P.E.R.C. No. 2026-2, Hamilton Tp

Notice to employeesNOTICE TO EMPLOYEES PURSUANT TO AN ORDER OF THE PUBLIC EMPLOYMENT RELATIONS COMMISSION AND IN ORDER TO EFFECTUATE THE POLICIES OF THE NEW JERSEY EMPLOYER-EMPLOYEE RELATIONS ACT, AS AMENDED, We hereby notify our employees that: ¶

CaptionSTATE OF NEW JERSEY BEFORE THE PUBLIC EMPLOYMENT RELATIONS COMMISSION In the Matter of HAMILTON TOWNSHIP, Respondent, -and- Docket No. CO-2024-193 POLICEMAN’S BENEVOLENT ASSOCIATION LOCAL 66 & POLICEMAN’S BENEVOLENT ASSOCIATION LOCAL 66A, Charging Parties. ¶

SynopsisSYNOPSIS ¶

The Public Employment Relations Commission grants a motion for summary judgment filed by the charging parties, PBA Locals 66 and 66A (PBA) on the PBA’s unfair practice charge alleging respondent Hamilton Township violated the Act by unilaterally changing a past practice affecting healthcare benefits provided to certain PBA members upon retirement. The Commission finds the Township’s undisputed provision of two months of no-cost health insurance to numerous PBA members upon retirement over a five- year period qualifies as a past practice establishing an enforceable term and condition of employment. The Commission further finds that because health benefits are mandatorily negotiable, the Township was obliged to negotiate with the PBA before implementing any changes to the practice, absent statutory or regulatory preemption. The Commission rejects respondent’s contention that the disputed practice was “illegal” and “unauthorized,” because the Township identified no statute, regulation, or other authority that the practice might materially violate. Finally, the Commission finds that at the time the Township sought to implement the change, the benefit was fully negotiable under Chapter 78 and was not violative of that act. ¶

This synopsis is not part of the Commission decision. It has been prepared for the convenience of the reader. It has been neither reviewed nor approved by the Commission. ¶

CaptionSTATE OF NEW JERSEY BEFORE THE PUBLIC EMPLOYMENT RELATIONS COMMISSION In the Matter of HAMILTON TOWNSHIP, Respondent, -and- Docket No. CO-2024-193 POLICEMAN’S BENEVOLENT ASSOCIATION LOCAL 66 & POLICEMAN’S BENEVOLENT ASSOCIATION LOCAL 66A, Charging Parties. ¶

AppearancesAppearances: ¶

For the Respondent, Elissa Grodd Schragger, Township Attorney ¶

For the Charging Parties, Crivelli, Barbati & DeRose, LLC, attorneys (Donald C. Barbati, of counsel) ¶

DECISION ¶

In this matter we consider a motion for summary judgment filed by the charging parties, PBA Locals 66 and 66A, Superior Officers Association (SOA), (collectively, PBA), on their unfair practice charge against the respondent, Hamilton Township (Township). The PBA’s charge initially alleged the Township’s unilateral change to a past practice, by reducing from two months to one the duration of free healthcare benefits provided to certain PBA members upon retirement, effective July 1, 2024, violated sections 5.4a(1), (5) and (7) of the New Jersey Employer-Employee Relations Act, N.J.S.A. 34:13A-1, et seq. (Act).1/ ¶

The PBA filed its charge on June 18, 2024, together with an application for interim relief. Following briefing and oral argument, a Commission Designee granted temporary restraints on July 24. I.R. No. 2025-1, 51 NJPER 75 (¶19 2024). On August 9, 2024, the PBA withdrew its 5.4a(7) claim.2/ On October 1, the Director of Unfair Practices issued a complaint on the remaining claims. ¶

The PBA’s summary judgment motion, filed on February 24, 2025, is supported by a brief, exhibits, and the certifications of: Timothy Young, President of Local 66; Stepehen Ligato, former President of Local 66A; and PBA counsel Donald C. Barbati. On May 29, the Township filed opposition, supported by a brief, exhibits, and the second certification of Kathryn Monzo, the Township’s Business Administrator.3/ On June 2, the PBA’s motion was referred to the full Commission, pursuant to N.J.A.C. 19:14- 4.8(a). ¶

