Nursing home workers with SEIU Healthcare MN & IA on a picket line in front of the Minnesota State Capitol in April.
In 2025, Cassandra Thomas and her coworkers at Chapel View Nursing Home in Hopkins, Minn., formed a union in order to improve pay and address what they say are consistently low-staffing issues that hurt both workers and the residents they care for. Speaking at a Minnesota Senate Labor Committee hearing in April, Thomas recalled seeing a very kind and friendly new face in the nursing home, urging workers to vote against the union. Later, Thomas and her coworkers learned this was a notorious union-busting consultant hired by the nursing home to urge the workers to vote against the union.
The union-busting campaign at Chapel View Nursing Home is not an isolated incident; it’s part of a much larger corporate strategy to hire outside union avoidance contractors, and according to new research, a federal reporting “loophole” is being used to underreport the scope of union-avoidance contracting. Due to ambiguous language and the absence of sufficient accountability mechanisms, researchers argue some companies do not comply with reporting requirements in order to obscure union avoidance activity.
Employers are supposed to report spending on outside union-avoidance consultants with the Office of Labor-Management Standards (OLMS), as decided by the Labor-Management Reporting and Disclosure Act (LMRDA) meant to facilitate transparency for both employers and unions during unionization campaigns.
However, researchers from the LaborLab determined that federal agencies’ report filings are riddled with discrepancies, and there also is a lack of adequate enforcement for companies that fail to file, or that underreport spending on union-avoidance contractors. Bosses take advantage of this permissive environment, researchers say, leading to a lack of transparency and accountability for union-busting campaigns across the country.
According to the LaborLab and SEIU Healthcare Minnesota and Iowa, there is reason to be concerned that the Chapel View Nursing Home is one such violator. On June 22, the groups submitted a complaint to OLMS requesting an investigation into Chapel View Nursing Home and the union-busting agency they contracted. The complaint, which was viewed by Workday Magazine, requests an investigation into “potential reporting non-compliance related to a persuader agreement between Augustana Chapel View Homes, Inc. and Government Resources Consultants of America (GRCA), to ensure that the rights of workers are protected.”
In October 2025, Chapel View Homes hired two anti-union consultants subcontracted by GRCA to counter an organizing drive by SEIU Healthcare Minnesota and Iowa. According to reports found in LM-10 forms required by OLMS, Chapel View ultimately reported paying $125,000 and hired at least two outside consultants to provide legal representation.
The complaint alleges that David J. Rittof identified himself as President of Modern Management, Inc. in the agreement, rather than President of GRCA, adding to confusion regarding the scope of each company’s work. Additionally, the report filing mentions “foregoing terms” without outlining or providing the terms referenced, a move that allegedly does not satisfy transparency requirements. The complaint states, “Workers covered by this campaign are being denied disclosure they are legally entitled to.” Additionally, the complaint alleges a discrepancy between paperwork filed by GRCA and Chapel View regarding the existence of a written agreement and whether Chapel View was contracting directly with GRCA or Modern Management.
In a statement, Angela Brown, Chief Human Human Resource Officer at Chapel View Nursing Home said, “We are aware of the complaint filed regarding federal reporting requirements. The issue raised relates to a document attachment associated with a filing. After receiving notification that clarification was needed, we reviewed the matter, identified an
administrative error in the uploaded documentation, and promptly submitted an amendment.”
But Teke Wiggin, a researcher with LaborLab, alleges that problems have persisted. “After we filed a complaint over Chapel View’s failure to disclose the full agreement, Chapel View has since appeared to use an accounting sleight of hand in order to avoid submitting the full agreement. Instead of submitting the full agreement, it has submitted an amended LM-10 form that now indicates there was no written agreement with GRCA or Modern Management, for that matter, only a verbal agreement,” he told Workday Magazine.
Wiggin continues, “But left unexplained is why Chapel View submitted the written agreement with Modern Management in the first place, why the agreement file was labeled ‘GRCA Agreement,’ rather than, say, ‘Modern Management Agreement,’ and what the relationship between Modern Management and GRCA is, given they share a President.”
According to a Department of Labor (DOL) spokesperson, “OLMS received an amended report correcting any identified errors on the employer’s Form LM-10. OLMS does not certify that this amended report is or is not deficient.”
