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Compliance Corner: Corrective Action Planning Guide

Each month, we highlight one of the many resources exclusively available to you as a member of Cascade.

This month, we're featuring our Corrective Action Planning Guide. This guide helps supervisors and human resources apply corrective action in a clear, fair, and consistent way. It walks through determining the appropriate level of action, key questions to ask early in the process, documentation requirements, how to conduct effective performance conversations, and more. The tools in this guide help employers reduce risk, promote consistency, and support long-term employee success.

In Case You Missed It: Key Action Items for January 1, 2026

Cascade Compliance Team
compliance@cascadeemployers.com

OREGON

Here’s what Oregon employers need to be ready for on January 1, 2026:

Sick Leave for Blood Donation (SB 1108)

  • Employees can now use Oregon Sick leave for voluntary blood donation through an accredited program such as the American Red Cross or American Association of Blood Banks as a new qualifying reason.
  • Update your sick/PTO policies and procedures accordingly.
  • Train supervisors, managers, and HR on this new eligibility reason.

Payroll Deduction Transparency (SB 906)

  • Review and customize BOLI’s model payroll notice template.
  • Provide the required written payroll notice at hire and update it annually by January 1.
  • Make sure to include the required disclosures such as pay periods, pay rates, deductions, benefit contributions, payroll codes, and any wage allowances.
  • Make the information easily accessible, such as by posting it in a central location, sharing an electronic file, providing a website link, or sending it by email.

Workplace Violence Protection for Healthcare Workers (SB 537)

(Applies to hospitals, home health agencies, and home hospice programs)

New Program Requirements

  • Consult with your workplace safety committee and incorporate updated risk-mitigation measures into your program.
  • Expand your program to address all forms of workplace violence, not just physical assault.
  • Conduct regular risk assessments, track incidents, and complete root-cause analyses after events.
  • Provide annual prevention and response training to employees and any onsite contracted security staff.

New Policies & Procedures

  • Adopt updated written policies for investigating and responding to workplace violence incidents.
  • Ensure policies address employee identification, post-incident interviews, medical and trauma-informed support, and follow-up steps.
  • Clearly define reporting, documentation, and investigative procedures to ensure accountability and compliance.

Training Requirements

  • Follow new training timelines:
    • Temporary employees must complete training within 14 days of hire.
    • All other employees must complete within 90 days of hire.
  • Conduct an annual review of training effectiveness with your safety committee.
  • Ensure training includes:
    • Definitions and types of workplace violence
    • De-escalation techniques
    • Emergency response procedures
    • Reporting and documentation expectations

WASHINGTON

Here’s what Washington employers need to be ready for on January 1, 2026:

Domestic Violence Leave Act Expansion (SB 5101)

  • Leave now covers victims of hate crimes or bias incidents and their family members.
  • Update Domestic Violence Leave Act policies and procedures to include the expanded reason.
  • Train supervisors, managers, and HR on new protections.

WA PFML Amendments (HB 1213)

 New Employee Job Protection

  • Update policies and procedures to reflect that employees now qualify for PFML job protection after 180 days of employment (previously 12 months).
  • Maintain the requirement that employees must still meet 820 hours worked to qualify for PFML benefits.
  • Update leave policies and procedures to reflect that employees may now take PFML leave in four consecutive-hour increments (previously eight).
  • Train supervisors, managers, and HR on the expanded job protection rules.
  • Notify employees of the updated eligibility requirements.

New Employer Size Threshold for Job Protection

  • Make sure your PFML policy reflects updated job protection rules based on employer size:
    • Jan 1, 2026 – Dec. 31, 2026: Applies to employers with 25+ employees
    • Jan 1, 2027 – Dec. 31, 2027: Applies to employers with 15+ employees
    • Jan 1, 2028 and onward: Applies to employers with 8+ employees

WA PFML Premium Increase

  • WA PFML premium rate increases to 1.13% of each employee’s gross wages (excluding tips).  Employers will pay 28.57% of the total premium, and employees will pay 71.43%.
  • Update payroll systems accordingly and apply the new rate to all wages paid on or after Jan. 1, 2026.
  • Notify employees of the updated withholding rate.
  • Confirm premium calculations are accurate across all pay groups.

Washington Minimum Wage Increase

  • Washington state minimum wage increases to $17.13 per hour ($0.47 increase from 2025)
  • City Specific Increases:
    • Bellingham: $19.13
    • Burien: $21.63 for employers with 500+ FTEs in King County; $20.63 or employers with 21-499 FTEs in King County.
    • Everett: $20.77 for employers with 500+ employees; $18.77 employers with 15-499 employees or more than $2 million in annual gross revenue in Everett
    • Renton: $21.57 for employers with 500+ employees worldwide; $20.57 for employers with 15–500 employees worldwide or more than $2 million annual gross revenue in Renton
    • Seattle: $21.30
    • SeaTac: $20.74 for Hospitality and Transportation workers.
    • Tukwila: $21.65
    • Unincorporated King County: $20.82 for employers with 500+ employees worldwide; $19.82 for employers with 16-499 employees or at least $2 million in gross annual revenue.
  • Audit minimum wage positions to ensure compliance with the new state and local minimum wage rates (if applicable).
  • Ensure all required minimum wage posters are updated for 2026.

Washington Exempt Salary Threshold Increase

  • Washington’s exempt salary threshold will be 2.25 times the minimum wage, requiring a minimum weekly salary of $1,541.70 ($80,168.40 annually).
  • Review all exempt employee salaries to ensure they meet the new minimum threshold.
  • Reclassify roles as needed or increase salaries to maintain exempt status.
  • Update offer letters, job descriptions, and internal compensation structures for compliance.

