CWA Local 1081
60 Park Place, Suite 501
Newark, NJ, 07102
Office (973) 623-1081
Fax: (732) 988-1081

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Newark Teachers Union

New Jersey Citizen Action Oil Group

June 13, 2011


Anibal Ramos, Director

Essex County Department of Citizen Services

18 Rector Street, Floor 9

Newark, NJ, 07102


Re: Step III Class Action Contractual Grievance

       Unacceptable Error Rate Memo

        Article I. Purpose

       Article VII. Discipline

       Article XXV: Non-Discrimination

       Article XXX. Work Distribution and Practices


Dear Mr. Ramos:


CWA Local 1081 submits this Step III Class Action Contractual Grievance on behalf of our applicable Family Service Workers assigned to the Westside office to protest the issuance by ASFS Carol Perkins of her May 11, 2011 memoranda to certain of our Family Service Worker members entitled "Unacceptable Error Rate". Ms. Perkins' attached Step I Class Action Contractual Grievance denial response of May 13, 2011, and its renewed threats of discipline, is unacceptable to our adversely affected members and CWA Local 1081, as is Director Yvonne Davis' attached Step II Class Action Contractual Grievance denunciation rejoinder of June 3, 2011:


  1. Ms. Perkins' assertion that "Redistricting is being looked into, but the districts are not that much out of alignment to cause workers to turn in 6 cases of their own choosing riddled with errors" is inadvertently supportive of our Union's position. Workers being required to submit "raw" cases for DCU scrutiny without their Family Service Supervisor's prior review renders the existence of errors utterly understandable.
  2. Our Union inquiries of you the following:

a)      How many of the Westside office's FSW's cases are submitted without any need for corrective action compared to those that do?

b)      How many of the cases allegedly "riddled of errors" are of a complex nature thus rendering the existence of comparatively more errors than simpler cases explicable?

c)      Have the FSS's historically "trained" their FSW charges when case errors have been cited or have they merely returned the cases with the directive they are completed correctly?


Our Union asserts anew that we seriously share Ms. Perkins', and Ms. Davis', concerns about the current WFNJ/TANF and Food Stamp program error rate within the Westside office as determined by pre-audits conducted by the Quality Control Unit. We realize that, in addition to the resultant delay in services to our agency's clients, federal and/or state funding may well be at risk were the error rate not significantly improved.


However, CWA Local 1081 has previously respectively discussed with Ms. Perkins and with Ms. Davis our concern that the most recent redistricting of her office (prior to her arrival) resulted in extremely inequitably distributed FSW caseloads. Unless these inequities are immediately addressed, and rectified, Ms. Perkins threatening certain of our FSW members that "if an unacceptable error rate is repeated possible disciplinary action for poor job performance may occur" is unfair and unacceptable.


As per the above cited Article XXX. Work Distribution and Practices of CWA Local 1081's contract with the County of Essex, "The County Welfare Division will continue its efforts to standardize caseloads".


The resolution to this grievance CWA Local 1081 respectfully re-reiterates consists of the County immediately assessing the present disproportional caseloads and correcting them before any further issuance of threats, or actual implementation, of discipline.


We seek a hearing in this regard.





David H. Weiner, President

CWA Local 1081