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Monthly Archives

October 2008

DOL WEBSITE PROVIDES HELP TO EMPLOYERS IN DETERMINING NOTICE, REPORTING, AND RECORDKEEPING REQUIREMENTS

By Employment Resources

Myriad federal laws apply to employment matters, and sometimes a company needs a legal adviser simply to determine whether it is subject to a particular rule or requirement. Now, the government is offering some assistance in taking this initial step toward compliance. The U.S. Department of Labor has launched a Web site, the FirstStep Employment Law Advisor, to help employers determine which major federal employment laws administered by the DOL apply to them.

To use the service, you answer a series of questions, including the nature of your business, number of employees, whether you employ any disabled or foreign workers, whether you have any union contracts, whether you offer retirement and health plans, whether you have federal contracts, and your location. The information the site generates will depend on which of its three features you have decided to use.

  • FirstStep Employment Law Overview Advisor will provide you with a summary of the basic requirements of each law determined to apply to your business, together with related recordkeeping, reporting and notice requirements.
  • FirstStep Recordkeeping, Reporting and Notices Advisor will give detailed explanations of these requirements for each applicable law.
  • FirstStep Poster Advisor will provide links to legally required posters for the workplace, together with information on the laws establishing these poster requirements.

If applicable, the information provided will include links to published or online compliance assistance materials (such as guides and fact sheets), model notices required for employees (such as under COBRA), and forms for required filings (such as Form 5500). Contact information for departments within the DOL and other federal and state agencies are also provided.

If an employer already knows what federal employment laws apply, the service can be used to access basic compliance information on recordkeeping, reporting, and poster requirements.

As noted above, this service covers major federal employment laws administered by the DOL. It does not cover all laws administered by the DOL, nor does it cover federal laws administered by other agencies, or state or local laws (but links are provided to some of these outside sources). Though the site focuses only on the major DOL-administered federal laws, it can be a good “first step” to legal compliance with federal employment laws.

Access FirstStep at http://www.dol.gov/elaws/FirstStep/. The service is free.

IRS ANSWERS QUESTIONS ON A WIDE RANGE OF HSA ISSUES

By Employment Resources

The Internal Revenue Service has issued a set of frequently asked questions, with answers, on health savings accounts (HSAs). The 42 FAQs included in Notice 2008-59 cover a wide range of topics, including who is eligible for an HSA, and issues related to high deductible health plans (HDHPs), HSA contributions and HSA distributions. This article summarizes some of the clarifications found in Notice 2008-59.

ELIGIBLE INDIVIDUALS

If an employer pays for or reimburses all or a part of an individual’s health expenses below the HDHP deductible (other than expenses for preventive care or other disregarded coverage), that individual will not be eligible to contribute to an HSA.

An individual who is eligible for, but not enrolled in, Medicare Part D, is eligible for an HSA, but once that individual has enrolled in Medicare Part D, he or she ceases to be HSA-eligible.

An individual can be covered under a health plan in addition to the HDHP, so long as that plan’s deductible is at least the statutory minimum deductible. The example given is of an individual with an HDHP with a lifetime benefit maximum of $1 million, who also is covered under a second health plan with a $1 million deductible and a $2 million lifetime benefit maximum.

Individuals who receive free or reduced-price health care from an employer’s onsite clinic can be HSA-eligible, so long as the clinic does not provide “significant benefits in the nature of medical care.” In an example, an onsite clinic that provided physicals and immunizations, allergy injections, nonprescription pain relievers and treatment for work accidents was not considered to provide significant benefits. In contrast, a hospital that provided free medical care to uninsured employees, and that waived deductibles and copayments for insured employees, was considered to provide significant benefits, and its employees would not be HSA-eligible.

HIGH DEDUCTIBLE HEALTH PLANS

To determine when an individual who switches from family HDHP to self-only HDHP coverage satisfies the self-only deductible, the plan may use any reasonable method to allocate the covered expenses incurred during the period of family coverage. Examples given of reasonable methods include considering only those expenses incurred by the individual and not those incurred by other family members, or allocating expenses on a per-capita basis according to the number of persons who had been covered under the family HDHP. Also, if the family deductible had been satisfied, the plan may treat the self-only deductible as satisfied.