Expanded Isolated Worker Harassment Prevention Requirements (HB 1524)

(Janitors, Security Guards, Hotel Housekeepers, Room Staff)

New Isolated Employee Definition

  • The law now applies to janitors, security guards, hotel/motel housekeepers, and room service staff who:
    • Work in areas where no coworker/supervisor can immediately respond without being summoned, or
    • Spend 50% or more of work hours alone.
  • If you are an employer in this industry, audit positions to see if they meet the definition of isolated employee.

Verify Panic Button Requirements

  • Provide panic buttons at no cost to applicable employees that are:
    • Designed to be carried by the employee;
    • Activatable by a single simple action without delay;
    • Capable of sending an effective signal under the work conditions; and
    • Able to permit identification of the employee’s location and summon immediate on-scene assistance.

Training and Record Keeping Requirements

  • Train isolated employees on panic button use.
  • Train supervisors and managers on their duty to respond to panic button alerts.
  • Continue required sexual harassment training.

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New Proposed Rules for Paid Leave Oregon

Cascade Compliance Team
compliance@cascadeemployers.com

Paid Leave Oregon has proposed new administrative rules that will clarify the amount of leave available for pre-placement leave, repeal the job protection section of the administrative rules, and change employee notification requirements for intermittent leave.

The proposed rules regarding pre-placement leave limit the amount of PLO available for pre-placement leave to 12 weeks per child, regardless of whether a new benefit year begins during the pre-placement process.

PLO is also proposing to remove rules related to job protection. Beginning January 1, 2026, rulemaking authority of job protections, retaliation and discrimination related to PLO is assigned to BOLI. This means that BOLI will be responsible for proposing rules relating to job protection. Currently, no proposed rules relating to PLO job protection have been published.

Additionally, PLO has proposed to remove the employee notice requirement for intermittent leave. This rule required employees to give employers notice of intermittent absences within 24 hours of each workday or earlier if known. As the Paid Leave Oregon statute does not address notice for intermittent leave, PLO rulemaking does not have the authority to define intermittent leave notice requirements. Such notice requirements would require a legislative change to the statute. Although the proposed rule removes the 24-hour notice requirement, it is likely that employers can still enforce their normal call-in policies as long as they are consistently applied with all other reasons for absences.

PLO is accepting written public comment on the proposed rule changes through December 5, 2025. Cascade will continue to monitor Paid Leave Oregon rulemaking and provide updates on any changes. If you have any questions, please do not hesitate to reach out to us.

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Hot Compliance Question

Cascade Compliance Team
compliance@cascadeemployers.com

Question: Are employers required to provide holiday pay to employees taking leave under Paid Leave Oregon (PLO)?

Answer:

PLO rules do not specifically address holiday pay. However, if an employee is taking continuous leave (full weeks), they receive a full weekly PLO benefit, which already covers the holiday. In this scenario, employers generally are not required to provide holiday pay because the employee is receiving PLO benefits for that day. Employers may choose to offer holiday pay to “top up” the difference between the PLO benefit and the employee’s regular holiday pay, but it is not required.

If an employee is taking intermittent leave, they do not receive PLO benefits for the holiday unless the holiday falls on a day they normally would have taken PLO leave. For example, if the holiday is Thursday and the employee only takes PLO on Wednesday, they would receive PLO for Wednesday only. In these situations, the best practice is to provide holiday pay, because the employee is not receiving PLO wage replacement for the holiday.

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Five Things You May Not Know About Withers Lumber

By Sheryl Kelsh, Membership Development Manager
skelsh@cascadeemployers.com

When a company has been part of Oregon’s business landscape for nearly a century, it’s safe to say they’ve built more than just homes; they’ve built trust. Withers Lumber has been serving the Willamette Valley since 1928, helping contractors, homeowners, and DIYers bring their visions to life. From its roots in Brooks to its yards in Silverton and Molalla, Withers blends small-town service with professional expertise that stands the test of time.

Here are five things you may not know about this Oregon original:

  1. A Legacy That Began Nearly 100 Years Ago

    Withers Lumber started as a small local yard in 1928; long before the age of power tools and prefab everything. Nearly a century later, it remains family-owned and community-minded, providing high-quality lumber and building materials across the region. Their longevity speaks volumes: when Oregon builders think reliability, they think Withers.

  2. Three Yards, One Purpose

    Withers operates multiple locations — in Brooks/Salem, Silverton, and Molalla — but their mission is consistent across all yards: to provide quality materials and expert service for every customer, big or small. Whether you’re managing a major build or repairing a porch, there’s a Withers location nearby ready to help.

  3. Your Partner in Every Project

    Withers caters to both professional contractors and weekend DIYers. Their team knows the difference between framing a dream home and fixing a squeaky floor, and they’re happy to offer guidance on both. They even share handy how-to tips and project advice through their online articles and videos, making building approachable for everyone.

  4. Deep Community Roots

    A proud member of organizations like the Home Builders Association of Marion and Polk Counties and the Strategic Economic Development Corporation, Withers is deeply embedded in the community. Their partnerships — including Cascade Employers Association — show how dedicated they are to supporting Oregon’s workforce, economy, and local growth.

  5. Modern Tools for a Timeless Trade

    Don’t let their long history fool you; Withers embraces the digital age. Their website features online resources, project galleries, and product insights, while their social media presence keeps them connected with customers and local builders alike. Tradition and innovation? Withers proves you can have both.

Building Oregon, One Project at a Time

From decking and siding to hardware and custom orders, Withers Lumber has supplied generations of Oregon builders with the quality and service they deserve. As they approach their 100th anniversary, their story is a reminder that great craftsmanship, and great customer care, never go out of style.

Visit witherslumber.com to learn more or stop by one of their yards to see why Withers remains a cornerstone of Oregon construction.

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