Exhibit 19 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.858 Filed 08/01/16 Page 1 of 43
Investigation Report 

CONFIDENTIAL 

To; Investigation File 

From: Dan E. Champney, Esq. 

Deputy General Counsel 

Health Alliance Plan 

2850 W. Grand Boulevard 

Detroit, MI 

Date: May 29,2013 

Re: Complaint filed by Monica Rogers alleging discrimination on the basis of age and 

race, as contained a complaint letter dated March 25,2013 

i 

I. Summary of Complaint: 

Monica Rogers alleges discrimination on the basis of age and race. Her compliant is 

based upon her assigned duties, which she claims are consistent with the duties of the 

"Sr. Consultant" classification—as opposed to her current classification as a "Consultant," 

A single reference to "harassment" in her letter of complaint has not been the focus of the 

investigation, since in her interview she indicated that this comment was in regard to past 

incidents not otherwise part of her current complaint. 

II. Pre-Investiaation Actions: 

No pre-investigative action was taken to the best knowledge of the investigator. Monica 

Rogers and all other employees mentioned in her complaint have continued employment 

with HFHS as of tine date of this report without limitation. 

I 

III. The Investigation Process 

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I began the investigation on April 30,2013. 

I received the letter of complaint, and job description for the Consultant -OHRD and 

Senior Consultant- OHRD from J, Jacobs on 4/30/13 

I interviewed the following witnesses: 

1. Monica Rogers: May 8, 2013- 3;00pm to 4:20pm 

2. Jan Harrington-Davis: May 13, 2013- 4:00pm to 4:30pm 

5. Laurie Jensen; May 15, 2013- 2:30pm to 4:00pm 

4. Barbara Bressack: May 15, 2013—4:00pm to 4:30pm 

5. Monica Jackson-Lewis: May 17,23103—12:00pm to 12:30pm 

My notes from these interviews are in the investigation file. 

IV. Documents 

I reviewed the following documents: 

o Monica's Letter of Complaint dated March 25, 2013 

o Consultant- OHRD job description (As received from J. Jacobs on 5/3) 

o Sr. Consultant- OHRD job description (As received from J. Jacobs on 5/3) 

o Consultant- OHRD job description (As received from L. Jensen via Phyllis Taylor 

on 5/16) 

0 Sr. Consultant- OHRD job description (As received from L. Jensen via Phyllis 

Taylor on 5/16) 

o Monica Rogers' performance evaluation for 2012 

o Laurie Jensen's journal entry for her meeting with Ms. Roger on 1/09/13. 

o Spreadsheet showing Consultants and Sr. Consultants by Name, Birthdate, Sex, 

Ethnic Group, Job Title, Department, and Start Date, 

o HFHS Organizational & Human Resources Development (OHRD) Organizational 

Chart 

o Chart showing the race, education level achieved, match to credentials of job description, and explanation of placement for several white employees referenced 

by Ms. Rogers. 

Copies of these items are in the investigation file. 

I completed my investigation on May 29, 2013. 

Invesligalion Report Form Page 2 of 9 

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! 

V. Comnlaint 

Ms. Roger's complaint alleges discrimination on the basis of age and race. It also makes 

an initial allegation of harassment. An analysis of each follows. 

A. Allegations of Age Discrimination 

Based upon her complaint letter, as well as her interview, Ms. Rogers' compliant 

of age discrimination would appear to be based upon a statement she claims was 

made by Laurie Jensen on two occasions. This statement is that "1 don't know 

about you, but at our age we only have one good job left." Ms. Rogers claims that 

this comment was made in a one-on-one meeting with Laurie Jensen on January 

17,2013 and repeated in a meeting with Laurie Jensen and Jan Harrington-Davis 

on January 23, 2013. In her interview, Ms. Rogers confinned that this comment 

was the basis of her age discrimination claim, She has made no further claim as 

to how this comment was connected to her complaint with regard to her classification. Both Laurie Jensen and Jan Harrington-Davis deny that this comment was 

made. 

Based upon this record, I would conclude: 

a. There is only Ms. Rogers' statement to support this comment ever being 

made, i.e. no other document or evidence revealed in the investigation supports such a comment being made. Ms, Roger does not suggest that this 

comment was made other than in a two-person conversation (with Laurie Jensen) and in a three-party conversation (with Laurie Jensen and Jan HarringtonDavis). Both other participants deny that this comment was made. 

b. Even if it was assumed that the cojrunent was made on two occasions, it 

would appear a fleeting reference and there is no indication that it played any 

role in Ms. Rogers' treatment. Both her direct supervisor (B. Bressack) and 

her Director (L. Jensen) categorically deny that Ms. Rogers was treated differently because of her age. Indeed, there is no showing of any employment action that would appear to lie to her age. 

c. Moreover, the essence of the comment does not necessarily suggest or infer an 

inclination to discriminate on the basis of age. The statement itself is vague. 

Investigation Report Foim Page 3 of 9 

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It can be seen as either an affirmation that someone should be favored by 

promoted or an affirmation that someone should not be favored. 

Based upon my interviews with the witnesses identified above and review of the 

relevant documents, there is no credible evidence to support Ms. Roger's complaint of age discrimination. 

B. Allegation of Race Discrimination 

Via her complaint letter of March 25, 2013, Ms. Rogers bases her race discrimination claim on several statements made by those in management during the time 

period of December, 2012 to February, 2013, These statements include: 

1. In talking to B. Bressack and in a staff meeting, she was told that; In order 

to get an evaluation of a "5" on my performance evaluation, I would have 

to perform duties above my current level of a "Consultant" and perform as 

a "Sr. Consultant." 

2. In talking to Jan Harrington-Davis about her treatment, Ms. Rogers connected her treatment to her age, but was told, "It has nothing to do with 

, your age, it's because you are black." 

3. In talking to L. Jensen she was told; 

i. "We know you can do the work because you've been doing it. There 

is just this one little thing that keeps us from making you a Sr. Consultant" 

ii. "There isn't much difference in the work of a Sr. Consultant and Consultant and the Sr. Consultant title might be eliminated" 

iii. "I support that you should be a Sr, Consultant" 

iv. "I think we've missed a lot of opportunities to fix this 

v. "Just because my "job title was wrong now, doesn't mean it should 

stay wrong" 

4. In taking to Ms. Monica Jackson-Lewis, Ms. Roger quotes her as saying 

that: 

! 

There are always ways around educational requirements; and 

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Once Ms. Rogers had the new job responsibilities and new and old 

job descriptions, she would have everytliing she needs and Ms. 

Rogers could do what she needs to do. 

»» 

n. 

In essence, Ms. Rogers' complaint is diat she performs at the level of a Sr. Consultant. Her supervisors recognized the inequity in her being at the Consultant 

level. Her Director indicated that she supported Ms. Rogers being at the Sr. Consultant level. A management representative (Ms. Jan Harrington-Davis) acknowledged that her treatment is because she is black. Following all of these discussions and acknowledgements, her position remains that of a Consultant, 

With regard to B1 above, the alleged comment does not relate to race- either by 

its terms or through implication. The comment was made both privately and publically. Ms. Rogers does not connote the comment being in reference to her race, 

e.g. she needed to perform at the next level because of her race, Rather, it was a 

statement used to describe the level of performance associated with rating under 

HFHS evaluation program. 

With regard to B2, this comment is the only comment Ms. Rogers quotes that 

does blatantly concerns race. It would be a sign of racial discrimination bias if a 

Director level management employee explained Ms. Rogers' treatment as because 

of her race. In this circumstance, Ms. Jan Harrington-Davis indicated that Ms. 