If a plan imposes a separate or higher deductible for specific benefits — such as for substance abuse — amounts paid toward satisfying that deductible are not treated as out-of-pocket expenses for purposes of satisfying the HDHP minimum annual deductible, so long as significant other benefits remain available under the plan in addition to the benefits that are subject to the separate deductible.

HSA CONTRIBUTIONS

If two spouses are eligible for HSA coverage and one spouse has self-only HDHP coverage and the other spouse has family HDHP coverage, the maximum annual HSA contribution for the married couple is the statutory maximum for family coverage. The same applies if each spouse has family HDHP coverage that does not cover the other spouse. The spouses need to divide the contribution limit by agreement.

An individual who ceases to be eligible to make HSA contributions during the year may still make contributions with respect to the months of the year when he or she was eligible, up to the time for filing his or her tax return.

Employer HSA contributions, including salary reduction contributions, may be allocated to the prior year if made between January 1 and the date for filing returns.

If an employer mistakenly makes HSA contributions to the account of an employee who was never an eligible individual, the HSA is considered to have never existed and the employer may correct the error. If amounts are not recovered by the end of the taxable year, they must be included as gross income on the employee’s W-2 for the year in which the contributions were made.

HSA DISTRIBUTIONS

An HSA may be administered through a debit card that is restricted to health care items, so long as HSA funds are also readily available through other means.

An HSA account beneficiary can authorize someone else to withdraw funds from the HSA.

Medicare Part D premiums are qualified medical expenses for account beneficiaries who have attained age 65. If the account beneficiary has not attained age 65, Medicare premiums for an age 65 or older spouse are not qualified medical expenses.

These are just a sampling of the FAQs from the array of guidance provided under Notice 2008-59. For further information on the notice and which aspects of it might be most relevant to your company and your health care plan, consult with one of our benefits professionals.

IS YOUR BUSINESS INSURED AGAINST DISASTER?

By Risk Management Bulletin

In the aftermath of Hurricanes Ivan and Ike — or this summer’s Midwest flooding or California wildfires — thousands of small-business owners are being hit with the bills for salvaging their building or the business itself, because they didn’t carry enough (or the right type of) coverage. Insurance is always a gamble.

For example, a number of communities flooded this summer when the Mississippi spilled over its banks were considered far enough from the river to be safe; which meant that some businesses owners chose not to buy Flood insurance. However, no matter where you’re located, if a small stream near your business swells up after an unusually long period of rain and water pours in through the windows or door, coverage through the federal National Flood Insurance Program will pick up the tab. For more information, visit the program’s Web site, www.Floodsmart.gov.

Similarly, a standard policy probably won’t cover earthquake damage. California businesses can buy insurance through the state-run California Earthquake Authority at www.Earthquakeauthority.com. However, other states are highly vulnerable to quakes; the largest temblor in U.S. history, centered on New Madrid, Missouri in 1812, caused damage in half a dozen states and reshaped a section of the Mississippi River.

In the aftermath of September 11, insurance companies generally require businesses to purchase separate Terrorism policies. You don’t need to be in a high-profile target area such as New York City to consider this coverage. If you’re close to a federal courthouse or administrative building, it might be a good idea.

Many businesses buy Property insurance to protect themselves against losses from such perils as wind, rain, and hail. They’d be better off with a Business Owners Policy (BOP), which includes Property coverage, together with Business Interruption insurance. This invaluable coverage will pick up the tab for your company’s operating expenses and lost profit if the business is shut down for an extended period. That can include salaries and employee benefits, rent and line-of-credit payments. It doesn’t have to be a natural disaster that shuts down the business; even losses stemming from a power outage can be covered.

Some small companies should carry special policies because of the kind of business they’re in. For example, a heavily damaged bed and breakfast that would need to restore its quaint ambience by purchasing antiques would probably need additional “guaranteed replacement” coverage. For more information on business insurance, check out the Insurance Information Institute Web site, www.iii.org. To help make sure your business is protected against disaster, feel free to contact our risk management specialists.

TEN STEPS FOR SAFER DRIVING AT WORK

By Risk Management Bulletin

Believe it or not, nearly half of workplace deaths occur in transportation-related mishaps. Financial losses come to an estimated $60 billion a year in direct accident costs and lost productivity. The loss of life is, of course, beyond measure. According to OSHA and two partner organizations, the National Highway Traffic Safety Administration (NHTSA) and the Network of Employers for Traffic Safety (NETS), businesses could avoid much of this carnage by following a 10-point pathway to workplace driver safety:

1. Management Involvement. Workplace road safety starts at the top. The program needs unequivocal management support in both policy-setting and allocating resources. But make sure that workers are involved in the decision-making process.

