the Year for 2018

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By: American Society of Employers

 

American Society of Employers (ASE) announces the Michigan HR Executives of the Year for 2018

Honorees will be celebrated on Nov. 8 at ASE’s Annual Summit

Media Contact: Heather Nezich, ASE, 248.223.8040, hnezich@aseonline.org

Livonia, Mich. —October 8, 2018 — The American Society of Employers (ASE), one of the nation’s oldest and largest employer associations, is pleased to announce the honorees for its annual Michigan HR Executive of the Year for 2018.  Through a nomination process overseen by ASE, candidates are selected in four categories and recognized for their admirable work that distinguishes them in the field of Human Resource Management.  The category winners are:

  • Diane M. Antishin, Vice President, HR Operations, DTE Energy (For-profit Organization – Large Employer)
  • Denise Dorigo Jones, Director, Human Resources, Nemak (For-profit Organization – Small Employer)
  • Elizabeth Wilcox, Associate VP, Human Resources, Kettering University (Non-profit Organization – Large Employer)
  • Michelle Hansel, Vice President, Human Resources, Detroit Regional Chamber (Non-profit Organization – Small Employer)

 

“The caliber of honorees this year is impressive, as always.  They’ve each dedicated themselves to the HR profession and have proven their dedication through their achievements,” stated Mary E. Corrado, ASE President & CEO.

The Michigan HR Executives of the Year for 2018 will receive their awards at ASE’s 15th Annual Summit, which celebrates not only the honorees but the pivotal role of the HR profession in Michigan’s business and non-profit communities. ASE will also celebrate and recognize its members that have been with ASE for 50+ years.

The ASE Annual Summit will be held Thursday, Nov. 8 from 5:00 p.m. to 8:00 p.m. at the Detroit Athletic Club. The event will feature a keynote presentation by Dr. Ken Washington, Vice President, Research and Advanced Engineering and Chief Technology Officer, Ford Motor Company.

ASE’s 2018 Annual Summit is open to both ASE members and non-members. Tickets are $99 per person, $539 for groups of six, and $639 for groups of eight. The evening includes networking, cocktails, small plates, and dessert. To purchase tickets or for registration information, please call 248-223-8006 or visit the ASE website.

About the American Society of Employers (ASE) – a Centennial Organization

The American Society of Employers (ASE) is a not-for-profit trade association providing people-management information and services to Michigan employers. Since 1902, member organizations have relied on ASE to be their single, cost-effective source for HR information and support, helping to grow their bottom line by enhancing the effectiveness of their people. Learn more about ASE at www.aseonline.org.

We’ve arrived!

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By: Sterling Insurance Group

 

News: Sterling Insurance Group opens doors in Detroit Renaissance Center.

We’ve arrived!

Sterling Insurance Group is proud to open its doors in Detroit. Find us in the beautiful Renaissance Center in Tower 100!  This office serves primarily as a Personal Insurance hub, so stop by and see us to get a quote on your Home & Auto Insurance.

Location:

100 Renaissance Center | Suite 1-1108
Detroit, MI
48243

For a limited time, we’re giving away Starbucks gift cards to all walk-ins. Be sure to stop by!

We’re proud to be in the Motor City. Stop by or call today: 313.394.0506

Get in touch with us:

Office Hours
Monday – Friday
7:15 AM – 3:00 PM

 

READ MORE: https://sterlingagency.com/resources/blog/news-sterling-insurance-group-opens-doors-in-gm-renaissance-center/

Financial Times Names 21 CAPTRUST Advisors to Top 401 List

captrust

 

By: CAPTRUST

 

 | Raleigh, NC

Financial Times Names 21 CAPTRUST Advisors to Top 401 List

The Financial Times included 21 CAPTRUST advisors in the publication’s 2018 list of the 401 Top Retirement Advisors. The list recognizes the top financial advisors who specialize in serving defined contribution (DC) retirement plans, such as 401(k) and 403(b) plans.

Financial advisors from across the U.S. applied for consideration, having met a set minimum of requirements. The applicants were then graded on six criteria: DC assets under management, DC plan growth rate, specialization in DC plans, years of experience, advanced industry credentials, and compliance record.

The final FT 401 represent an impressive cohort of elite advisors: the average advisor in this year’s FT 401 has 20 years of experience advising DC plans and advises on $1.26 billion in DC plan assets.