Rogers has taken the comment significantly out of context in two ways. First, Jan 

Harrington-Davis statement was that her reference was made to a prior incident in 

Ms. Rogers' employment history in which there was a suggestion that inappropriate comments and/or actions were suffered by the employee. Jan HarringtonDavis was quite emphatic that her comments related to this prior period of time 

and not the current events concerning Ms. Roger' job classification. Secondly, 

Ms. Harrington-Davis explained that the comment she made was phrased as an affirmation of what Ms. Rogers had said, i.e. she was being treated differently in 

that prior incident not because of her age, but because of her race. According to 

Jan Harrington-Davis, she was summarizing Ms. Rogers's prior account and certainly not categorizing recent events. -

Invesligallon Report Form Page 5 of 9 

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With regard to die several statements contained within B3 above, Ms. Laurie Jensen denies making these comments. She expresses that she did not believe that 

Ms. Rogers was performing at a Sr. Consultant level. She further indicates that 

the degree required to do a Sr. Consultant's job is not a "little thing" at all. She 

added that Ms. Rogers would be challenged to perfonn the Sr. Consultant's job in 

areas such as "instructional design" and having the necessary background in leadership and strategic direction. Ms. Jensen suggests that she had personally supplemented the work of Ms. Rogers in supporting the Leadership Academy and 

Advance Leadership Academy work. Ms. Jensen's memory of the meeting is 

supported by a journal entry she has maintained from January 9, 2013 as well as 

Ms. Rogers' 2012 performance evaluation. 

With regard to statement B4i above, Ms. Jackson-Lewis denies making this comments and suggests that it was Ms. Rogers who made this comment in talking 

about her co-worker—Brian Robertson. With regard to statement B4ii, Ms, Jackson-Lewis denied making this comment as recited by Ms. Rogers. 

Through my interview with Ms. Rogers, there were several times comments concerning how many "system-wide" programs she lead, In her interview, Ms. Rogers identified Leadership Academy, Advanced Leadership Academy and the Renewal program as system-wide programs she leads. With regard to this point, neither Ms. Bressaek nor Ms. Jensen believed Ms. Rogers to lead two system-wide 

programs. She was not credited with leading Advanced Leadership Academy and 

the Renewal program was described as a class and not a program. 

Ms. Rogers' compliant letter also includes several other employees she alleges are 

white and were promoted into higher level positions although they did not have 

the requisite education and/or experience. 1 have been provided by the Employer 

with a chart which captures the employment history associated with these identified employees and the title/position identified by Ms. Rogers. (1 have not endeavored to authenticate the correctness of the facts contained in this chart- as 1 

deemed that outside the scope of this investigation.) For each identified employinvestigation Report Form Page 6 of 9 

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ee, except one, the recited facts indicate that they did in fact have the required experience/education for their positions. The exception is Brian Robertson- who as 

noted above- is in the same position as Ms. Rogers, and like her, does not have his 

bachelor's degree. However, it would not appear that he was promoted into the 

Consultant job, but was placed in the job as a result of department reorganization. 

C. Hostile Work Environment 

In the second sentence of her complaint letter, Ms. Rogers uses not only the word 

"discrimination" but "harassment." At the onset of my interview with her, I asked 

her to further explain if she was also complaining about harassment. She clarilied 

that this reference was to past incidents and not the facts surrounding the current 

complaint. As a consequence, this investigation has not focused upon claims of a 

hostile work environment or harassment. 

VL Conclusions 

Having completed the investigation, reviewed my notes and having carefully reviewed all the documentation, I have concluded that there is little evidence that Monica Rogers has been discriminated against on the basis of her age or race. While Ms. 

Rogers is a member of a protected class on both the basis of her age and race, a prima 

facie case of discrimination is not made out. 

First, it should also be noted that Ms. Rogers' complaint of discrimination on the basis of age and race is not connected to an active employment determination, but inaction. In other words, the facts complained of are not that Ms. Rogers applied for and 

was denied a Sr. Consultant job- Rather, it is her contention that her job classification 

remained the same when, under her complaint, she should have been advanced into 

the Sr. Consultant role. The action (or Inaction) complained of would appear to be 

the failure to transfer her into a Sr. Consultant's job. 

Under these undisputed facts, it is questionable whether there was any type of adverse 

employment action, as she has not been denied a promotion or disciplined under the 

facts germane to this matter. Her direct and Director-level management can describe 

the actions (or non-action) taken against her (perhaps best described as failing to 

Investigation Report Form Page 7 of 9 

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change her job title to "Sr. Consultant) as reasonable, since her responsibilities still 

fell within the job description of a "Consultant" and she did not meet the educational 

requirements of a Sr. Consultant. Her management can and did offer examples of responsibilities that she would struggle to successfully undertake if working in the Sr. 

Consultant role. They also dispute her claims that she leads two system-wide programs. There is certainly the absence of a record that demonstrates that Ms. Rogers 

was qualified to serve in the Sr. Consultant job, i.e. she did not have the required degree and her management believes that she lacked certain experience and skills to 

perforin all responsibilities of the Sr. Consultant. There did not seem any pretext to 

these comments to the investigator. 

The record seems clear that persons in the position of Sr. Consultant indeed have degrees-- and degrees at the Master's level. Ms. Rogers is one of two employees in the 

Consultant classification who do not have a Bachelor's degree. Ironically, Ms. Rogers complains of the other person (Brian Robertson) having been placed in the Consultant role without a degree when in fact that is her own status and employment history. 

Finally, the statements she cites that could be said to evidence a racial or age bias are 

denied by management as either not being said or repeated inaccurately or out of context. Management denied categorically that Ms. Rogers was treated differently because of her age or race. 

VII, Recommendations 

1. Based on the conclusion above, I find that this matter should be closed. Both Ms. 

Rogers and her direct (B. Bressack) and her Director (L. Jensen) should be advised of the investigation results. 

2. Ms, Rogers' supervisor did not deny making comments concerning performing at 

the next level in order to earn a "5" on an evaluation. It is submitted that this is an 

explanation that could lead to confusion on the part of employees. Performance 

examples within the job classification should be used to describe excellent performance levels. 

3. In the process of completing the investigation, I was afforded access to the job description of Consultant and Sr. Consultant both by HR management and by Ms. 

Roger's management. The copies received were not identical- although in subInvesllgalion Report Form Page 8 of 9 

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Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.866 Filed 08/01/16 Page 9 of 43
stance there is not a great deal of difference. As a result, greater confusion was 

created than is necessary. If not already adopted, there should be a clear depository and point person for job descriptions. 

Signed: ^ 

Date; 

InvBsliijatlon Report Form Pago So! 9 

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Notes and Observations: 

Interview with Monica Rogers 

May8( 2013 

3;00pm -4:20pm 

: 

1. Monica Rogers agreed to meet with me on May 8,2013 at my offices at 2850 W. Grand 

Boulevard, Detroit, Ml 48202 to discuss her complaint- as embodied in a letter dated March 25, 

2013 and addressed to Derick Adams- VP Human Resources Corporate Services. 

2. Mr. Rogers appeared at my office on time and was alert and professional throughout the 

interview. While certain occurrences or reported facts were clearly emotional to relate, she 

maintained her composure throughout. 

3. I thanked Ms. Rogers for meeting with me and explained that I had been asked to conduct an 

Investigation of her complaint and wished to talk to her with regard to her complaint. I also 

explained that while Jolene Jacobs had also conducted an Interview with her, there was now an 

interest on the partof HFHS in having an individual outside of the HFHS HR department talk to 

her about her complaint. I further explained that I did not want to rely upon Ms. Jacob's 

Interview since I wanted to talk to Ms. Rogers personally. 

4. I explained to Ms. Rogers that I wanted to go through her letter with great care and that I 

wanted to fully understand what her complaint was. I asked her to correct me if I said anything 

or characterized any matter different than what she intended. I also invited her throughout the 

interview to feel free to supplement what she tells me even after the Interview Is completed. 

5. Ms. Rogers currently holds the position of "Consultant- OHRD," She reports that she has held 

this position since 2007. However, her tenure with HFHS goes back to 1981 and includes 

positions In the areas of Occupational Therapy, Staff Services, Corporate Retirement, and 

Employee Relations, among others. 