2. Written Policies/Procedures. Implement and enforce a strict, no illegal drugs or alcohol policy during duty hours (which includes all breaks and on-call periods). Set a policy on personal seat-belt use, distracted driving (including use of cell phones while driving), and use of personal vehicles for work.

3. Driver agreements. Have a written contract with each of your drivers which states that they understand and will follow all relevant policies and laws. With this document in hand, no one can later say, “They didn’t tell me that.”

4. Driver record checks. Driving records are public information, and it’s easy to get each prospective driver’s record of motor vehicle convictions and accidents. Screen out those with poor records or certain serious violations (such as reckless driving) before hire; and then institute a point system on those you do employ. DS Waters, a drinking water distributor, uses such a system with its 3,000 drivers, working in 40 states. Point totals are checked at 6, 12, and 36 months after hire. Drivers who come up short are taken off the road.

5. Reporting Policy. Make it clear that even a minor fender-bender must be reported to a supervisor immediately. However, looking at accident reports to find bad driving patterns isn’t enough: Scrutinize your drivers’ total behavior, even using in-cab video to study it. People take calculated risks and don’t have accidents. Accidents are poor indicators-because most people get away with risky behavior.

6. The vehicle element. Road safety has three components: The driver, driving conditions, and the vehicle itself. Purchasing vehicles with “best-in-class” DOT safety ratings and then implement the makers’ preventive maintenance schedule. Supplement this with a complete mechanical inspection at least annually, and keep all maintenance records on file. Insist that personal vehicles used for business be carefully maintained.

7. Discipline. Create a structured program of disciplinary actions based on a pattern of violations or incidents, with clearly stated penalties. Some companies use a point system for this.

8. Rewards. The other side of the disciplinary coin is to reward safe driving by building driving safety into the overall job performance evaluation, with rewards or incentives.

9. Compliance. Be sure that all drivers know the law, as spelled out by various agencies, including NHTSA, the Federal Motor Carrier Safety Administration, which regulates commercial trucking, the DOT, and other agencies.

10. Training. Because it’s a skill so commonly used, most people think they already know how to drive safely. A solid defensive driving training program, supplemented by constant reminders, can show how much they have yet to learn.

OFFICE SAFETY AND SECURITY: WHAT WORKERS NEED TO KNOW AND DO

By Risk Management Bulletin

Although offices are usually thought of as safe and serene, in fact they’re rife with risks, both inside and outside the building. The Protection One security company recommends taking these safety precautions:

  • Parking Lot Security/Lighting. Implement a “buddy system” to ferry workers to and from their cars. Limit parking lot access to controlled points and have the lots as well lit as possible. In fact, light is such a deterrent to crime that it’s wise to keep your entire facility lit, inside and out, during non-business hours.
  • Entrance Area Safety. Make sure that reception areas are always manned, all visitors registered (even if they wear the uniform of contract cleaning or other service personnel), and all doors, windows, and locks checked frequently for proper operation. Use photo ID systems, with entry code systems checked often. Never let employees prop open a door with a chair so that it doesn’t lock behind them outside on a break.
  • Suspicious Activity. Urge employees to report any suspicious persons or activity around the building. Never allow suspicious packages to be opened. Instead, report them to the authorities for proper search and disposal.
  • Information Safety. Unfortunately, it’s increasingly easy for computer “hackers” or disgruntled employees to steal your organization’s vital business information. To guard against this threat, use the latest security software for your entire system, frequently updated, and make sure that this information is backed up on a regular basis. Shred paper documents with critical information as soon as they’re no longer needed.
  • Equipment Security. Keep an inventory of all your critical equipment, hardware, and software. This is especially important as electronic devices keep shrinking in size, making them easier to conceal and remove. Having an inventory (many experts suggest taking photos of important items) will also make it easier for your insurance carrier to process any claim if anything “goes missing.”
  • Employee Valuables. Provide secure places, such as lockable drawers and closets, for employee property and encourage their use. Valuables, especially any item that reveals personal information, should be locked away during company gatherings or break.
  • Safety Team: Set up a group that includes both managers and employees that meets regularly with a set agenda.