By way of background, Young certifies that as President of Local 66 he has served in that position at all times relevant to this matter. (Young Cert., ¶1.) Ligato certifies that, as a former President of Local 66A, he likewise served in that capacity at all relevant times. (Ligato Cert., ¶1.) Monzo certifies that she has served as the Township’s Business Administrator since May of 2020, when she was first appointed by Mayor Jeff Martin and confirmed by the full Township Council. (Monzo 1st and 2d Certs., ¶2.) ¶

Local 66 exclusively represents patrol officers and detectives, while Local 66A exclusively represents sergeants, lieutenants, and captains, for purposes of collective negotiations between the PBA and the Township concerning salaries, wages, hours and other terms and conditions of employment of officers employed by the Township Police Department. The Township is a party with each Local to respective collective negotiations agreements (CNAs), each effective from January 1, 2020, through December 31, 2024. The parties are currently in negotiations for successor agreements. ¶

The Township’s Employee Handbook states that employees who separate from Township employment for certain reasons including retirement will receive one calendar month of health benefits coverage immediately following their termination date. The parties’ 2020-2024 CNAs are silent on this subject. They require certain retirees to contribute to their post-retirement health insurance benefits, including by reference to “Chapter 78” rates, but they contain no provisions explicitly addressing post- retirement coverage during the 30 to 60 days immediately following a retiring officer’s last day of employment. ¶

Effective June 28, 2011, P.L. 2011, c.78 (Chapter 78) required non-exempt public employees and retirees (i.e. those with less than 20 years of creditable service as of June 28, 2011) to contribute to the cost of their healthcare benefits coverage, paying a share of the premium based upon their salary/retirement allowance. This contribution scheme was implemented over four years, with each employee/retiree paying the full rate in year four. N.J.S.A. 40A:10-21.1(a) and (b)(1). These requirements went into effect on either June 28, 2011, or upon the expiration of any applicable CNA then in effect. N.J.S.A. 40A:10-21.1(a). They expired four years later, or upon the expiration of the CNA in which year-4 rates were reached. P.L. 2011, c.78, § 83. Health benefits contributions are fully negotiable in the next CNA thereafter. N.J.S.A. 40A:10-21.2. ¶

Monzo certifies that on July 1, 2019, two months of free health insurance was first given to a police officer upon retirement “during the last Administration,” to an officer who had served “on the private security detail for the then Mayor.” (Monzo 1st Cert., ¶14; 2d Cert., ¶10.) Monzo further certifies that other officers subsequently received “the 2 months free” at “the unauthorized direction of the [previous] Personnel Director [unnamed].” 4/ (Monzo 2d Cert., ¶11.) Monzo certifies that the personnel division was directed to “cease overruling the manual” once she and the Mayor learned, on a date not specified, of these “ultra vires acts” of the previous Personnel Director. (Id., ¶12.) ¶

THE SUMMARY JUDGMENT STANDARD ¶

Summary judgment will be granted if there are no material facts in dispute and the movant is entitled to relief as a matter of law. Brill v. Guardian Life Ins. Co. of America, 142 N.J. 520, 540 (1995); Judson v. Peoples Bank & Trust Co., 17 N.J. 67, 73-75 (1954). N.J.A.C. 19:14-4.8(e) provides: ¶

If it appears from the pleadings, together with the briefs, affidavits and other documents filed that there exists no genuine issue of material fact and that the movant or cross-movant is entitled to its requested relief as a matter of law, the motion or cross-motion for summary judgment may be granted and the requested relief may be ordered. ¶

In determining whether there exists a “genuine issue” of material fact that precludes summary judgment, we must “consider whether the competent evidential materials presented, when viewed in the light most favorable to the non-moving party, are sufficient to permit a rational fact finder to resolve the alleged disputed issue in favor of the non-moving party.” Brill, 142 N.J. at 540. We “must grant all the favorable inferences to the non-movant.” Id. at 536. A motion for summary judgment should be granted with extreme caution and may not be substituted for a plenary trial. Baer v. Sorbello, 177 N.J. Super. 183, 185 (App. Div. 1981), certif. denied, 87 N.J. 388 (1981). Summary judgment “should be denied unless the right thereto appears so clearly as to leave no room for controversy.” Saldana v. DeMedio, 275 N.J. Super. 488, 495 (App. Div. 1995). ¶

Applying the above standards to the undisputed material facts in the record (set forth below and viewed in a light most favorable to the non-moving party), we grant the PBA’s motion for summary judgment, as further detailed infra. ¶