6. I asked her what the main responsibilities of her current job are and she identified the following 

programs/processes; 

a. Leadership Development 

b. leadership Academy 

c. Renewal Program 

d. Consulting 

e. Coaching 

f. Team Building 

7. Ms. Rogers reported having approximately two years of college credit, 

8. Turning to her letter of complaint of March 25lh,! asked her what type of discrimination she was 

complaining about. He indicated discrimination on the basis of race and age. She specifically 

denied any complaint concerning gender discrimination. 

1 

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9. I asked Ms. Rogers about the fact that the first sentence of her letter of complaint alleges both 

discrimination and harassment. She indicated that her reference to harassment referred to past 

occurrences- not those contained in her letter. 

10. Ms, Rogers indicated that her letter of complaint was actually a distilled summary of a much 

larger document that she has maintained and that she produced the letter as a summary with 

the assistance of her attorney. 

11. I asked Ms. Rogers, for an explanation of why her claims of discrimination were directed at 

Laurie Jensen. She indicated that Ms. Jensen is the Director of the OHRD, but not her current or 

even former direct supervisor. She related that her current direct supervisor is Barbara 

Bressack. 

Letter of Complaint and Interview Notes: 

12. First Paragraph: December 1,2012-January 8,2013 

Ms. Roger related that this paragraph represents conversation between B. Bressack and Ms. 

Rogers between the dates Identified. This was before Ms. Bressack was her direct supervisor 

and they were talking in the context of who was going to be doing what in the department. Ms. 

Rogers reports that in the conversation that Ms. Bressack said that in order to get a "5" on 

evaluation that employees needed to perform above their classification. Ms. Rogers interpreted 

this to mean that she had to perform at a "Senior Consultant- OHRD" level—the classification 

above her own. She reports saying to Ms Bressack that "I guess I'll just get a 3." She reports 

stating to Ms. Bressack that she was not asking for anything that had not been done for others. 

By this she was referencing Brian Robertson, a white make, without a degree who she reports as 

having been promoted to an ORHD Consutlant. 

13. Second Paragraph: December 1, 2012--January, 2013 

Ms. Rogers cannot remember the exact date, but following her conversation reported 

immediately above with Ms. Bressack, Ms. Rogers went to talk to Jan Harrington-Davis- who Ms. 

Rogers reports as being the Director of Employee Relations and Diversity. Ms. Rogers shared 

Ms. Bressack's comments about getting a "5" and her concerns that she was being asked to 

perform at a Senior Consultant level without having the title or pay forthis position. According 

to Ms. Rogers, Ms. Harrington-Davis indicated that if she was being asked to perform the same 

duties as a Senior Consultant without the title/money that would be illegal. Ms. Rogers 

indicates that she suggested that perhaps this was happening because of her age. Ms. Rogers 

reports that Ms. Harrington-Davis laughed and stated "it has nothing to do with your age; if s 

because you are black." 

14. Third paragraph: January 9,2013- Laurie Jensen's Office (11:30am) 

Ms. Rogers reports that in her "update meeting" of 1/9/13 with Ms. Jensen, she was receiving 

her evaluation and received a score of 4.3 out of 5. She further reports that Ms, Jensen 

indicated that "We know you can do the work because you've been doing it" and there was 

"Just this one little thing that keeps us from making you a Sr. Consultant." Ms, Roger's letter of 

complaint indicates that this was a reference to lack of credentials, but in the interview clarified 

2 

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that this meant the lack of a degree. On this point, Ms. Rogers Identified the following 

employees as being Senior Consultants and Consultant and educational level as far as she knew: 

p :s 

degree 

degree 

degree 

o Mike 

« Cathy 

o Barbara Bressack (prior to promotion) 

Consultants 

degree 

degree 

no degree 

degree 

no degree 

degree 

degree 

» Patrick 

o Liz 

o Brian 

o Karen 

o Monica 

o Michelle 

o Jennifer 

Ms. Rogers also reports that Ms. Jensen indicated that she didn't think that there was much 

difference In the work of a Sr. Consultant and a Consultant and that she was considering eliminating 

the Sr. Consultant title and everyone would be a Consultant. 

15. Fourth Paragraph: January 16,2013 Staff Meeting 

Ms, Rogers reports that during a staff meeting on 1/16/13, copies of the Consultant and Sr. 

Consultant job descriptions were distributed to the team for review and feedback. 

[Note I provided a copy of the jd I have been given and Ms. Rogers said she needed to check 

and see if they wore the same ones handed out in this meeting.] 

According to Ms. Rogers, the team was told that the job descriptions would be re-written to 

reflect current job duties. Ms. Jensen stated that the major difference between Consultant and 

Sr. Consultant is that the Sr. Consultant leads two or more system-level programs/projects. The 

Consultant leads one. 

Upon Inquiry, Ms. Rogers reports that she believes that several of her projects were systemwide, including Leadership Academy and the Renewal Program. 

Ms. Rogers also reports that both Monica Jackson-Lewis and Laurie Jensen repeated the 

statement that to get a "5" on your performance evaluation; you must perform the duties of the 

Sr. Consultant. 

16. Fifth Paragraph: January 17, 2013. Update Meeting w/Laurie Jensen 

Ms. Rogers reports that this was an "update meeting" with Ms. Jensen. Ms. Rogers attributes 

several key comments to Ms. Jensen in this conversation, including: 

o 1 support that you should be a Sr. Consultant 

o I think we've missed a lot of opportunities to fix this, 

o Just because your job title was wrong now, doesn't mean it should stay wrong. 

3 

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o I don't know about you but I feel that at our age we only have one good Job left. 

As to this last comment, upon inquiry, Ms. Rogers indicated that she interpreted that to mean 

that at her age she only had time for one more promotion. 

According to Ms, Rogers, Ms. Jensen suggested that a meeting with Jan Harrington-Davis should 

be set up to see what can be done to fix this issue. When queried, Ms. Rogers could not explain 

why Ms. Jensen suggested that a meeting with Jan Harrington-Davis was a way to fix the issue. 

I 

: 

17. Sixth Paragraph: January 23,2013- meeting with Jan Harrington-Davis and Laurie Jensen and 

Monica Rogers 

Ms. Rogers reports that she was surprised by the fact that Ms. Jensen started the meeting by 

saying the meeting's objective was to discuss how Monica feels she performs at the same level 

of Sr. Consultant. She reports being surprised since she believed that Ms. Jensen called the 

meeting to "fix" the issue. Ms. Rogers reports that Ms. Jensen repeats the comment that "at 

our age we only have one good Job left." 

Ms. Rogers reports that Ms. Harrington-Davis Indicated that she did not support Ms. Rogers 

getting a change In title, but that she agreed that Ms, Rogers perform at the senior level. Ms. 

Harrington-Davis suggests writing a Job description based upon what Ms, Rogers duties were; or 

change/modify current Sr. Consultant job description to say "degree preferred." Ms. Jensen 

didn't like either suggestion. 

18. Seventh Paragraph: January 24,2013. Meeting with co-workers 

Ms. Rogers reports that on 1/24/13 her co-workers (Brian Robertson, Lb Mallory, Patrick Payne, 

Karen Glovannini and Jennifer Landers met to discuss the job duties of the OHRD Consultant. 

Based upon the differences in level of duties, the group did not reach any conclusion. 

19; Eighth Paragraph: January 29,2013. ALA/LA partnership Session. 

Ms. Rogers reports that toward the end of this session her direct supervisor, Barbara Bressack, 

told Ms. Rogers that her current Job duties would not be changing and that coaching and 

consulting would be an additional requirement. This last comment, In Ms. Rogers view, was in 

response to her asking which of her Job responsibilities would be reduced. 

20. Ninth Paragraph; HFHS University Staff Meeting 

Ms. Rogers indicates that at this meeting the staff received an updated copy of the Consultant's 

job description. Upon inquiry, Ms. Rogers indicates that the Consultant job description was 

changed to now say that "two or more" major programs are to be handled by the Consultant. 

21, Tenth Paragraph; February 4,2103. 

Ms. Rogers reports that on 2/4/13, her prior supervisor, Monica Jackson Lewis came to Ms. 

