Part XIII: Mandated Notice to All Employees by October 1, 2013 Page 1 Mandated Notice to All Employees by October 1, 2013 Page 2 Employer-Friendly U.S. Supreme Court Opinions Warrant Attention, But No Change in Employer Best Practices You Asked: Can We Set Up Our Payroll System to Automatically Deduct for Meal Periods of Nonexempt Employees? Page 3 Independent Business Requirement for Independent Contractors Page 4 Public Employers: State Agencies Wise to Carefully Draft Settlement Agreements Page 5 Going to Canada, eh? Do You Have Bullies in Your Workplace? Page 6 Survey News Page 7 Economic Perspective
Peggy Hoyt-Hoch, Employment Law Services Employers1 are required to distribute a Notice of Exchange (a.k.a. “Marketplace”) to all employees on or before October 1, 2013. The notice is intended to educate your workforce about the health coverage options that may be available to them beginning January 1, 2014. The exchange open enrollment period for 2014 begins October 1, 2013. The U.S. Department of Labor (DOL) has published a revised, but temporary COBRA continuation coverage election notice. This new notice explains the availability of health insurance exchanges as an option to COBRA coverage. While no effective date for use of this notice has been published, presumably October 1, 2013 is the target date. The DOL has published two different exchange notices that employers may use. One is to be given by employers who sponsor a group insurance plan for some or all employees, and the other is to be given by employers who do not sponsor a group insurance plan. After initial distribution, employers must begin to provide notice to each new hire employee within 14 days of the first day worked.
Employers Who Do Not Offer Group Insurance Coverage The Notice these employers distribute provides basic information about the exchange and states that the employer does not offer coverage. The notice encourages employees to learn more about the plans offered through the state exchange.
Employers Who Do Offer Group Insurance Coverage Employers who sponsor group insurance plans are required to complete certain information on the exchange notice and then distribute it to each employee whether or not that employee is eligible for the coverage. The specific sections to be completed include: • Contact information for the employer plan, • Information on the type of health plan offered, • Who is eligible for coverage, and • Whether the health plan meets the “minimum value.” There is additional information that could be useful to employees, but completion is optional. Employers with fully-insured health plans should receive confirmation from their insurance providers as to whether their applicable plan design meets minimum value. Employers who self-insure plans should request this information from their third-party administrators, plan consultants or actuaries. The IRS offers three optional ways to determine if your plan meets minimum value: (1) Use the Minimum Value Calculator (http://www.cms.gov/CCIIO/Resources/ Regulations-and-Guidance/Downloads/mv-calculator-final-4-11-2013.xlsm); (2) Adopt a safe harbor plan design designated by the IRS as a safe harbor plan; or
1 “Employers” are those defined in the Fair Labor Standards Act (“FLSA”), which provides only narrow exceptions.
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Employer-Friendly U.S. Supreme Court Opinions Warrant Attention, But No Change in Employer Best Practices David Dixon, Northern Regional Office A pair of U.S. Supreme Court opinions published on June 24, 2013, prompted national media coverage based on their potential significance for Title VII harassment and retaliation litigation. Employers should be aware that these were employer-friendly decisions, but that neither decision prompts any particular change in the best practices employers should already be proactively following to prevent workplace harassment and retaliation. In Vance v. Ball State University, the Supreme Court rejected, by a slim 5-4 majority, the Equal Employment
Opportunity Commission’s long-standing and relatively expansive definition of a “supervisor” for determining an employer’s liability and possible defenses against claims of harassment. It held that “an employee is a ‘supervisor’ for purposes of vicarious liability under Title VII [only] if he or she is empowered by the employer to take tangible employment actions against the victim.” When the harasser is not a supervisor, “negligence provides the better framework for evaluating the employer’s liability.” It criticized the EEOC’s definition, which included persons who may
direct an employee’s daily activities, as “a study in ambiguity,” that “would impede the resolution of the [supervisor status] issue before trial,” and contribute to the “danger of juror confusion.” The Court upheld the Seventh Circuit’s previous conclusions that a catering specialist was not a catering assistant’s supervisor and that the employer had acted reasonably in response to complaints during the plaintiff ’s employment, thus affirming rejection of her lawsuit. Justice Ginsberg’s vigorous dissenting opinion, joined by three Continued on next page
Can We Set Up Our Payroll System to Automatically Deduct for Meal Periods of Nonexempt Employees? Tina Harkness, Membership Development The answer is a cautionary yes. Suits alleging improper automatic deductions for meal periods continue to plague employers. Last month, the First Circuit Court of Appeals revived the claim of a class of 4,000 current and former hospital employees alleging improper automatic deductions for meal periods. Manning v. Boston Medical Center Corp. (1st Cir. 2013). The court held that the hospital’s president and CEO could be held individually liable because she exercised operational control over employee staffing, the hospital’s budget, and its compensation practices, but declined to extend individual liability to the senior human resources director because he was not an owner and did not exercise operational control. Many employers set their payroll systems to automatically deduct half-hour or longer meal periods for nonexempt employees each day. While there is nothing illegal or improper about doing this, you need to make sure of two things: 1) that your nonexempt employees are taking at least 30 minutes for their meal period, and 2) that this period is not interrupted by work. The federal Fair Labor Standards Act (FLSA) does not require meal periods. Instead, this is determined by state law. If you provide meal periods, as most employers do, the FLSA requires the period to be at least 30 minutes long and uninterrupted by work for it to be unpaid time for nonexempt employees.