UNDISPUTED MATERIAL FACTS ¶

1. The parties here were under contract on June 30, 2011, so they did not commence Chapter 78 contributions until July 1, 2013. They completed full implementation by June 30, 2017.5/ The applicable agreements that were in effect at that time covering each Local expired on December 31, 2019. (See Fact 6, infra.) ¶

2. The parties’ 2020-2024 CNAs contain identical provisions addressing the subject of retiree health benefits. (Barbati Cert., Ex. A and B; 2020-2024 CNAs, Article 22, Section 1a(1-6).) These make post-retirement health benefits available to employees “upon retirement and 25 years of creditable service.” ¶

3. Under the 2020-2024 CNAs, such employees are not required to contribute to their post-retirement health benefits if they also had “20 or more years of creditable service in a pension system as of June 28, 2011,” the effective date of Chapter 78. ¶

4. Under the 2020-2024 CNAs, otherwise-eligible retirees with fewer than 20 years of creditable service as of June 28, 2011, are required to pay a healthcare contribution, depending on when they retire, of either: 6% of their pension salary; or the greater of “year 4” of “the Ch. 78 grid” or “1.5% of their pension.” (2020-2024 CNAs, Article 22, Section 1a(3).) ¶

5. Both the 2020-2024 CNAs, at Article 35(3) of each, state: “Proposed new rules or modifications of existing rules governing working conditions shall be negotiated with the [PBA and SOA] before they are established.” (Barbati Cert., Ex. A and B.) ¶

6. The record contains copies of: the January 1, 2017, through December 31, 2019, CNA for Local 66; the January 1, 2017, through December 31, 2018, CNA for Local 66A; and a memorandum of agreement (MOA) addressing a wage increase for Local 66A covering the period from January 1 through December 31, 2019. (Monzo 1st Cert., Ex. A, B and C.) These agreements required no healthcare contribution either from then-current retirees or then-current retiring employees with 20+ years of service as of June 28, 2011. Future retirees with less than 20 years as of that date were required to pay the greater of the Chapter 78 “contribution schedule” or 1.5% of their pension. ¶

7. Except as provided to retiring employees who had 20 years of creditable service as of June 28, 2011, the subject of the provision of “free” health care benefits (for any period of time after retirement) is not addressed in the parties’ 2020-2024 CNAs or the prior agreements in the record. ¶

8. The record contains copies of the Townhip’s Employee Handbooks from 2022 (Township’s Answer to Charge, Ex. A) and 2010 (Monzo 2d Cert., Ex. A). Each contains the following provision: ¶

Employees who separate from employment, whether by retirement, resignation, sabbatical or leave of absence etc., will be covered for one (1) calendar month immediately following their termination date. ¶

[(Employee Handbooks, Section B, Health Benefits.)] ¶

9. The record contains a copy of a spreadsheet submitted by the Township “reflecting police officers who either retired or left employment with the Township for other reasons,” covering a period of time from March 1, 2010, through June 1, 2024. (Monzo 1st Cert., ¶10 and Ex. D.) Both parties refer to and rely upon the information contained in it. (Id., ¶ ¶11, 14-15; Monzo 2d Cert., ¶ ¶9-11; Young Cert., ¶ ¶9-13; Ligato Cert., ¶ ¶9-13.) ¶

10. The spreadsheet indicates that from March 1, 2010, through May 1, 2019, a total of 71 officers left Township employment, seven of whom received “one free month” of health insurance, presumably pursuant to Section B of the Employee Handbook. (Monzo 1st Cert., Ex. D.) The rest received “free insurance,” presumably because they had no contribution obligation under the CNAs. (Id.) ¶

11. The spreadsheet further indicates that from July 1, 2019, though June 1, 2024, a total of 41 officers left Township employment, 23 of whom received “2 months free” insurance. (Monzo 1st Cert., Ex. D.) The rest received “free insurance.” 6/ (Id.) ¶

12. On February 9, 2024, the Township issued a memorandum entitled “Health Care After Separation or During Leave Without Pay” addressed to all active employees. As it pertained to retiring employees or those who resign in good standing, it stated: ¶

After careful consideration, please be advised that the prior policy of continuing health care (medical, prescription, vision and dental) for any employee who separates employment from Hamilton Township will be modified as of July 1, 2024. As of that date, insurance coverage for those who retire early or under special circumstances or resign in good standing will be carried only to the end of the month in which you separate. Retirement separation is the last day of the month in which you work. ¶

NOTE- This change does not affect retirement benefits that a true retiree would receive. This change will only affect the period of no cost insurance prior to your receipt of retirement benefits. ¶