Rogers office to "provide counseling." Upon Inquiry, Ms. Rogers believe this was due to the fact 

that she gave the appearance of being disappointed with the treatment of her job description. 

Ms. Roger reports that Ms. Monica Jackson-Lewis made the following comments; 

•> Ms. Roger should do whatever Laurie and Barbara asked her to do 

" There are ways around the education a requirement, we have done It before 

I 

4 

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o When Ms. Rogers has both the old and new job descriptions, she will have all that she 

needs to do what you have to do 

22. Eleventh Paragraph; February 20, 2013, Meeting with Barbara Bressaclc 

Ms. Rogers reports that In this meeting with her direct supervisor, her 2013 performance goals 

were established. She indicates that her duties remain as equai to a Sr. Consultant, 

I 

Ms. Rogers concludes her complaint by indicating that this treatment is unlawful because she is 

being treated differently than white counterparts. She identifies the following as white 

employees for which an exception was made with regard to education or experience level-

, 

o Brian Robertson—OHRD Consultant 

o Patti Sanburn—HR Director 

o Carol Bridges—Director Service Excellence, Volunteer Services , 

o Tarra Bufford—her Analyst—Experience in lieu of education 

o Nicole Logai—Sr. Consultant, Compensation—Master preferred 

o Debra Temrowskl~HR Director—Experience number of years reduced. 

In her.letter of complaint, Ms. Roger indicates that "on more than one occasion, statement 

referencing my age have been made." Upon inquiry, she did not have anything to add to this 

complaint—other than the statement repeated above concerning one last job left. 

Ms, Roger claim is that; 

"These Issues of race and age discrimination, promotion, job assignment and equal pay, must be 

addressed and the unfair treatment I have experienced must be made right, " 

General Qbservatfons: 

Ms. Rogers present herself well and her concerns with her treatment would appear sincere 

and heartfelt. 

5 

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( 

Notes and Observations 

Interview with Laurie Jensen 

May 15, 2013 

2:30 to 4:00ptn 

1. Laurie Jensen agreed to meet with me on May 15, 2013 to discuss the discrimination complaint 

filed by Monica Rogers. 

2. Ms. Jensen reported that she holds the position of Director, Organizational and HR 

Development, HFH5 University. She reports to having been in essentially this job for 7 years, 

including one year in an interim capacity. 

3. Prior to this position, Ms. Jensen worked as a Sr. Representative for Organizational 

Development. She has worked at HFHS for 9 years In total. 

4. Ms. Jensen did not dispute Ms. Rogers's statement that they had a discussion concerning job 

responsibilities in an update meeting on January 9, 2013. During this discussion, Ms. Roger 

received her performance evaluation. Ms. Jensen gave Ms. Rogers an evaluation of 4.3- which 

Ms. Jensen characterized as "extremely high." Ms. Jensen indicates that they had been nonverbal clues that Ms. Rogers was not happy and that she drew her out as to what her concerns 

were. Ms. Rogers indicated that she believed she was doing the work of a Sr. Consultant, but 

remained classified as a Consultant. Ms. Jensen did not agree with this perception. 

5. Ms. Jensen denied saying In this meeting that "we know you can do the work because you've 

been doing it," and that she would not have characterized Ms. Rogers has having been doing Sr. 

Consultant work. Rather, Ms. Jensen opined that Ms. Rogers wasn't capable of doing Sr. 

Consultant's work. While she had to step into a project when a Sr. Consultant left the staff, 

others including Ms. Jensen had to provide guidance and direction, 

6. Ms. Jensen denied saying in this meeting that "just this one little thing that keeps us from 

making you a Sr. Consultant." (Referring to the fact that Ms. Rogers did not have a degree.) Ms, 

Jensen indicates that she does not consider a degree a "little thing" at all. She notes that certain 

features of the Sr. Consultant position would be challenging to Ms, Roger, An example given 

was the "Instructional design" aspect of the Sr. Consultant job. Moreover, Ms. Rogers did not 

have leadership experience as part of her career. 

7. Ms, Jensen suggested that Ms. Rogers has taken out of context her comments about eliminating 

the Sr, Consultant position. Ms. Jensen did indicate that they would be taking a fresh look at the 

job descriptions. 

8. Turning to a staff meeting identified by Ms. Rogers as being on January 16, 2103, Ms. Jensen 

denies limiting the differences between Sr. Consultant and Consultantto whether the position 

has one or two system-level programs/projects. Rather, she relates that it was providing the 

overall strategic direct ion for one or more system-level projects that was one of the distinctions. 

1 

ATTACHMENT I) 

HF 00414 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.873 Filed 08/01/16 Page 16 of 43
Consultants do handle various components of system-wide programs, but do not have the 

overall strategic direction for the programs, 

9. When asked if Monica led two or more system-wide programs in January, 2013, Ms, Jensen 

indicated "no." She provides leadership to Leadership Academy and support to the Advanced 

Leadership Academy. She does not provide strategic direction or the necessary "creative 

element." Asked about the "renewal" program, Ms. Jensen indicated that this was a class-not a 

system-wide program. 

10. Ms. Jensen denied saying in this staff meeting that in order to get a "5" on your evaluation, you 

had to perform the duties of the Sr. Consultant. Rather, she would have expressed that you 

have to do more than the minimum of your job. 

11. With regard to an "update meeting" Ms. Rogers's reports took place on January 17, 2013, Ms. 

Jensen is uncertain whether that is the correct date, but knows that they met again before their 

conversation with Jan Harrington-Davis. 

12. Ms. Jensen denied saying in this meeting that "we've missed a lot of opportunities to fix this." 

13. Ms. Jensen denied saying in this meeting that "I don't know about you, but 1 feel that at our age 

we only have one good job left." Rather, Ms. Jensen reports that she knew from Ms, Rogers' 

comments that she was planning to retire. She did express support for providing her work with 

which she was comfortable prior to retirement. 

14. Ms, Jensen denied saying in this meeting that there was not much difference In the work of a Sr. 

Consultant and a Consultant and that she was considering eliminating the Sr. Consultant title. 

Rather, she recalls taking about the impending merger with Beaumont and that this event may 

give rise to re-consider job duties. 

15. Ms. Jensen denied saying in this meeting that just because your job title was wrong now, 

doesn't mean it should stay wrong. She did not use the word "wrong" but was open to 

understand any issues with the job descriptions. 

16. Ms, Jensen denied saying fn this meetifig that she said that she would support Ms, Rogers in 

getting the Sr, Consuitant job in meeting with Jan Harrington-Davis, Rather, she recalls saying 

that she would support Jan's approach to this issue, Ms. Jensen reports that she was not seeing 

an Inecjuity in job responsibility as expressed by Ms. Rogers. However, she was willing to get a 

third party review of the situation and wouid support that view, 

17. Ms, Jensen does not deny saying in this meeting thatiliey should consult with Jan HarringtonDavis. She was looking for another point of view on this issue, 

18. Ms. Jensen supports Ms. Roger statement that a meeting with Jan Harrington-Davis took place 

on January 23,2013. Ms. Jensen reports that Ms, Rogers set up the meeting, 

19. Ms, Jensen denied saying In this meeting that the objective was to discuss how Monica feels she 

performs at the same level of a Sr. Consuttant, Rather, she reports that her objective was for 

Monica to express her feeling of unfairness and to ask Jan to think about solutions with them- as 

an objective third party. 

20. Ms. Jensen again denied saying in this meeting that "I don't know about you, but I feel that at 

our age we only have one good job left," 

2 

HF 00415 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.874 Filed 08/01/16 Page 17 of 43
21. Ms. Jensen did not deny that Jan Harrington-Davis did suggest that Monica Rogers performs at a 

high level. She agreed that there are certain aspects of the Consultant job that Monica performs 

very well. 