Employers using automatic deductions for meals run into trouble when employees take less than 30 minutes for their meal periods. This is more likely to occur when employees only have 30 minutes for meals. If a meal period is less than 30 minutes that time must be paid and included in the overtime calculation. Employers who automatically deduct also have problems when the employee’s meal period is interrupted by work. Although it only takes a few minutes for the employee to answer their co-worker or supervisor’s question, that is enough of an interruption to make the meal period paid time. Employers should train supervisors and co-workers not to interrupt an employee’s meal period. Employers may also want to insist that nonexempt employees take lunches away from their work areas, so that they are less likely to interrupt their own meal period by answering the phone when it rings or responding to an email. Employers should train nonexempt employees to take a 30-minute, uninterrupted meal period. Employers should also set up an easy way for nonexempt employees who do not take a full 30 minutes or whose lunch is interrupted to cancel the automatic deduction. Employers may wish to have employees sign off confirming the change. Employees who persist in failing to follow their employer’s instructions about taking their full, uninterrupted meal period can be disciplined.
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other justices, invites Congress “to correct the error into which the Court has fallen.” The other case, University of Texas Southwestern Medical Center v. Nassar, also a close 5-4 decision with a vigorous dissent urging Congress to respond, rejected a long-standing EEOC enforcement position. In Nassar, the Supreme Court for the first time specified the causation standard for Title VII retaliation claims. A 1989 Supreme Court decision, followed by the Civil Rights Act of 1991, had clarified that discrimination (as distinct from retaliation) could be established if the protected characteristic was “a motivating factor for any employment practice, even though other factors also motivated the practice.” That “mixed motive” causation standard is lower than so-called “but for” causation, under which an employer can avoid liability if it can prove that it would have taken the same employment action regardless of any discriminatory animus also present. The EEOC opined for decades that the lower standard applied to both Title VII discrimination and retaliation claims, but the Court rejected EEOC’s view and held that the “but for” standard applies to Title VII retaliation claims. The majority observed that the Court’s 2009 decision in Gross v. FBL Financial Services, Inc. concluded that “but for” causation was the standard for age claims under the Age Discrimination in Employment Act, as distinct from Title VII claims, and applied a close textual analysis of Title VII’s various subsections to support its conclusion. Both decisions should have profound impact in Title VII litigation by improving employer chances of winning summary judgment motions, and both were influenced at least partly by practical concerns about the volume of Title VII jury trials. Yet, despite their potential significance for Title VII litigation, neither decision prompts any change for real-time employer decision making and/or best practices. The best strategy for employers to reduce exposure to harassment liability is to continue proactively taking all steps reasonably available to prevent and respond effectively to harassment, including adopting proper policies and supporting them with supervisor and employee training about workplace respect, harassment avoidance, and harassment complaint processes. Likewise, reducing retaliation exposure is best accomplished by ensuring that all supervisors are trained to understand unlawful retaliation and how to base their employment decisions exclusively on legitimate, well-documented, non-retaliatory business reasons.