[(Barbati Cert., Ex. C.)] ¶

13. Young and Ligato certify that in response to the Township’s February 9 memorandum, “the Charging Parties advised the Township [that] they adamantly opposed any alteration and modification of the current practice of providing members with two (2) months of continued health care coverage free of charge after their separation from employment in the absence of negotiation.” (Young Cert., ¶23; Ligato Cert., ¶23.) ¶

14. On April 11, 2024, the Township issued a second memorandum, also entitled “Health Care After Separation or During Leave Without Pay,” addressed to all active employees. In pertinent part, this document repeated the first and second paragraphs of the February 9 memorandum (quoted supra) and added the following: ¶

After July 1, 2024, a “true” retiree (defined as an employee who retires with 25 years of pensionable service with at least the last three years in the employ of Hamilton Township) will receive one month of the above coverage for one month [(sic)] meaning if you retire effective July 1, 2024 we will carry the insurance until July 31, 2024. The Township, upon approval of the Business Administrator or his/her designee, may expand this time under extraordinary circumstances. ¶

[(Barbati Cert., Ex. D.)] ¶

15. Young and Ligato certify that the PBA filed the instant unfair practice charge and request for interim relief after the Township “confirmed its intention to alter and/or modify its prior policy . . . to include” PBA members. (Young, Ligato Certs., ¶ ¶33, 36.) ¶

PARTIES’ ARGUMENTS ¶

The PBA argues that the Township’s practice of providing PBA members (who were not otherwise eligible for a contribution exemption) with two months of free healthcare coverage after separating from employment is a valid, viable, and controlling past practice, notwithstanding the absence of relevant contract language. The PBA argues that this practice was: (1) unequivocal; (2) clearly enunciated and acted upon; (3) occurring for five years; and (4) a fixed practice relied upon by both parties. The PBA stresses that the practice occurred over the course of two CNAs between the Township and the Charging Parties and was followed by not only the prior administration, but the current one as well. ¶

The PBA further argues that health benefits are a mandatorily negotiable subject, and that the period of no cost insurance coverage when a member separates from employment with the Township constitutes a negotiable level of compensation and benefits for the Charging Parties’ members. The PBA asserts the Township violated the Act when it unilaterally eliminated a portion of this health benefit, by reducing its duration from two months to one, in the absence of negotiation. The PBA argues it is irrelevant whether, as the Township contends, the practice was a type of political favoritism or perk started by the prior administration. ¶

The Township argues it had no obligation to negotiate with the PBA prior to “immediately” ceasing an “illegal” practice. The Township contends it acted pursuant to a managerial prerogative to audit personnel and financial practices in the Township on a regular basis; and to immediately end “unauthorized” practices. The Township argues that the unauthorized extra free month of health insurance post-retirement should not be considered, under the Act, a term and condition of employment requiring negotiation. ¶

ANALYSIS ¶

N.J.S.A. 34:13A-5.4a(5) makes it an unfair practice for an employer, its representatives, or agents not to negotiate in good faith with a majority representative concerning terms and conditions of employment of employees in that unit. Public employers are also prohibited from “[i]nterfering with, restraining or coercing employees in the exercise of the rights guaranteed to them by this Act.” N.J.S.A. 34:13A-5.4a(1). This provision will be violated derivatively when an employer violates another unfair practice provision. Lakehurst Bd. of Ed., P.E.R.C. No. 2004-74, 30 NJPER 186 (¶69 2004). ¶

Public employers have an unconditional duty to negotiate “[p]roposed new rules or modifications of existing rules governing working conditions . . . with the majority representative before they are established.” N.J.S.A. 34:13A- 5.3. (Emphasis added). “[E]mployers are barred from ‘unilaterally altering . . . mandatory bargaining topics, whether established by expired contract or by past practice, without first bargaining to impasse.’” County. of Atlantic, 230 N.J. 237, 252 (2017) (quoting Bd. of Educ. v. Neptune Twp. Educ. Ass’n, 144 N.J. 16, 22 (1996); accord Galloway Twp. Bd. of Educ. v. Galloway Twp. Educ. Ass’n, 78 N.J. 25, 48 (1978)). When a subject is mandatorily negotiable, a public employer is affirmatively obligated to seek negotiations before making any such changes, absent evidence that a majority representative clearly and unequivocally waived its right to negotiate. City of East Orange, P.E.R.C. No. 2020-36, 46 NJPER 318 (¶78 2020) (citing Kean University, P.E.R.C. No. 2018-18, 44 NJPER 221 (¶64 2017)). The majority representative is not required to first prove a severable “impact” or demand negotiations regarding such changes. E. Orange. ¶