22. As to suggestions made by Jan Harrington-Davis, Ms. Jensen; 

" Agrees that waiting to see how the merger impacted job description was a possible 

solution; 

o Doesn't recall her saying that the Consultant and Sr. Consultant position should be 

clarified, but doesn't disagree and notes that they were, in fact, working on that; 

o Doesn't recall the suggestion that the education requirement of the Sr. Consultant job 

description be change to make it "preferable.." 

23. Ms. Jensen also offers that throughout this conversation, Jan Harrington-Davis was trying to 

ascertain from Ms. Rogers whether it was the Sr. Consultant title or the compensation that was 

the Irritant to her. Ms. Jensen recalls that Ms. Rogers never answered these questions. 

24. When asked in summary if Ms. Roger met the qualifications for the Sr. Consultant job In January, 

2013, Ms. Jensen indicated "no." She added that she neither had the required educational 

background nor she did oversee system-wide initiatives. Ms. Jensen gave the following 

examples of system-wide programs: 

o Performance Management 

« Employee Engagement 

o Physician Development 

o Succession Planning 

25. When asked what had been done to resolve this issue for Monica, Ms. Jensen suggested that it 

was her understanding that Monica had accepted waiting to see if the merger lead to different 

job duties. She also noted that she had pulled Monica into an initiative on cultural change that 

she thought was engaging for her. 

26. When asked If Monica Rogers was treated differently than others because of her race, Ms. 

Jensen responded, "no." 

27. When asked if Monica Rogers was treated differently than others because of her age, Ms. 

Jensen responded, "no." 

28. When asked If Monica Rogers ever complained of a hostile work environment, Ms. Jensen 

responded, "no." 

3 

HF 00416 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.875 Filed 08/01/16 Page 18 of 43
Notes and Observations 

Interview with Barbara Bressack 

May IS, 2013 

4:00 to4;30pm 

1. Barbara Bressack agreed to meet with me on May 15,2013 to discuss the discrimination 

complaint filed by Monica Rogers. 

2. Ms. Bressack reported that she holds the position of Manager of Leadership Development, 

OHRD. She reports to having been in this job for only 5 months, starting essentially In the New 

Year. 

3. Prior to this position, Ms. Bressack worked as a Sr. Consuitant-OHRD. She was promoted from 

the Consultant job to the Sr. Consultant job. She has worked at HFHS for 9 years in total. 

4. Ms. Bressack did not dispute Ms. Rogers's statement that they had a discussion concerning job 

responsibilities in January, 2013. As she recalls the discussion, she was asking Ms. Rogers what 

job duties she was most interested in. Ms. Rogers expressed dissatisfaction with her work load 

versus others. Ms. Bressack was most familiar with the work load of Jennifer Landers and didn't 

believe there was any inequity disfavoring Monica Rogers. 

5. Ms, Bressack indicated that her comment was taken out of context with regard to having to 

perform at a Sr. Consultant's level in order to geta "5" as a Consultant. Rather, Ms. Bressack 

indicates that her personal philosophy is that one should always try to perform at a level above 

your position, She believes that she may have communicated this philosophy to Ms. Rogers. 

6. Turning to a staff meeting Identified by Ms. Rogers as being on January 16, 2103, Ms. Bressack 

indicates that Laurie Jensen led the meeting and handed out the job descriptions. The Sr, 

Consultants and Consultants were both asked to work on updates to reflect current duties. Ms, 

Jensen also did Indicate that a main difference between a Sr. Consultant and a Consultant was 

the leadership of two system-wide projects/program 

7. In responding to what system-wide programs Monica Rogers led in January, 2013, Ms. Bressack 

indicated that she did lead Leadership Academy, but only supported Advance Leadership 

Academy. The "renewal" was only a cfass. 

8. Ms. Bressack did not recall a conversation with Monica Rogers at the ALA/i.A Partnership session 

on January 29,2013 where Monica Rogers claims that Ms, Bressack told Monica that her job 

responsibilities would not change. As to Ms. Rogers claim that Ms. Bressack also said that 

coaching and counseling would be additional responsibilities, Ms. Bressack indicates that her 

communication was that such responsibilities would continue to be part of her job. 

9. When asked about the claim that at a HFHS University Staff meeting on January 31, 2013 that 

Monica Rogers received a new job description that now contained the indication that a Sr. 

Consultant would have responsibility for "two or more" system-wide programs, Ms, Bressack 

indicated that this could well be correct. 

i 

! 

1 

ATTACHMENT F 

HF 00422 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.876 Filed 08/01/16 Page 19 of 43
10. Ms. Bressack does not contest Monica Rogers claim that in meeting with her on February 20, 

2013, her performance goals were established and that her Job title did not change. 

11. When asked if Monica Rogers was performing the job duties equal to a Sr. Consultant In January, 

2013, Ms, Bressack indicated "no." She did not provide strategic oversight and was not the 

direct point of contact for senior management for her projects. 

12. When asked if Monica Rogers met the qualification for a Sr. Consultant in January, 2013, Ms. 

Bressack indicated "no." She did not have the required educational qualifications. 

13. When asked if Monica Rogers was treated differently than others because of her race, Ms. 

Bressack responded, "I did not." 

14. When asked if Monica Rogers was treated differently than others because of her age, Ms. 

Bressack responded, "I did not." 

15. When asked if Monica Rogers ever complained of a hostile work environment, Ms. Bressack 

responded, "no." 

2 

HF 00423 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.877 Filed 08/01/16 Page 20 of 43
Notes I and Observations 

Interview with Jan Harrington-Davis 

Harrington-Davis May 13, 2013 

4:00 to 4:30 pm 

D. Champney's Office 

1. Jan Harrington-Davis was interviewed on May 13,2013 with regard to the discrimination 

complaint filed by Monica Rogers. 

2. Ms. Harrington-Davis is the Director of Empbyeo Relations, labor Relation, Compliance and 

Work Force Diversity. She reports having been in this position just shy of two years. She has 

work within the Hf!HS since 2001. Among her varied responsibilities is the Affirmative Action 

Program for which she serves as the Diversity Officer. 

3. Ms. Harrington-Davis recalls talking to Monica Rogers about her concerns regard discrimination 

on several occasions. These Included one-on-one meetings, meeting with both her and her 

management and other more brief conversations. 

4. Ms. Harrington-Davis acknov/ledges Monica Rogers' recount that they had a one-on-one 

meeting in the time frame between December 1 and January 3'i, 2013 concerning her concerns. 

Ms. Harrington-Davis recalls that part of their conversation related to past Issues Involving 

Monica and a former HR VP in which there was an allegation that he would not let her work on a 

matter because of her race. Ms. Harrington-Davis believes Monica filed a formal complaint with 

regard to this matter, 

Ms, Harrington-Davis relates that this conversation also dealt with Monica's concerns that she 

was performing the same work as those in the Sr. Consultant position. When asked if she had 

indicated to Monica that her current discrimination claim "has nothing to do with your age, it's 

because of your race" Ms. Harrington-Davis indicates that: (l)she was referring to this past 

incident; (2) she was asking a question as opposed to making a statement; and (3) she does not 

recali any reference to age. 

5. Ms. Harrington-Davis acknowledges that Monica Roger's statement that there was a meeting on 

January 23, 2013 with Laurie Jensen, Monica Rogers and herself is probably correct, since Ms. 

Harrington-Davis recalls her sister having a medical procedure at this time. Ms, HarringtonDavis does not know exactly how this meeting was scheduled, but remembers that Monica 

Rogers had called her to tell her that such a meeting was scheduled. Ms, Harrington-Davis 

recalls that Monica Rogers talked about doing the job of both the Consultant and Sr. Consultant 

jobs and that she compared herself to others in the two positions. Ms, Harrington-Davis also 

acknowledges that she did indicate her opinion that Monica Rogers was working at a Sr. 

