U.S. Department of Labor
Office of Labor-Management Standards
Cleveland Office
1240 East 9th Street, Suite 831
Cleveland, OH 44199
(216) 357-5455 Fax: (216) 357-5425
June 24, 2015
Ms. Danielle Murphy, President
Ohio Nurses Employee Association Union
4000 East Main Street
Columbus, OH 43212
Case Number: 350-6003959()
LM Number: 521603
Dear Ms. Murphy:
This office has recently completed an audit of Ohio Nurses Employee Association Union under the Compliance Audit Program (CAP) to determine your organization’s compliance with the provisions of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA). As discussed during the exit interview with you, Vice-President Anne Barrett and Secretary Molly Ackley on June 11, 2015, the following problems were disclosed during the CAP. The matters listed below are not an exhaustive list of all possible problem areas since the audit conducted was limited in scope.
Recordkeeping Violations
Title II of the LMRDA establishes certain reporting and recordkeeping requirements. Section 206 requires, among other things, that labor organizations maintain adequate records for at least five years by which each receipt and disbursement of funds, as well as all account balances, can be verified, explained, and clarified. As a general rule, labor organizations must maintain all records used or received in the course of union business.
For disbursements, this includes not only original bills, invoices, receipts, vouchers, and applicable resolutions, but also documentation showing the nature of the union business requiring the disbursement, the goods or services received, and the identity of the recipient(s) of the goods or services. In most instances, this documentation requirement can be satisfied with a sufficiently descriptive expense receipt or invoice. If an expense receipt is not sufficiently descriptive, a union officer or employee should write a note on it providing the additional information. For money it receives, the labor organization must keep at least one record showing the date, amount, purpose, and source of that money. The labor organization must also retain bank records for all accounts.
The audit of Ohio Nurses Employee Association Union records for fiscal year ending
April 30, 2015 revealed the following recordkeeping violations:
General Expenses
Ohio Nurses Employee Association Union failed to maintain a receipt for pizza purchased during a union lunch meeting in September 2013.
As noted above, labor organizations must retain original receipts, bills, and vouchers for all disbursements. The president and treasurer (or corresponding principal officers) of your union, who are required to sign your union’s LM report, are responsible for properly maintaining union records.
Based on your assurance that Ohio Nurses Employee Association Union will retain adequate documentation in the future, OLMS will take no further enforcement action at this time regarding the above violations.
Other Violation
Inadequate Bonding
Ohio Nurses Employee Association Union officers and employees are not currently bonded, but they must be bonded for at least $1,745.72. Ohio Nurses Employee Association Union should obtain adequate bonding coverage for its officers and employees immediately. During the exit interview, I provided the bonding requirements of the LMRDA. Please provide proof of bonding coverage to this office as soon as possible, but not later than July 11, 2015.
Other Issue
Bank Account Signatories
During the audit, Ohio Nurses Employee Association Union officers advised that they are not signatories on the bank account. The former treasurer, who resigned the office in March 2015 and a former president, who is no longer employed with the company are the signatories. The current officers have been unable to update the signatories due to the account being set up incorrectly approximately 20 years ago. During the exit interview, I mentioned a couple of options for correcting the signatory issue and I advised that current officers remedy this situation immediately. Please provide proof that the situation has been resolved as soon as possible, but not later than July 11, 2015.
I want to extend my personal appreciation to Ohio Nurses Employee Association Union for the cooperation and courtesy extended during this compliance audit. I strongly recommend that you make sure this letter and the compliance assistance materials provided to you are passed on to future officers.
If we can provide any additional assistance, please do not hesitate to call.
Sincerely,
Senior Investigator
cc: Ms. Anne Barrett, Vice-President
Ms. Molly Ackley, Secretary