Health benefits are mandatorily negotiable unless preempted by statute or regulation. In re Council of New Jersey State College Locals, 336 N.J. Super. 167 (App. Div. 2001), aff’ g P.E.R.C. No. 2000-12, 25 NJPER 402 (¶30174 1999); Willingboro Bd. of Ed., 178 N.J. Super. 477 (App. Div. 1981), aff’ g P.E.R.C. No. 81-2, 6 NJPER 367 (¶11186 1980), certif. den. 91 N.J. 545 (1982); Essex Cty. (App. Div. 2021), aff’ g P.E.R.C. No. 2020-40, 46 NJPER 359 (¶88 2020); E. Rutherford Bor. (App. Div. 2010), aff’ g P.E.R.C. No. 2009-15, 34 NJPER 289 (¶103 2008); and West Orange Bd. of Educ. v. West Orange Educ. Ass’n (App. Div. 1993), aff’ g West Orange Bd. of Ed., P.E.R.C. No. 92-114, 18 NJPER 272 (¶23117 1992). More specifically, we ask not whether a statute or regulation permits an employer to take an action, but whether it precludes the employer from exercising any discretion over an employment condition such that there is nothing left to negotiate. Ridgefield Bd. of Ed., P.E.R.C. No. 2022-45, 49 NJPER 4 (¶2 2022); Somerset County Prosecutor’s Office, P.E.R.C. No. 2023-4, 49 NJPER 117 (¶26 2022). Unions also have “a cognizable interest in ensuring that retired employees receive whatever retirement benefits were contracted for in the agreement that was in effect at the time an employee retired.” Twp. of Voorhees v. Voorhees Police Officers Ass’n (App. Div. 2012), aff’ g Voorhees Tp. P.E.R.C. No. 2012-13, 38 NJPER 155 (¶44 2011). ¶

Terms and conditions of employment may arise from a past practice not contained in a CNA. Ridgefield Bd. of Ed., supra. (citing, New Brunswick Bd. of Ed., P.E.R.C. No. 78-47, 4 NJPER 84 (¶4040 1977) mot. for recon. den., 4 NJPER 56 (¶4073 1978)). The Commission has defined past practice as a course of events “which is repeated, unequivocal, clearly enunciated and acted upon, and readily ascertainable over a reasonable period of time as a fixed and established practice accepted by both parties.” Somerville Boro., P.E.R.C. No. 84-90, 10 NJPER 125, 126 (¶15064 1984). Where a CNA is silent or unclear concerning a particular term, then the parties’ past practice may control. Sussex Cty., P.E.R.C. No. 83-4, 8 NJPER 431 (¶13200 1982). ¶

Here, we find that under our precedent, the Township’s undisputed provision of two months of no-cost health insurance to numerous PBA members upon retirement over a five-year period qualifies as a past practice establishing an enforceable term and condition of employment. Ridgefield Bd. of Ed., Somerville Boro., and Sussex Cty., supra. Because the disputed term and condition of employment established by that practice involves a health benefit, we further find the Township was obliged to negotiate with the PBA before implementing any changes to it, absent statutory or regulatory preemption. In re Council of New Jersey State College Locals, et al, supra. ¶

The Township contends it had no obligation to negotiate because the disputed practice was “illegal” and “unauthorized.” Yet the Township identifies no statute, regulation, or any other authority that the disputed practice might materially violate. Moreover, the Township’s February 9 and April 11, 2024, memorandums announcing a unilateral curtailment of the benefit, effective July 1, 2024, do not state or indicate that the Township’s “careful consideration” of a need to modify its “prior policy” included either a desire to conform that policy to the Employee Manual or to address unauthorized, ultra vires actions of a former Personnel Director. ¶

The effective date of the Township’s intended modification of the policy occurred well after the expiration of the CNAs in effect when the parties completed full implementation of Chapter 78 health benefit contributions. In fact, the Township sought to implement this change during the next CNA thereafter. Thus, at the time the Township sought to implement the change, its provision of two months of free health benefits to certain PBA members upon retirement or resignation in good standing was fully negotiable under Chapter 78 and was not violative of that act. N.J.S.A. 40A:10-21.2. ¶