Consultant level and that she felt the job description should be amended to clarify the two 

positions, i.e. Consultant and Sr. Consultant and/or have the Sr. Consultant job description have 

"degree preferred" language. However, Ms, Harrington-Davis did not recommend Monica 

ATTACHMENT G 

HF 00424 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.878 Filed 08/01/16 Page 21 of 43
being place into the Sr. Consultant job as written, since the )ob description required a master 

degree and Monica did not have a college degree. Ms. Harrington-Davis recalls that Laurie 

Jensen was not receptive to the suggestions with regard to changing clarifying the job 

descriptions. Ms. Harrington-Davis also recalls suggesting that perhaps the pending merger with 

Beaumont might provide an opportunity to address this situation or that Monica could acquire 

her degree. 

5. Ms. Harrington-Davis does not recall any statement being repeated in this conversation related 

to "having only one good job left." 

: 

' 

7. Ms. Harrington-Davis also recalls a short conversation with Monica Rogers a week or two 

following the meeting on January 23,2013. She remembers expressing understanding of 

Monica's concerns, but also expressing to her that either the job description needs to change or 

she needed to acquire a degree. , 

HF 00425 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.879 Filed 08/01/16 Page 22 of 43
Notes and Observations 

Interview with Monica Jackson-Lewis 

May 17, 2013 

1. Monica Jackson-Lewis agreed to meet with me on May 17, 2013 to discuss the discrimination , 

complaint filed by Monica Rogers. 

2. Ms. Jackson-Lewis reported that she currently hold the position of Director of Retention, 

Training and Quality for Client Services at Health Alliance Plan. She has held this position since 

February 8, 2013. 

3. Prior to her position with HAP, Ms. Jackson-Lewis was the Manager of Henry Ford University, 

Employee Development. She held this position for 13 years and has worked within the HFHS 

system for 18 years. 

4. Ms, Jackson-Lewis denies that In a staff meeting on January 16, 2013 she said that to get a "5" 

on your performance review as a Consultant that you had to perform the duties of a Sr. 

Consultant. Rather, she would have expressed that to get above a "3" would you have to 

perform above what you normally do. 

5. Ms. Jackson-Lewis agrees with Ms. Rogers that she had a one-on-one meeting with Ms. Rogers 

on February, 4, 2013. She indicates that Ms. Rogers asked to talk to her prior to her reporting to 

her new job at HAP with regard to recent changes in Ms. Rogers' department. 

Ms. Jackson-Lewis explained that Ms. Rogers used to report to her working in the Employment 

Engagement area, but she had asked and had been placed in the Leadership Development area. 

6. Ms. Jackson -Lewis also volunteered that while working for her; Ms. Rogers had some 

performance issues and was In fact on a Performance Improvement Plan due in large part to her 

difficulty in accepting Ms. Jackson-Lewis' management. However, her performance improved 

and she and Ms. Laurie Jensen granted Ms. Rogers request to be place in Leadership 

Development, 

7. At the February 4

,h meeting, Ms. Jackson-Lewis reports that Ms. Rogers was concerned that she 

was performing work (Leadership Academy) that used to be led by a Sr. Consultant, but she 

remained a Consultant. Ms. Jackson-Lewis reports that she told Ms. Rogers that this was likely a 

result of the structural changes in her department. Ms. Jackson-Lewis further reports that she 

indicated to Ms, Rogers that she couldn't be put Into the Sr. Consultant position because she 

didn't have a degree. When Ms. Rogers asked her what she should do, Ms. Jackson-Lewis 

responded by saying "just do your job," 

8. With regard to Ms. Roger's statement that Ms. Jackson-Lewis had said that "there are always 

ways around the education requirement, we have done it before," Ms, Jackson-Lewis denies 

every saying that. Ms, Jackson-Lewis believed Ms, Roger might have been referring to Brian 

Robertson- a white male- who is a Consultant, but who doesn't have a degree, Ms. JacksonLewis relates that it was Ms. Roger who actually made this statement concerning the 

educational requirement. 

: 

ATTACHMENT H 

HF 00426 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.880 Filed 08/01/16 Page 23 of 43
9. With regard to Ms. Roger's statement that Ms. Jackson-Lewis had said that once you have the 

new job responsibilities in writing, copies of the new job description and copies of the old job 

description, this would give her everything she needs and she would do what you have to do, 

Ms. Jackson-Lewis denies making this statement in this meeting. Ms. Jackson-Lewis volunteered 

that Ms. Rogers referenced a prior incident of sexual harassment at HFHS and that she may now 

feel a sense of entitlement based on those facts. Ms. Rogers said she had talked to her son and 

he had advised her to talk to an attorney. Ms. Jackson-Lewis suggested that Ms. Rogers do her 

job. 

10. When asked if Ms. Rogers was performing at the level of Sr. Consultant in January, 2013, Ms. 

Jackson-Lewis said that she was performing as a Consultant, not a Sr. Consultant. 

11. When asked if Ms. Rogers was qualified to be a Sr. Consultant in January, 2013, Ms, JacksonLewis indicated that she was qualified except for her educational level. 

12. When asked in Ms. Roger was treated unfairly because of her race, Ms. Jackson-Lewis Indicated 

no. 

13. When asked in Ms. Roger was treated unfairly because of her age, Ms. Jackson-Lewis indicated 

no. 

! 

HF 00427 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.881 Filed 08/01/16 Page 24 of 43
•i 

MEAUTt* SYSTEM 

• 

JOB DESCRIPTION 

Ws7rt»ieis*iK5s 

Consultant - OHRD 

F01207 

Exempt 

February 2007 

Job Title: 

Job Code: 

FLSA Status: 

Date; 

aaisaesss&ffi 

GENERAL SUMMARY: 

Under limited supervision, conducts training/development needs analyses and 

assessments on an organizational, and/or individual basis, and develops and 

implements specified training and development programs and initiatives to meet 

assessed needs. , 

PRINCIPAL DUTIES AND RESPONSIBILITIES: 

1. Conducts individual, group, and organization-based training and development needs 

analyses and assessments. 

2. Based on assessed need, plans, develops, and delivers or coordinates the delivery 

of individual and/or group training and instructional programs, encompassing a wide 

range of technical, operational, management, and/or other skills areas. 

3. Develops or oversees the development of training curricula; formulates or reviews 

training outlines, and determines appropriate instructional methodologies and 

formats; evaluates and recommends incorporation of vendor programs, as 

appropriate to meet overall training goals and objectives. 

4. Work with TES and instructional design team to develop and execute System 

solutions. 

5. Oversees and coordinates the development and preparation of teaching and visual 

aids, instructional materials, computer tutorials, and reference materials appropriate 

to specific program objectives. 

6. As appropriate to the individual position, coordinates, facilitates, and/or conducts 

specified development activities, such as planning retreats, team building programs, 

organization analyses, or restructuring exercises. 

7. Evaluates effectiveness of training and development programs and utilizes relevant 

evaluation data to revise or recommend changes in instructional objectives and 

methods. 

A TTACHMENT J HF 00437 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.882 Filed 08/01/16 Page 25 of 43
TITLE: Consullant - OHRI) F0I207 Page: 2 of 3 

8. Coordinates work flow and administrative activities necessary to deliver and 

document unit programs and activities. 

9. Provides input and assists in the planning, assessment, and implementation of 

organizational goals and objectives, in line with overall department goals and 

objectives. 

10. Performs miscellaneous job-related duties as assigned. 

EDUCATION/EXPERIENCE REQUIRED: 

• Bachelor's degree 

o At least 3 years of work experience that can be demonstrated to be applicable to the 

duties listed In the job description. 

0 Knowledge and understanding of adult learning principles, and of a wide range of 

training methods, techniques, and formats. 

« Skill in organizing resources and establishing priorities. 

« Ability to determine training objectives, 

a Ability to provide technical leadership to external and internal constituencies. 

• Knowledge of organization development principles and processes, methods, and 

techniques. 

• Advanced verbal and written communication skills. 

: 

o Skills in facilitating and leading strategic planning and organizational development 

interventions. 

o Knowledge of curriculum development and preparation procedures. 

• Ability to interpret and assess training and development needs and to develop 

appropriate and creative responses. 