Independent Business Requirement for Independent Contractors Nick Haynes, Employment Law Services To be classified as an independent contractor, a worker must be both free from direction and control and customarily engaged in an independent business or trade. Most companies can easily identify whether a worker is free from direction and control, but they have more difficulty determining whether the worker is customarily engaged in an independent business or trade, also referred to as the “economic realities” test. As a result, companies may mistakenly classify workers who receive most of their income from one company or do not have multiple clients at the same time as independent contractors. Arizona, Wyoming, and Colorado, as well as many other states, have some derivation of the economic realities test or a requirement that independent contractors have multiple clients. The basic premise is that employees have unemployment insurance available to them; independent contractors do not. If a worker’s income comes from one source or one company and that relationship terminates, the worker will be without the protection of unemployment insurance. Many states take the approach that if a worker is truly an independent contractor, the worker should have many clients and sources of income. In other words, the independent business requirement is designed to protect the workers who receive substantially all their earnings from one company. Arizona is somewhat more lenient than other states on this point. It provides that a worker can be an independent contractor when the services are performed through occasional transactions with a single company. Thus, implying that there are multiple clients, and the independent contractor does not derive all of his income from one source. In Wyoming, the determination is based on whether the worker represents services to the general public as an independent contractor and whether the worker performs work for others or devotes all his time to one company. An independent contractor generally has multiple clients at any given time. Colorado focuses on whether the worker is customarily engaged in an independent business or trade. The current status of the law is that an independent contractor must provide similar services to others at the same time he works for the employer. In very limited circumstances, the worker may have short-term exclusive relationships. In this situation, the worker should have other clients before and after that short-term exclusive relationship, and be actively seeking for other business the entire time. Employers should consider asking whether their independent contractors have other clients. If not, contact an MSEC attorney to determine whether the independent contractor is classified properly.
State Agencies Wise to Carefully Draft Settlement Agreements Lorrie Ray, Membership Development On July 15, 2013, the Tenth Circuit Court of Appeals handed down a decision that no doubt made an attorney representing the Department of Public Safety (DPS) for the State of Oklahoma a bit queasy. The court determined that a settlement agreement, clearly drafted by an attorney, was responsible for the agency waiving its sovereign immunity, and allowed an employee to sue the state agency in federal court alleging violation of state law. Pettigrew v. Oklahoma (W.D. Okla. 2013). In 2009, Officer Pettigrew applied for a promotion to Field Major in the Oklahoma Highway Patrol and was denied in favor of an African-American applicant. Citing race discrimination, he grieved the decision. In the meantime he was placed on administrative leave for leaks to the press in an unrelated sexual-harassment complaint. Pettigrew filed suit in U.S. District Court alleging that the leave was retaliation in violation of Title VII, and making other state law claims. The parties negotiated and signed a settlement agreement, which contained the following language about the correct venue
should either party believe that the terms of the agreement had been violated: In the event that any litigation is commenced by either party to enforce the terms and conditions of the Agreement, the litigation will be brought in the appropriate Oklahoma court having jurisdiction, either state or federal, and the losing party shall pay to the prevailing party all reasonable attorneys’ fees and costs incurred by the prevailing party defending against the claim(s). Pettigrew, believing that the agreement had been violated, filed suit in federal court on January 31, 2012. The state argued that Pettigrew could not pursue the state law claims in federal court because of the protection of sovereign immunity under the Eleventh Amendment. The court disagreed and explained why. First, the Eleventh Amendment ordinarily bars federal-court jurisdiction over private suits by citizens of a state. Second, the Oklahoma DPS is an arm of state government and is protected. (Sovereign
immunity does not extend to what the court refers to as “lesser entities” which includes municipalities.) Third, the federal court, because it has jurisdiction over the Title VII claim, also has the jurisdiction to hear related claims, unless the state can use the defense of sovereign immunity. Here the state could not use that defense, because the court ruled the only logical way to read the settlement agreement was to read it as allowing suit in a court which would have jurisdiction—in this case, federal jurisdiction—and that the language acted as a waiver of sovereign immunity. It is understandable that the attorney drafting the agreement did not intend to waive sovereign immunity, and really meant that a Title VII claim could be pursued in federal court, and that state law claims would not be appropriate for federal court, but unfortunately, that is not what the document appeared to mean to the court. This highlights why the careful drafting of agreements is so important, and why it can be so difficult to convey what is meant in a settlement agreement.