The list includes the following CAPTRUST financial advisors:

Robert C. Auditore (Boston)

Karen Casillas, CFS®, AIF® (Los Angeles)

John Davenport, CFA (New York)

Jean Duffy, ARPC, AIFA® (Des Moines)

Jim Edwards, AIF® (Allentown)

Shaun Eskamani (Raleigh)

Jeb Graham, CPFA®, CEBS®, CIMA® (Tampa)

Errol A. Hau, CTP/CCM (Clarkston)

Todd Jones, CFP®, AIF®, ARPS (Raleigh)

Wat B. Keys, CFP®, CRPS (Raleigh)

Christopher D. Kulick, Jr., CIMA® (Doylestown)

Michael Maresh, AIFA® (Austin)

Patrick K. Marlatt (Raleigh)

John Martin, AIF® (Raleigh)

Paul W. Owen, AIF®, APR (Birmingham)

John A. Pickett, CIMA® (Dallas)

Jim Pierce, CEBS® (Des Moines)

Paul Schaffer, AIF® (Doylestown)

Paul Stibich (Akron)

Scott Wertheim, AIF®, CEBS® (Doylestown)

Travis Whitten, CFP® (Dallas)

To read the article online, please visit ft.com.

About CAPTRUST

CAPTRUST Financial Advisors is an independent investment research and fee-based advisory firm specializing in providing retirement plan and investment advisory services to retirement plan fiduciaries, endowments and foundations, and executives and high-net-worth individuals. Headquartered in Raleigh, North Carolina, the firm represents more than $278 billion in client assets from its offices located across the U.S.

Nov 6-7 Training + Conference: Grab Your Spot!

michigan

By Michigan Wellness Council 

 

grab your spot!

Nov 6-7 Training + Conference
Exploring Pathways to Positive Workplace Culture

sponsorship opportunities

November 6th Pre-Conference Training: 8:30 am to 4:00 pm Workplace Wellness that Works – Training (Sponsored by Marsh And McLennan) by Laura Putnam at 3331 W Big Beaver Rd, #200, Troy, MI 48084 (Details & Registration)

November 7th Conference Presentations: 8:00 am to 4:00pm Exploring Pathways to Positive Workplace Culture at MSU Management Education Center, 811 W. Square Lake Road, Troy, MI 48098 (Details & Registration)

(1) OPENING KEYNOTE Micromoves to build a positive workplace by Chris White, Managing Director, Center for Positive Organizations at University of Michigan

(2) Creating a Culture of Wellbeing: Swimming, Floating or Drowning? by Mary Marzec, PhD, Senior Health Strategy Consultant at RedBrick Health

(3) Case Study: Creating a world-class wellness program as an employee engagement strategy by Shawn Premer, Chief Human Resources Officer at Consumers Credit Union

(4) Cleveland Clinic: What can small business learn from one of the largest employee wellness programs in the world? by David Pauer, Director of Wellness for the Employee Health Plan (EHP) at The Cleveland Clinic

(5) CLOSING KEYNOTE A New Way of Thinking: Wellbeing as the Foundation of Employee Experience by Mindi Cox, Senior Vice President, People & Great Work at O.C. Tanner.

Registration Fee:

$175 -11/6 Training ONLY – Non-Members
$150 – 11/6 Training ONLY – MWC Members
$275 – 11/7 Conference Presentations ONLY – Non-Members
$250 – 11/7 Conference Presentations ONLY – Members
$300 – 2-Day Package – MWC Members
$350 – 2-Day Package – Non-Members

Hotel Options:

The Somerset Inn (call 248-643-7800 and let them know you are with Michigan Wellness Council to get a discounted rate of $129 plus tax) 2601 W Big Beaver Rd, Troy, MI 48084 (distance to conference venue 4.3 miles)

Options on MSU Management Center Website

Hampton Inn 100 Wilshire Dr, Troy, MI 48084 (distance to conference venue 4 miles)

Hilton Garden Inn 200 Wilshire Dr, Troy, MI 48084 (distance to conference venue 4 miles)

Certification: National Association for Business Resources Best and  Brightest Programs is recognized by SHRM to offer SHRM-CP®or SHRM-SCP® professional development credits (PDCs).

SHRM-Recertification-Provider-CP-SCP-Seal-2018_CMYK-e1515684420679.jpg

Register for the Conference – November 6-7, 2018
Conference Sponsorship Opportunities

Want to save on the cost of MWC events? Renew your MWC membership (or become a member) to get discounts.

Are you student? Contact us for student rates.

Enjoy your day!
Contact: Rita Patel, Executive Director