• Ability to design, develop, implement, and evaluate training plans, curricula, and 

methodology. 

o Strong interpersonal and communication skills and the ability to work effectively with 

a wide range of constituencies in a diverse community. 

Must meet or exceed core customer service responsibilities, standards and behaviors 

as outlined in the HFHS' Customer Service Policy and summarized below: 

Ownership 

Motivation 

Excellence 

Respect 

Communication 

Understanding 

Sensitivity 

Teamwork 

Must practice the customer skills as provided through on-going training and in-servlces. 

t 

HF 00438 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.883 Filed 08/01/16 Page 26 of 43
TITLE; Consullant - OimD FQI207 Page: 3 of 3 

Must possess the following personal qualities; 

Be self-directed 

Be flexible and committed to the team concept 

Demonstrate teamwork, initiative and willingness to learn 

Be open to new learning experiences 

Accepts and respects diversity without judgment 

Demonstrates customer service values 

PHYSICAL DEMANDS/WORKING CONDITIONS: 

Norma! office environment with minimal exposure to noise, dust, or extreme 

temperatures. 

Moderate physical activity. Requires handling of average-weight objects up to 25 

pounds or standing and/or walking for more than four (4) hours per day. 

APPROVED BY: 

DEPARTMENT HEAD: DATE: 

HUMAN RESOURCES: DATE: 

The above statements are Intended to describe the general nature and level of work being performed by 

people assigned to this classification. They are not intended to be construed as an exhaustive list of all 

responsibilities and duties of personnel so classified. 

. HF 00439 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.884 Filed 08/01/16 Page 27 of 43
w 

JOB DESCRIPTION 

Job Title; 

Job Code; 

FLSA Status: 

Sr Consultant - OHRD 

F01208 

Exempt 

Februafy 2007 

: 

Date: 

GENERAL SUMMARY: 

Provide project management, leadership coaching and organizational development 

expertise to achieve service and performance excellence across Henry Hord Health 

System. Works with leaders to bridge the gap between the strategic vision and the 

organization's current performance and culture. Includes organizational 

assessment/analysis, leadership development, change management, organizational 

design/structure, customer service, process improvement, organizational learning and 

strategy execution. 

PRINCIPAL DUTIES AND RESPONSIBlLITiES: 

1. Support/manage System wide HR planning initiatives such as performance 

management, and succession planning. 

2. Design, build and oversee leadership development programs. 

3. Supports/manage development and execution of the HFHS Leadership Academy 

for top performers. 

4. Supports/manage development and execution of the HFHS New Leader Orientation. 

5. Works with business unit leaders to support System integration and the Henry Ford 

Experience. 

6. Facilitates leadership assessments and development plans, 

7. Consults with senior leadership on high priority organizational and change initiatives 

and interventions. 

8. Support/manage executive coaching and mentoring relationships and programs. 

9. Performs miscellaneous Job-related duties as assigned. 

ATTACHMENT K HF 00440 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.885 Filed 08/01/16 Page 28 of 43
TITLE; SrConsultant-OHRO F0I208 Page: 2 of 3 

EDUCATION/EXPERIENCE REQUIRED: 

» MBA, MA, or MS in Organizational Development (OD). Human Resources or related 

field. 

•> Three to five year's management/or Human Resource professional level experience. 

.. Strong interpersonal, communication (oral, written and listening) and presentation 

skills. Applied knowledge of OD theories, methods and processes including change 

management, organizational behavior, performance management and leader 

development. 

e Ability to interact with senior leadership 

<> Excellent project management skills 

• Excellent presentation and facilitation skills 

• Excellent written and communication skills 

« Skilled in organizing and integrating information 

o Extremely high standards for personal integrity: ability to preserve confidentiality of 

highly sensitive information. 

• Self-directed and takes Initiative. 

Must meet or exceed core customer service responsibilities, standards and behaviors 

as outlined in the HFHS' Customer Service Policy and summarized below: 

Ownership 

Motivation 

Excellence 

Respect 

Communication 

Understanding 

Sensitivity 

Teamwork 

Must practice the customer skills as provided through on-going training and in-services. 

Must possess the following personal qualities; 

Be self-directed 

Be flexible and committed to the team concept 

Demonstrate teamwork, initiative and willingness to learn 

Be open to new learning experiences 

Accepts and respects diversity without judgment 

Demonstrates customer service values 

HF 00441 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.886 Filed 08/01/16 Page 29 of 43
TITLE: Sr Consultant - OHRD FO1208 Page: 3 of 3 

PHYSICAL DEMANDS/WORKING CONDITIONS: 

Normal office environment with minimal exposure to noise, dust, or extreme 

temperatures. Moderate physical activity. Requires handling of average-weight objects 

up to 25 pounds or standing and/or walking for more than four (4) hours per day. 

APPROVED BY; 

DEPARTMENT HEAD: DATE: 

HUMAN RESOURCES: DATE: 

The above statements are intended to describe the general nature and level of work being performed by 

people assigned to this classification. They are not intended to be construed as an exhaustive list of all 

responsibilities and duties of personnel so classified. 

HF 00442 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.887 Filed 08/01/16 Page 30 of 43
• i 1 1 

HEALTH SYSTEM 

i 

JOB DESCRIPTION 

Sr Consultant - OHRD 

Organizational Human Resources Development 

1 Ford Place 

Reports To: Director Organizational and HR Development, Engage and 

Retain Center of Excellence 

FLSA Status: Exempt 

Prepared By: 

Prepared Date: 

Job Code: 

Pay Grade: 

Job Title: 

Department: 

Location: 

February 2010 

F01208 

B70 

GENERAL SUMMARY: 

Provide project management, leadership coaching and organizational 

development expertise to achieve service and performance excellence across 

Henry Ford Health System. Works with leaders to bridge the gap between the 

strategic vision and the organization's current performance and culture. Includes 

organizational assessment/analysis, leadership development, change 

management, organizational design/structure, customer service, process 

improvement, organizational learning and strategy execution. 

PRINCIPAL DUTIES AND RESPONSIBILITIES: 

1, Support/manages/ and/or consults on System wide HR planning initiatives 

such as performance management, employee engagement, retention 

strategies, onboarding, and succession planning. 

2. Design, build and oversee leadership development programs. 

3. Designs and executes Organizational Development Consulting 

model/initiative. 

4. Designs and executes HFHS Coaching strategy. 

5. Works with business unit leaders to support System integration and the 

Henry Ford Experience. 

6. Facilitates leadership assessments and development plans. 

7. Facilitates strategic planning, team building, and change management 

retreats. 

8. Consults with senior leadership on high priority organizational and change 

initiatives and interventions. 

9. Support/manage executive coaching and mentoring relationships and 

programs 

ATTACHMENT L HF 00443 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.888 Filed 08/01/16 Page 31 of 43
TITLE: Sr Consullant - OHRD FO1208 Page: 2 of 3 

10. Performs miscellaneous job-related duties as assigned that are aligned to 

Department's achievement of goals and business outcomes for HFHS. 

KNOWLEDGE. SKILLS AND ABILITIES REQUIRED: 

MINIMUM EDUCATION; 

MBA, MA, or MS in Organizational Development (OD). Human Resources or 

related field. 

MINIMUM EXPERIENCE; PREFERRED EXPERIENCE 

Three to five year's management/or Human Resource professional level 

experience. 

Strong interpersonal, communication (oral, written and listening) and 

presentation skills. Applied knowledge of OD theories, methods and processes 

including change management, organizational behavior, performance 

management and leader development. 

o Ability to interact with senior leadership 

<• Excellent project management skills 

o Excellent presentation and facilitation skills 

o Excellent written and communication skills 

o Skilled in organizing and integrating information 

o Extremely high standards for personal integrity; ability to preserve 

confidentiality of highly sensitive information. 

o Self-directed and takes initiative. 

Must meet or exceed core customer service responsibilities, standards and 

behaviors as outlined in the HFHS' Customer Service Policy and summarized 

below: 

Ownership 

Motivation 

Excellence 

Respect 

Communication 

Understanding 

Sensitivity 

Teamwork 

Must practice the customer skills as provided through on-going training and 

inservices. 