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(3) Obtain certification from an actuary. Further information on each may be found on the Health Care Reform Learning Zone at MSEC.org. Note that employer contributions to health savings accounts (HSAs) and amounts available under health reimbursement arrangements (HRAs) may generally be counted toward minimum value calculation.
Proposed IRS Safe Harbor Design While the IRS offers option (2) above for minimum value, they have yet to finalize these plan design rules. Nonetheless, they have proposed that the following designs may be designated as safe harbors for determining minimum value as long as the plan covers all the benefits in the Minimum Value Calculator. (1) a plan with a $3,500 integrated medical and drug deductible, 80 percent plan cost-sharing, and a $6,000 maximum out-of-pocket limit for employee cost-sharing; (2) a plan with a $4,500 integrated medical and drug deductible, 70 percent plan cost-sharing, a $6,400 maximum
out-of-pocket limit, and a $500 employer contribution to an HSA; or (3) A plan with a $3,500 medical deductible, $0 drug deductible, 60 percent plan medical expense cost-sharing, 75 percent plan drug cost-sharing, a $6,400 maximum out-ofpocket limit, and drug copays of $10/$20/$50 for the first, second and third prescription drug tiers, with 75 percent coinsurance for specialty drugs. Employers should review the model notices on the DOL website at: www.dol.gov/ebsa/pdf/FLSAwithplans.pdf. Complete the employer contact information and as much of the plan information as you can. Then reach out to your provider, thirdparty administrator, or consultant to determine whether your plan meets minimum value, and complete the rest of the form. Finally, set up your distribution plan for all employees to ensure receipt on or before the deadline. MSEC will update our COBRA information before the presumed October 1, 2013, effective date for the new election notice.
Going to Canada, eh? Mark Cicotello, Human Resource Services U.S. census statistics on foreign trade show that the state of Colorado exports more goods to Canada than any other country. If your organization is thinking about doing business with our neighbor to the north, you and your HR team need to know that there are several distinctions between U.S. and Canadian “labour” law. This article summarizes a few of the major areas—recognizing there is a level of granularity that can’t be covered here.
administrative tribunals or, in the case of a unionized workplace, by arbitrators acting under a collective agreement. Pay Equity: Ontario, Quebec, and the federal jurisdiction require “pay equity” or comparable worth pay between males and females in the same or similar jobs. Pay adjustments required to achieve rate equity are limited to 1 percent of total payroll annually.
Government Structure: Canada is composed of a federal jurisdiction and 10 provinces—Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, Prince Edward Island, Quebec, and Saskatchewan, and three territories—Northwest Territories, Nunavut, and Yukon Territory. The federal government of each of the provinces and territories has authority to enact “labour” and employment laws.
Workers’ Compensation: In Canada, private insurers have no function in workers’ compensation. Each province has a fund financed by employers through assessments and administered by a workers’ compensation board. In addition, each board administers rehabilitation services and determines and pays compensation claims.
Termination of Employment: The greatest area of divergence is in the termination of employees. The doctrine of “at-will employment” does not exist in Canada. All Canadian jurisdictions require minimum statutory notice of termination or payment in lieu of notice. Employers are also obligated to provide reasonable notice of termination at common law. Generally, common-law notice exceeds the statutory minimums.
Healthcare: Canadians enjoy a system of universal access to medical and hospital care variously funded by general tax revenues, employer contributions, and individual premiums. Most employers offer extended health care plans, dental plans, other health care benefits, and group life, accidental death and dismemberment (AD&D), and disability insurance to supplement the public health insurance system.
Discrimination: Canadian employers are covered by human rights legislation regardless of the number of employees they have. Discrimination does not give rise to a private cause of action in Canada. Discrimination complaints are determined by
Visas: If you are traveling to Canada for business or sending employees there, a business visa is often required. Have additional questions? Contact MSEC or refer to the FYI Global Human Resources: HR Considerations when Going Global.