For guidelines on keeping your office safe, please contact our risk management professionals.

TRAFFIC ACCIDENTS CONTRIBUTE TO EMPLOYEE ACCIDENTAL DEATH AND DISABILITY

By Business Protection Bulletin

The International Association of Industrial Accident Boards and Commissions (IAIABC) discovered that not only are highway vehicles the biggest risk of serious injury to employees, but they are also associated with some of the most costly workers compensation claims.

The researchers analyzed injury data from the National Council on Compensation Insurance (NCCI) and the National Institute on Occupational Safety and Health (NIOSH). Their findings revealed that only work in construction, agriculture, and certain natural resource industries caused more employee injuries than vehicle accidents. The data also showed that traffic accidents were the source of a large portion of the total number of serious disabilities and fatalities.

The study categorized injuries by industry and occupation. As an occupational class, truck drivers were found to have a substantially high risk of fatalities; however, they had significantly fewer non-serious injuries. The reverse was true for passenger cars. They were found to have fewer fatalities, but almost double the number of non-serious injuries. The researchers concluded that the size and weight of trucks protect occupants in slower-moving collisions with other vehicles. However, because trucks are prone to jackknifing and overturning, truck drivers are more likely to experience a fatal injury. Besides the high fatality rates, trucker drivers were discovered to have workers compensation claims of longer duration and higher average cost.

Other occupational categories that generated a high number of expensive workers compensation claims as a result of vehicle accidents were salespersons, messengers, and collectors. It is important to realize that these were actual claims, and not rates of injury per worker. This means that jobs that have traditionally been considered unlikely to cause worker injury carry more risk than originally believed.

The data also indicated that employees involved in vehicle accidents had a significantly higher rate of permanent total disability and workers compensation death claims than all other types of claims combined. The average severity of temporary total disability, permanent total disability, and fatality was greater for vehicle claims than for non-vehicle claims.

The predominant cause of injury in workers compensation claims resulting from vehicle accidents was neck sprain and neck pain, which accounted for 15% of all vehicle claims. However, these claims made up less than 2% of the overall number of workers compensation claims.

When examining the cost of vehicle accidents to employers, workers compensation payouts represent only a small part of the expense. The Network of Employers for Traffic Safety studied the combined cost of motor vehicle accidents to employers in 2000. The researchers found that medical expenses amounted to $7.7 billion, sick leave, life and disability insurance benefits totaled another $8.6 billion, while workers compensation claims costs approximately $2 billion for employers.

PROTECT YOURSELF FROM THE BIG BUSINESS OF DATA THEFT

By Business Protection Bulletin

According to the U.S. Federal Trade Commission Internet fraud complaints soared from $206 million in 2003 to $336 million in 2005. The worst news, according to a survey performed by the Enterprise Strategy Group in 2006, is that your data is more likely to be stolen from inside your company by employees or on-site contractors than by outside hackers.

Protecting your most valuable and sensitive data must be a three-fold approach:

ASSESS YOUR DATA RISK

Begin the process by asking yourself three basic questions.

  • Who would want steal from my company? Consider the possibilities from different perspectives such as hackers, competitors, thieves, disgruntled current or former employees.
  • What data would they want to steal? Sensitive data is any information which compromises the security of your company. Client information, product and technology information, social security numbers, bank account and financial information, credit card numbers are just a few examples of the data which could be at risk.
  • What do I need to do to plug the leaks and protect this data? Security measures you can implement range from the very economical, such as purchasing commercial security software, to having an IT security consultant develop a custom security system appropriate to your company’s needs.

FORMULATE INTERNAL SECURITY PROCEDURES

Creating in-house security procedures is the only sure way to prevent data leaks from occurring inside your company. Security measures should include technical features, physical safeguards and the human element. Proactive steps to remedy potential weak points include:

  • Ensuring terminated employees lose access to not just the physical locale, but to the computer network, e-mail, and voice-mail systems as well.
  • Implementing access controls through the creation of internal firewalls to restrict the availability of sensitive data to only those employees who need it.
  • Creating stringent password policies to ensure employees do not share passwords. Alter passwords when employees leave or use additional passwords for sensitive data. Passwords should be strengthened by using a mixture of letters and symbols.
  • Updating your operating system regularly. Newer systems upgrade their security software and the options relating to access control giving you better security.
  • Scrutinizing how employees use your computer system. Prevent employees from being able to download material to CDs or iPods. Install security alarms to alert you when large blocks of data are deleted. Include a system to allow designated IT staff to be guard against unauthorized remote access to internal data.