Separate from the legal concerns, Wiggin raised ethical concerns about the resources spent on union avoidance. “Our upper estimate of the cost per worker of that anti-union campaign was about $2,800 which would have worked out to around a 7% to 8% raise for workers in a bargaining unit,” he says.
Chapel View Nursing Home disputed these numbers claiming that, based on the company’s analysis, “the comparable figure would be substantially lower.”
Wiggin expressed confidence in his figure and raised questions about Chapel View’s transparency. But, he argued, even if the company’s figures are correct, this is still a lot of money that could instead be going to improving workers’ wages. “Chapel View itself reported spending $125,342 on GRCA,” Wiggins wrote. “That cost alone – one of only several that Chapel View chose to incur by refusing to voluntarily recognize the union – is $853 per worker, equivalent to a 2.3% raise for the unit, assuming a $20/hr average wage and 35-hour work week.”
In June, Workday Magazine reported Chapel View’s record of receiving public funds from the state of Minnesota, and then using these funds to hire union busters, findings also based on a report by the LaborLab.
Brown from Chapel Hill Nursing Home insists, “With regard to the union organizing effort at Chapel View, our objective was straightforward: to ensure employees had access to accurate information so they could make their own informed decisions regarding representation.”
GRCA’s union-avoidance contracting work spans the country, with clients ranging from Amazon, Johns Hopkins Hospital, Hard Rock Casino, Cisco, Sunbelt Homes, and the Cleveland Museum of Natural History. LaborLab researchers found major discrepancies in OLMS forms filed by GRCA. In one example, Amazon reported $5 million in payments to GRCA in 2025 but GRCA itself reported more than $8 million in receipts from Amazon—leaving a $3 million plus discrepancy.
LaborLab researchers believe that this discrepancy is due, in part, to the lack of clarity around what constitutes consultants giving workers direct advice.
“In the law, it says that ‘advice to employers’ which is an ill-defined concept, is exempt from reporting requirements. It also says explicitly that indirect persuasion towards workers, not just direct persuasion, is reportable,” Wiggin explains. However, employers frequently mislabel indirect persuasion as advice to management, he says, a mislabeling that leads to failure to report indirect persuasion.
Additionally, according to Wiggin, there is an imbalance in consequences when it comes to penalties. “It’s extremely uncommon for OLMS to pursue criminal or civil penalties against a consultant, and not uncommon at all to do so with unions – even though consultants and employers have much, much, much worse LMRDA compliance,” he says.
According to LaborLab, workers who interacted directly with the consultant Dawn Chapman at Chapel View Homes, including workers who ultimately supported the union, reported that she was extremely kind, charismatic, and likable. In a Minnesota Senate Labor Committee hearing in April, Thomas states, “The lady was very nice. But I kept wondering, why was she on the floor talking to us? She kept saying bad stuff about the union. She said the union won’t work for us. She said that we will pay the union’s bills. I kept wondering, who is paying her bills?”
Wiggin stresses workers’ right to transparency regarding these consultants, and that workers’ right to know that what these consultants say to them during union-busting campaigns is not an organic, personally-held position by the employer, but rather “a formula that has been developed by industrial psychologists and strategists to show as much fear and doubt about the value of unionization as possible.”
“Just because professional union busters don’t use guns and clubs like the Pinkterons and the union-busters of yore, they should still be understood as morally reprehensible and impermissible in a democratic society,” Wiggin adds.
Wiggin and researchers at the LaborLab advocate for what they consider to be a more accurate interpretation of the LMRDA, where indirect persuasion is actually required to be reported under the law. The loophole was created in 1962, and it has been contested since then. However, a federal court upheld the loophole on the basis of attorney-client privilege as recently as 2016, and employers continue to get away with not reporting indirect persuasion to OLMS.
The LaborLab reports stress that this is not just administrative filing errors, but rather a fundamental threat to what constitutes free speech and transparency in workers’ fight to organize and bargain collectively. “The messages that you’re hearing from your employer, through supervisors, through flyers, these are not organic, earnest perspectives on unions.” Rather, he says, “they’ve been very carefully crafted by psychologists to manipulate you and that’s why the employer is spending thousands of dollars per worker to be able to deploy this playbook of tactics and messages that are meant to maximize fear and doubt.”
Workday Magazine also reached out to GRCA and Modern Management and did not receive a response by deadline.