Do You Have Bullies in Your Workplace? Donna Treber, Human Resource Services Your initial response will likely be no. That only happens in grade school. But, read on. Workplace bullies are frequently charming, socially skilled, professionally successful, and well-regarded by their superiors. They have refined their bullying skills and hidden them well from their superiors. They are well-liked and productive in their positions. They are motivated to get ahead, have high self-esteem, and a need to achieve. They often possess a high level of political skill as well as leadership qualities. However, their targets tell a very different story. Workplace bullies are destructive and manipulate others into doing work for them while they take all the credit. They also take credit for suggestions given by others. They blame their targets for a project gone bad when it was their idea and their specific instructions to do it a certain way. They make up rules on the fly. They harshly and consistently criticize their victim. Bullies blame and
belittle their subordinates or co-workers in private, but treat them as equals and buddies in group settings. Bullies are smart and very quickly identify those victims that are more likely to respond to their aggressive behaviors. Employees who “need” their jobs and are financially dependent on it, those with lower self-esteem, possibly those with lower levels of education, minorities, and those who have limited skills to seek other opportunities. Darren Treadway, Ph.D. from the University of New York at Buffalo - School of Management, is one author of a study titled Political Skill and the Job Performance of Bullies, available online at: http://mgt.buffalo.edu/faculty/academic/ resources/faculty/darrent/bullyingstudy. This study is enlightening and a must-read for HR professionals. It illustrates management’s tendency to ignore bullying by looking at the case of Rutgers University basketball coach Mike Rice, who was
permitted to continue to punch, kick, and belittle players even after the abuse was reported simply because he was a well-known and winning coach. To avoid bullying in your organization, ensure you have an open door policy where employees can report bullying incidents to their supervisors or to Human Resources without fear of reprisal. Although bullying is not currently expressly prohibited by U.S. law, it needs to be investigated just as you would investigate a harassment complaint or other employee-relations concern. You may also want to review your turnover statistics to determine if you have departments where lower-level subordinates leave frequently. This may be an indication of a bullying situation. Treadway says it is important that “HR Managers demonstrate that changing the workplace culture affects the wellbeing of employees, whether it means turnover, performance or profitability.”
It Pays to Participate in MSEC Surveys! If you participated in the 2013 Arizona, Colorado or Wyoming Benchmark Compensation Survey, you have received a FREE custom analysis comparing your organization’s data to other organizations in your geographic demographic. Percent differences for base pay are displayed for weighted average and 25th, 50th, 75th percentiles. This custom analysis also displays the quartile ranking for each of your reported positions. Your reported Information Technology positions are included in this extract as well.
2013 Call Center Compensation Survey This survey collects salary data for 28 benchmark jobs in the call center industry. The data are sorted by employment size (under 500 employees and 500 or more employees) and by call center size (less than 50, 50-200 and more than 200 employees). In addition to salary data, participants provided 2012 separation and job absence rates for call center employees, and shift differentials. Also included are percentage increases in pay for 2013, projections for 2014, and frequency of pay increases.
2014 Pay Projections Look for the 2014 Pay Increase and Health Insurance Increase Projections on MSEC.org in September. As data are collected, we will keep this site up-todate with the latest numbers. The 2013 Planning Packet containing the 2014 Pay Increase Projections for Arizona, Colorado, and Wyoming will be available in September.
Union Wage Increases Up Union wage increases, collectively bargained through July 22, 2013 was an average 2.0 percent compared with an average 1.7 percent in the comparable period of 2012. Most of the industry groups reported a 2013 year-to-date increase from their average settlement increase in the comparable period in 2012. The exception was the Manufacturing Industry, reporting 2.0 percent versus the 2.2 percent reported last year. The 2013 all industries median wage increase was 2.0 percent, compared to 1.7 percent for 2012. These data are compiled by the Bureau of National Affairs (BNA).
2013 Miscellaneous Benefits and Pay Practices Survey – Arizona, Colorado, and Wyoming MSEC is currently conducting this biennial survey that covers hiring/ employment practices, hours of work, performance appraisals, communication methods/practices, employer sponsored programs, and severance pay among others. If you would like to participate and have not received your questionnaire or online survey access code, please call the Surveys Department. A hard copy can be downloaded from https://www. msec.org/services/surveys/Pages/Survey-Questionnaires.aspx. It is member participation that makes MSEC surveys the number one data source for the region.
2013 Colorado REA Compensation Survey This survey is now available. This survey provides wage and salary information in 22 Colorado Rural Electric Associations for 53 positions. Salary data are displayed by employment size. Also included are compensation costs as percent of operating revenue and total revenue, average entry-level wages for inside and outside positions, and flexible work schedules.