DEVELOP SYSTEMS/INTERNET SECURITY

Data threats from within your physical locale can be solved by:

  • Employing encryption algorithms to protect vital data by making it unreadable to outside eyes. This includes your order forms where sensitive information such as credit card numbers or bank account information is involved and e-mail between employees who are transmitting crucial or sensitive information should also be encrypted.
  • Basic or custom designed security software packages which guard against viruses and worms are essential. Many companies fail to regularly update their security protection. Hackers or crackers evolve their methods and strategy of attack frequently and can be incredibly diabolical and creative.
  • Ensure you have a firewall suitable to the needs of your company. Commercial software packages may be adequate for smaller companies, but larger companies may require custom designed systems to safeguard sensitive data.
  • Back up all of your systems on a regular basis. Larger companies should do so daily while smaller companies could get by with weekly backups. Regardless, backups should be stored off-site! Should you keep backups on-site when your business experiences a natural disaster your backup system could also be destroyed. Companies need to be able to set up their system from another location with minimal delay.
  • Consider adding a virtual private network (VPN). Vested partners must be able to access the necessary data from your company in a secure manner. A VPN will allow safe access from remote locations. Extend your security system to any hardware employees are using such as cell phones, laptops etc.

DON’T MAKE THESE MISTAKES WHEN TERMINATING EMPLOYEES

By Business Protection Bulletin

Many employers become embroiled in convoluted and expensive litigation because they make simple but avoidable errors when terminating an employee. Even if you do terminate an employee correctly there is no guarantee you will avoid a lawsuit. However, if you’ve done everything properly during the termination process, your chances of winning the lawsuit are much greater.

Five Common Termination Mistakes

The most common errors made by employers are:

1. Not Applying Human Resource Policies and Procedures

Proper termination policies and procedures should provide good directions for terminating an employee in accordance with applicable state and federal laws. Similarly, a well-written employee handbook, which spells out issues of misconduct and poor job performance, adds to an employer’s credibility while negating claims to the contrary from a terminated employee.

2. Lack of Documentation

Poor performance should be documented in detail along with a substantiating basis. Misconduct issues require a thorough, unbiased investigation in alleged incidents. Chronologically order the documentation to provide a solid foundation for the termination. Keep in mind that without adequate documentation, your basis for terminating an employee may appear to be groundless and lack substance.

If disciplinary actions have been taken, the manager, and always with a witness present, should ask the employee to sign a description of the incident and the employer’s response. If the employee refuses to sign, this should also be documented.

3. Failing to Give Employee Notice of a Termination

Although many states do not require you to give notice to an employee, many legal experts say doing so can prevent a negative decision. One very important reason is to prevent the employee from using an unrelated tactic such as discrimination to cloud the real issue behind the termination.

Should an employer terminate an employee without a prior warning, the onus is on the employer to prove that the employee should have known they would be terminated based on their actions. Avoid this situation by giving the employee notice that if they commit the same or related infraction again, they will be terminated.

4. Failing to Provide a Just Cause for Termination

In many states, workers are employed ‘at-will,’ which means that employers can terminate an employee at any time. Consequently, many employers feel they can terminate an employee for practically any reason and are immune from negative consequences. This is simply not true.

Most employees fall in some protected class such as age, gender, race, religion or disability. Many lawsuits can be avoided or won by employers who base their termination decision on a ‘just cause’ or who provide a legitimate reason for the employee’s termination. A ‘just cause’ reason must have its foundations based on facts or proof.

5. Not Providing Accurate Performance Evaluations

The lack of documented performance evaluations is commonly used as the basis behind many wrongful dismissal actions. Often, managers seek to avoid confrontations with employees at appraisal time by giving the employee a positive evaluation and indicating the employee met performance expectations. Supervisors must be taught to be honest when completing appraisals. An employee may entertain thoughts of litigation when their performance appraisal states their performance met expectations, but the employer terminates them for alleged poor performance.