Must possess the following personal qualities: 

Be self-directed 

Be flexible and committed to the team concept 

Demonstrate teamwork, initiative and willingness to learn 

Be open to new learning experiences 

HF 00444 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.889 Filed 08/01/16 Page 32 of 43
TITLE; Sr Consullant - QHRD F01208 Page: 3 of 3 

0 Accepts and respects diversity without judgment 

» Demonstrates customer service values 

WORKING CONDITIONS: 

Normal office environment with minimal exposure to noise, dust, or extreme 

temperatures. Moderate physical activity. Requires handling of average-weight 

objects up to 25 pounds or standing and/or walking for more than four (4) hours 

per day. 

APPROVED BY: 

DEPARTMENT HEAD: DATE: 

HUMAN RESOURCES: DATE: 

The above statements are intended to describe the general nature and level of work being 

performed by people assigned to this classification, They are not intended to be construed as an 

exhaustive list of all responsibilities and duties of personnel so classified. 

i 

HF 00445 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.890 Filed 08/01/16 Page 33 of 43
Job Title; Consultant - OHRD 

Job Code: F01207 

FLSA Status: Exempt 

Date; February 2007 (reviseci 1/2013) 

GENERAL SUMMARY: 

Under the direction of the supervisor of the department and with high degree of 

autonomy, the OHRD Consultant Wlli work independently or as a Project leader to 

manage wock of a medium to complex nature. The OHRD consultant will plan, organize 

and coordinate project task completions with individuals and teams of professionals at 

other levels, as well leaders and outside contractors while developing solutions for 

business opportunities/ challenges. They will team up with experts from other disciplines 

inside and outside HFHS; conducts training/development needs analyses and 

assessments on an organizational, and/or individual basis, and develops and 

implements specified training and development programs and initiatives to meet 

assessed needs; and work effectively with other members of team and promote a 

healthy high performing work environment. 

PRINCIPAL DUTIES AND RESPONSIBILITIES; 

1. Responsible for leading or supporting one or more project teams/initiatives. 

2. Conducts individual, group, and organization-based training and development, needs 

analyses, and assessments. Facilitates training or programs as needed. 

3„ Based on assessed need, plans, develops, and delivers or coordinates the delivery of 

individual and/or group training and instructional programs, encompassing a wide range of 

technical, operational, management, and/or other skills areas. 

4.. Develops or oversees the development of training curricula; formulates or reviews training 

outlines, and determines appropriate instructional methodologies and formats; evaluates and 

recommends incorporation of vendor programs, as appropriate to meet overall training goals 

and objectives, 

5. Oversees and coordinates the development and preparation of teaching and visual aids, 

instructional materials, computer tutorials, and reference materials appropriate to specific 

program objectives. 

6. Coordinates, facilitates, and/or conducts specified development activities, such as planning 

retreats, team building programs, organization analyses, or restructuring exercises. 

7. Evaluates effectiveness of training and development programs and utilizes relevant 

evaluation data to revise or recommend changes in instructional objectives and methods. 

S. Coordinates work flow and administrative activities necessary to deliver and document unit 

programs and activities. 

9. Provides input and assists In the planning, assessment, and implementation of organizational 

goals and objectives, in line with overall department goals and objectives. 

ATTACHMENT M HP 00446 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.891 Filed 08/01/16 Page 34 of 43
10. Performs miscellaneous job-related duties as assigned. 

EDUCATION/EXPERIENCE REQUIRED: 

Bachelor's degree 

At least 3 years of work experience that can be demonstrated to be applicable to the duties 

listed in the job description. 

Knowledge and understanding of adult learning principles, and of a wide range of training 

methods, techniques, and formats. 

Skill in organizing resources and establishing priorities. 

Ability to determine training objectives. 

Ability to provide technical leadership to external and internal constituencies. 

Knowledge of organization development principles and processes, methods, and techniques. 

Advanced verbal and written communication skills. 

Skills in facilitating and leading strategic planning and organizational development interventions. 

Knowledge of curriculum development and preparation procedures. 

Ability to interpret and assess training and development needs and to develop appropriate and 

creative responses. 

Ability to design, develop, implement, and evaluate training plans, curricula, and methodology. 

Strong interpersonal and communication skills and the ability to work effectively with a wide 

range of constituencies in a diverse community. 

Must meet or exceed core customer service responsibilities, standards and behaviors as 

outlined in the HFHS" Customer Service Policy and summarized below: 

n Communication n Ownership 

Understanding U Motivation 

G Sensitivity 0 Excellence 

L Teamwork U Respect 

Must practice the customer skills as provided through on-going training and in-services. 

HF 00447 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.892 Filed 08/01/16 Page 35 of 43
Must possess the following personal qualities; 

• Be self-directed 

D Be flexible and committed to the team concept 

• Demonstrate teamwork, initiative and willingness to learn 

• Be open to new learning experiences 

• Accepts and respects diversity without judgment 

• Demonstrates customer service values 

PHYSICAL DEMANDS/WORKING CONDITIONS: 

Normal office environment with minimal exposure to noise, dust, or extreme temperatures. 

Moderate physical activity. Requires handling of average-weight objects up to 25 

pounds or standing and/or walking for more than four (4) hours per day. 

HF 00448 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.893 Filed 08/01/16 Page 36 of 43
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2012 Employee Performance Plan & Review tor Monica J. Rogers rageo or 3 

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HF 00421 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.898 Filed 08/01/16 Page 41 of 43
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Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.899 Filed 08/01/16 Page 42 of 43
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No - Brian's position was restructured from 

a Training Analyst position in Tedwica! 

Education Services to Consultant in 

Organizational Human Resources 

Development due to the reorganization of 

the departments. No job posting. 

02/2007 Promoted from 

Tratning Analyst 

Info Services to 

Consultant CHRD 12/31/2010 

White Consultant, 

OHRD 

Some 

i College 

No F02I07 Brian 

Bachelor's required 

3 years' work experience 

Robertson 

(meets experience 

requirements) 

10/2007 Yes- No Job posting. Career progression. Promoted from Yes 

Mgr HR to D!r Bachelor's required or min 

HR 9/16/2007 of 8 years of experience as 

HRMgr 

White Director HR L00910 HS Patti 

Sanbeim CCS Graduate 

n/a Yes, at the time of her promotion she was 

the Dir of Volunteers Wyandotte, since then 

her job title has changed because she was 

asked to supervise an additional department. No Job posting. 

No White Promoted due 

to job expansion. Was Dir Vol 

| Serv but 

obtained additional dept. 

Serv Excellence 9/11/2011 

HS Director 

Service Exc and Volunteer Services 

W00074 Carol 

Bridges Bachelor's required 

Master's preferred 

Graduate 

(meets experience 

requirements) 

job Req 1 

63053 

Yes Promoted from 

Employee Services Rep to 

E-HR Analyst 8/14/2011 

Yes 2 year 

Coliege 

Degree 

White FOSSIS e-HR Analyst Tara 

Boufford Bachelors required or 

experience considered in lieu of education requirement (meets experience 

requirements) 

Yes. No Job posting. Career progression. Promoted from 

Sr. Rep to Sr. 

i Consultant 

1 OHRD 

8/1/201C ' 

Bachelor's Degree 

White Yes Nicole 

Logan 

Sr. F02704 

Bachelors required 

Masters preferred 3-5 years comp/beneRts 

admin experience 

Compensation 

Consultant 

Job Req 

72959 

Yes Promoted from 

HR Business Partner to HR 

Director 11/18/2012 

White Yes Bachelor's 

Degree 

Debra 

Temrowski 

HR Director LOS284 

i Bachelor's required 

Master's preferred 7 years exp 

1 year leadership i. 

ATTACHMENT N HF 00449 

Case 2:15-cv-12312-MOB-EAS ECF No. 48-20, PageID.900 Filed 08/01/16 Page 43 of 43