This case raised issues relating to a hospital’s obligations under Article 21 of the Collective Agreement (Fiscal Advisory Committee).
While the Board of Arbitration, chaired by Russell Goodfellow, did not find a breach of Article 21 on the specific facts of the case, it did make some useful comments about the scope of hospitals’ Article 21 obligations generally that will undoubtedly be of use in future cases:

“Article 21 is obviously an important and complex provision that clearly recognizes the value of the Union’s input on behalf of employees through the budgetary process on matters that may impact the Union’s members. It further contemplates┬áthat the Union will be consulted when unforeseen circumstances lead to changes or revisions to the budget. It also contemplates timely production of financial and staffing information to the Union at, or, where possible, in advance of, scheduled F AC or equivalent meetings. Finally, the article contemplates that an employee participating at an F AC or equivalent meeting shall be paid at his or her regular or premium rate as may be applicable. Transparency is important in labour relations and this article is designed to support that value.”