By major industrial groups the average first year wage increases, year-to-date was: First-Year Average Wage Increases (Lump Sums Not Factored) All Industries Manufacturing Non-Manufacturing (w/out construction) Construction
2.0% 2.0% 2.7%
1.7% 2.2% 2.3%
All Industries Manufacturing Non-Manufacturing (w/out construction) Construction
2.5% 3.0% 3.4%
2.1% 3.3% 2.8%
Salary Survey Data: Making Sense of the Numbers September 10, 2013 • 8:30-11:30am NO CHARGE • MSEC Denver Office This free seminar presents the basics of wage and salary data. Topics include questionnaire mechanics, survey methodologies, and what to look for when using the MSEC surveys. This seminar is designed for individuals responsible for completing the MSEC questionnaires and using the survey data, especially those new to the responsibility.
To request copies of the surveys, please contact the MSEC Surveys Department. Copies of these resources are available to authorized personnel of MSEC members. Call 800.884.1328, email email@example.com, or go online to MSEC.org.
First-Year Average Wage Increases (Lump Sums Factored)
Unemployment Rate DENVER-AURORABROOMFIELD MSA
Latest Date Latest Figure / Year Ago
5/13 EN 6.6% / 7.8%
5/13 DN 6.8% / 7.9%
WEEKLY HOURS (MFG.) Latest Date Latest Figure / Year Ago
5/13 N 41.2 / 38.8
HOURLY EARNINGS (MFG.) Latest Date Latest Figure / Year Ago
5/13 N 27.30 / 27.50
Figures reported for Denver, Colorado and U.S. are from the Current Population Survey [Federal Method]
5/13 EN 6.2% / 7.1%
5/13 DN 7.4% / 8.2%
5/13 DN 4..2% / 5.3%
6/13 A 7.6% / 8.2%
5/13 N 38.8 / 37.6
5/13 N 41.1 / 42.0
5/13 N 41.5 / 42.0
5/13 N 36.0 / 40.5
6/13 AP 41.8 / 41.6
5/13 N 24.33 / 25.21
5/13 N 19.04 / 18.18
5/13 N 18.64 / 17.94
5/13 N 21.88 / 22.26
6/13 AP 19.29 / 19.08
(CPI) Consumer Price Index DENVER, CO
1982-84 = 100
DEC. 2001 = 100
1982-84 = 100
Latest Date Latest Figure / Year Ago % Change
Jul-Dec 2012 N 216.8 / 212.0 +2.3%
Jul-Dec 2012 N 123.9 / 122.4 +1.2%
6/13 A 229.3 / 225.4 +1.8%
CPI-U* All Urban Consumers Latest Date Latest Figure / Year Ago % Change
Jul-Dec 2012 N 226.2 / 221.5 +2.1%
Jul-Dec 2012 N 124.3 / 122.2 +1.7%
6/13 A 232.9 / 228.9 +1.8%
CPI-W* Revised CPI for Urban Wage Earners & Clerical Workers
(ECI) Employment Cost Index WAGES & SALARIES
12 Months Ended
12 Months Ended
1.9% 2.1% 1.8% 1.8% 1.0%
1.9% 2.0% 1.8% 1.8% 1.8%
Private Industry Workers Manufacturing Service-providing Industries** Mountain Region*** State/Local Government Workers
NOTE: Denver-Aurora MSA includes 10 counties: Denver, Arapahoe, Adams, Jefferson, Douglas, Broomfield, Elbert, Park, Clear Creek, and Gilpin. * CPI data for Wyoming is not available. ** Includes the following industries: wholesale trade; retail trade; transportation and warehousing; utilities; information; finance and insurance; real estate, rental and leasing; professional; scientific and technical services; management of companies and enterprises; administrative support; waste management and remediation services; education services; health care and social assistance; arts, entertainment, and recreation; accommodation and food services; and other services, except public administration.
DEFINITIONS/SOURCES (1) P = N = A = D = E = R = C =
Bureau of Labor Statistics, U.S. Dept. of Labor Preliminary Data Not Seasonally Adjusted Seasonally Adjusted Reflects revised population controls and model reestimation Reflects inputs, reestimations, and new statewide controls Revised Corrected
For more information: www.bls.gov *** Includes the states of Arizona, Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming.
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