CHANGE YOUR DRIVING HABITS TO SAVE ON CAR INSURANCE

By Personal Perspective

Most Americans are driving less in order to save money on gas. However, decreasing the time you spend in your car can actually make you eligible for another savings opportunity: Paying less for your Auto insurance. If you’ve cut back on your driving, it’s a good idea to contact us to review the ramifications.

Consumers who are making greater use of public transportation or participating in car pools should contact their insurance company, because significantly reducing the number of miles driven each week could lower the cost of their Auto insurance premiums.

Many companies offer low mileage discounts to motorists who drive fewer than 7,000 miles a year. Even though each insurance company calculates rates differently, they all consider how many miles a motorist drives because the risk of an accident increases with the time you spend behind the wheel.

However, decreasing the risk of accidents isn’t the only benefit to driving less. The money you can potentially save on premiums is significant. A motorist who drops from an average of 15,000 miles driven per year to 8,000 miles could qualify for a 5% premium discount. A driver who goes from 15,000 miles per year down to 5,000 could possibly receive a 15% discount. Keep in mind that your insurance carrier may ask for an annual odometer reading to calculate annual mileage.

The Insurance Information Institute noted some other ways drivers could save on Auto insurance rates. SUV and truck owners who exchange their vehicles for a more fuel-efficient car could also reduce their Auto insurance costs. Premiums are generally lower for a $30,000 mid-size sedan than for a large $60,000 SUV. Besides sticker price, an insurance company will determine the coverage rate for an individual vehicle based on factors such as the cost to repair it, its overall safety record, and the likelihood that it will be stolen.

Drivers can also lower their Auto insurance premiums by taking a higher deductible, maintaining good credit, and dropping unnecessary coverages. If you insure your boat, RV, or motorcycle with the same company, you might also qualify for an extra discount on your Auto coverage.

MAKE CERTAIN YOUR NEXT PARTY DOESN’T BECOME A LIABILITY

By Personal Perspective

There’s nothing like the combination of good food and good friends. Whether it’s a potluck dinner for a few of the neighbors, or a wedding for 500 guests, these are the events that memories are made of. However, those memories could easily turn into bad ones if one of your guests leaves your home intoxicated and gets behind the wheel.

Most people are aware that businesses such as restaurants and bars have legal obligations to stop serving alcohol to visibly intoxicated patrons. But you might not be aware that in some states, individual hosts also have legal responsibilities when it comes to serving alcohol. Legislation called “social host” laws makes you responsible for the actions of your inebriated guests after they leave your party venue. Currently, 33 states and the District of Columbia have social host laws, according to Mothers Against Drunk Driving (MADD).

There are specific circumstances that must be present for a social host to be liable for the injury or damage caused by an intoxicated guest:

  • They were aware, or should have been aware, that the guest who caused the injury/damage was intoxicated.
  • They knew that the guest who caused the injury/damage would be driving after they left the gathering.

There are some ways to protect yourself from liability if you do serve alcohol at your next party:

  • Stop serving alcohol after a couple of hours and serve coffee instead.
  • Make sure there is plenty of food available for your guests to eat while they are drinking.
  • Assign designated drivers to take intoxicated guests home.
  • Keep a list of cab companies’ phone numbers by the telephone in case you need to call a cab for a guest who shouldn’t drive.
  • Remain sober so that you can monitor your guests’ sobriety level.

Another good way to protect yourself from liability is to check your Homeowners policy before your next party to determine what your coverage is for property damage and liability. In the event of an incident, your Homeowners policy would pay for covered liabilities up to the policy limit. You should also consider purchasing a Personal Liability Umbrella policy for increased protection.

Apartment dwellers and owners of condos and co-ops typically aren’t covered for liability and personal property damage under their building’s insurance policy. Generally, the building policy only covers the common areas. That’s why renters should have Renter’s insurance, and condo and co-op owners should purchase a HO-6 Homeowners policy that is specifically designed for their needs. They should also review their condominium or co-op association’s master policy to determine what their responsibilities are in the event of an incident.

If you hire professional caterers and bartenders for your event, don’t assume that you are covered under their Liability insurance. You must be specifically named on the policy to be covered in the event of an accident. However, if you are named on your party Professional Liability policy, their insurance company will defend you if you are sued. That’s why it’s important to verify that they have Liability insurance, the specific situations that are covered, any exclusions, and if you can be a named insured on the policy. Questions? Contact us for more information.