Tips for Drafting Hospital Policies and Handbooks
This Briefing is brought to you by AHLA’s Labor and Employment Practice Group.
- June 16, 2025
- Thomas J. Wiencek , Roetzel & Andress
In Stericycle, Inc., 372 NLRB No. 113 (2023), the National Labor Relations Board (NLRB) established a new/modified standard for analyzing facially neutral rules in policies and handbooks. Under Stericycle, the General Counsel, who oversees litigating an unfair labor practice charge on behalf of the NLRB, must “prove that a challenged rule has a reasonable tendency to chill employees from exercising their Section 7 rights.”Section 7 of the National Labor Relations Act (the Act), among other things, provides employees with the right to engage in concerted activities for their mutual aid and protection.
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