Based upon the foregoing, we find there are no material facts in dispute and the PBA is entitled to relief as a matter of law. We further find the Township violated sections 5.4a(1) and (5) of the Act through its unilateral change to a past practice, by reducing from two months to one the duration of no-cost healthcare benefits provided to certain PBA members upon retirement or separation from employment in good standing, effective July 1, 2024. The Township is ordered to negotiate in good faith with the PBA over any changes to that practice. Pending the completion of such negotiations, our Designee’s interim order shall remain in full force and effect. ¶

OrderORDER ¶

Hamilton Township is ordered to: ¶

A. Cease and desist from: ¶

1. Interfering with, restraining or coercing employees in the exercise of the rights guaranteed to them by this Act, particularly by unilaterally altering its practice of providing two months of no-cost healthcare benefits to certain members of the PBA (Locals 66 and 66A) upon retirement or separation from employment in good standing; ¶

2. Refusing to negotiate in good faith with the PBA concerning terms and conditions of employment of employees in the affected units, particularly by unilaterally altering the Township’s practice of providing two months of no-cost healthcare benefits to certain PBA members upon retirement or separation from employment in good standing; ¶

B. Take the following actions: ¶

1. Negotiate in good faith with the PBA over any changes to its practice of providing two months of no-cost healthcare benefits to certain PBA members upon retirement or separation from employment in good standing; ¶

2. Post in all places where notices to employees are customarily posted, copies of the attached notice marked as Appendix “A.” Copies of such notice shall, after being signed by the Respondent’s authorized representative, be posted immediately and maintained by it for at least sixty (60) consecutive days. Reasonable steps shall be taken to ensure that such notices are not altered, defaced or covered by other materials. ¶

3. Notify the Chair of the Commission within twenty (20) days of receipt what steps the Respondent has taken to comply with this ORDER. ¶

BY ORDER OF THE COMMISSION ¶

Chair Hennessy-Shotter, Commissioners Eaton, Ford, Higgins, and Kushnir voted in favor of this decision. None opposed. Commissioner Papero recused himself. ¶

ISSUED: August 28, 2025 ¶

Trenton, New Jersey ¶

Notice to employeesWE WILL cease and desist from interfering with, restraining or coercing employees in the exercise of the rights guaranteed to them by this Act, particularly by unilaterally altering the Township’s practice of providing two months of no-cost healthcare benefits to certain members of the PBA (Locals 66 and 66A) upon retirement or separation from employment in good standing; WE WILL cease and desist from refusing to negotiate in good faith with the PBA concerning terms and conditions of employment of employees in the affected units, particularly by unilaterally altering the Township’s practice of providing two months of no-cost healthcare benefits to certain PBA members upon retirement or separation from employment in good standing; WE WILL negotiate in good faith with the PBA over any changes to the Township’s practice of providing two months of no-cost healthcare benefits to certain PBA members upon retirement or separation from employment in good standing. ¶

Note1/ These provisions prohibit public employers, their representatives or agents from: “(1) Interfering with, restraining or coercing employees in the exercise of the rights guaranteed to them by this act...(5) Refusing to negotiate in good faith with a majority representative of employees in an appropriate unit concerning terms and conditions of employment of employees in that unit, or refusing to process grievances presented by the majority representative...(7) Violating any of the rules and regulations established by the commission.” ¶

2/ The withdrawal of the 5.4a(7) claim is noted in PERC’s case management system, however the record does not contain an amended charge. ¶

3/ Monzo’s first certification was submitted in opposition to the PBA’s interim relief application. Monzo relies upon and incorporates it in her second. ¶

4/ The record does not contain a certification or affidavit from this former Personnel Director. ¶

5/ As it was not found in the record initially, the parties provided this undisputed information in response to a June 27, 2025, query from the Commission’s Case Manager. ¶

6/ The record contains no information indicating whether or to what extent non-police Township employees received free post-retirement health benefits, either pursuant to the Employee Handbook or because they qualified for a contribution exemption, during the 14~year period covered by the spreadsheet. ¶

Notice to employeesDocket No. CO-2024-193 Hamilton Township (Public Employer) Date: By: This Notice must remain posted for 60 consecutive days from the date of posting, and must not be altered, defaced or covered by any other material. If employees have any question concerning this Notice or compliance with its provisions, they may communicate directly with the Public Employment Relations Commission, 495 West State Street, PO Box 429, Trenton, NJ 08625-0429 (609) 292-9830 APPENDIX “A” ¶