On April 2, 2019, Google announced a minimum standard for wages and benefits for members of our provisioned (with systems and/or badge access) extended workforce (temps and vendors) in the United States. In order to be a supplier of Google’s extended workforce, this standard must be met and maintained. Suppliers were required to comply with the wage standard by January 1, 2020 and the benefits standard by January 1, 2022, at the latest.
Note: This standard will extend to similar members of Alphabet’s provisioned (with systems and/or badge access) extended workforce in the United States.
All members of Google’s provisioned extended workforce, working in the United States, should be paid $15/hour or more.
In locations where the minimum wage is more than $15/hour, we will expect that you comply with that higher requirement.
Compliance Date: January 1, 2020
To comply, Google suppliers must provide the minimum wages and benefits outlined in Google’s Wages and Benefits Standards to their employees who meet the following criteria:
| Alphabet Companies | These standards apply to Google’s U.S. based provisioned (with system and/or badge access) temps and vendors. These standards will be extended to Alphabet temps and vendors |
|---|---|
| Country | United States |
| Access | Provisioned with system and/or badge access to a Google operated building, excluding temporary badges |
| Employment Status |
|
| Exclusions | Employment Status
|
While the wages portion of this policy must be followed without adjustment, Google’s suppliers may include eligibility requirements to receive the benefits portion of this policy. However, those eligibility requirements should not exceed:
| Waiting period | 90 consecutive days on assignment at Google |
|---|---|
| Service requirement |
30 hours/week (average) on assignment at Google. Both "hours of service" and how such hours are averaged is to be determined according to the Affordable Care Act (ACA) definitions. All benefits listed should be available as soon as individuals meet eligibility requirements. |
Employers of our extended workforce are required to offer a healthcare plan that includes, at a minimum, the following essential health benefits.
- Required essential health benefits (each as defined under the ACA) include:
- Laboratory services
- Emergency services
- Prescription drugs
- Mental health and substance use disorder services
- Maternity and newborn care
- Pediatric services, including oral and vision care
- Rehabilitative and habilitative services and devices
- Ambulatory patient services
- Preventive and wellness services and chronic disease management
- Hospitalization
- The healthcare plan offered must be valued at the ACA’s Gold level or above, which generally means that the plan must provide a level of coverage that is designed to provide benefits that are actuarially equivalent to 80% of the full actuarial value of the benefits provided under the plan:
- 80% – Plan paid (employer contribution + employee payroll deduction)
- 20% – Employee out-of-pocket expenses
Cost to employees
The payroll deduction for:
- Employee-only coverage cannot exceed the federal poverty level safe harbor provision in the ACA to determine healthcare plan affordability. This rate changes annually and is adjusted by inflation.
- Dependent coverage cannot exceed 50% of the cost for that coverage.
Employer requirement
Employers may not take a pay or play penalty as allowed by the ACA in order to avoid providing a healthcare plan meeting these requirements.
While reference is made to the ACA, our requirement is not dependent on the applicability of the ACA to an employer. We use ACA references as generally accepted principles and definitions where applicable.
Eight fully paid sick days per year
- Flexible paid time off (PTO) can go towards meeting the requirement
- In locations where the state/local law minimum paid sick days is more than eight days per year, we will require that you meet that higher requirement
- All eight paid sick leaves must be available once they meet all eligibility requirements
12 weeks fully paid parental leave
Parental leave is inclusive of:
- Adoption leave
- Baby bonding
This applies to birth and adoptive parents.
Short-term disability leave for birth moms will be on top of the 12 weeks.
Short-term disability leave for birth moms will be on top of the 12 weeks.
$5,000 tax free tuition reimbursement per year
- Reimbursement should be used for career-related learning. Personal learning or hobbies should be excluded. If a supplier has internal learning management systems (e.g., skillbuilder) employees can use it to satisfy the requirement.
- If career-related learning is not available through internal resources, employees may leverage external resources that map back to a specific skill and have a guided curriculum by an instructor.
Six support sessions per year to include
- Remote/off-site services:
- 24-hour crisis telephone response
- Confidential assessment and counseling services
- Referral support, tracking, and follow-up
- Intervention/critical incident stress management
- On-site assistance will be provided in a timely fashion for emergencies, including critical incident stress or management (CISM) defusing and debriefing, and other crisis response needs management and employees, including:
- Substance abuse expertise
- Access to qualified EA clinical providers
- Dependent and domestic partner coverage
- Guaranteed confidential recordkeeping
FAQs
General Policy/Program
Is there someone I can have a conversation with at Google about these requirements?
We are a new supplier with Google and will need some time to comply with the policy. How can we seek an extension?
Healthcare
You can send an email to xws@google.com with a list of your questions and someone from our team will respond back.
How should I handle the increased costs associated with putting these benefits in place for applicable employees?
Google sees these benefits standards as an ongoing cost of doing business that will impact all suppliers who have employees with Google badge and/or systems access. We are raising the bar for the marketplace as it relates to how temp and vendor populations are treated by their employers as we see this as the right thing to do for the industry. We trust that you’ll manage the cost impacts of these benefits in a way that makes financial sense for your company based on how you operate. We encourage you to reach out to your Google Vendor Manager to discuss your concerns.
We don’t have any individuals working on assignment with Google with badge and/or systems access. Does this policy apply to my company?
Not at this time. However, if you have employees in the future who are granted badge and/or systems access, you will need to comply with this policy for those employees.
We have read the policy requirements and have determined that we are excluded from compliance. Do we need to apply for a waiver?
If you determine that your company is excluded from compliance, please reach out to xws@google.com with the reason for the exclusion. We will record your status and audit your company at a later date to certify your excluded status.
Please reach out to xws@google.com to initiate extension discussions.
Does the medical plan benefit that Google outlines have to be the only medical plan that my company offers?
Parental Leave
You may offer other plans in addition to one that meets the standard outlined by Google. Our requirement is that, at a minimum, you offer a plan that does not exceed the federal poverty level safe harbor provision in the ACA to determine healthcare plan affordability– it doesn't have to be the only option available to your employees.
Is there a Google defined approach to determine if a plan has an 80% actuarial value?
Suppliers may use an Actuarial Value calculation tool of their choosing to determine whether they satisfy the 80% AV minimum requirement. The 80% threshold must be satisfied, without any rounding or buffers. There are no other explicit requirements around the underlying claims data sources used, trend rates, or methodologies. The tool must use a normative database of claims that is representative of the range of utilization across the supplier's population, and modeled against the average plan design (i.e. AV cannot be based on the usage of person X alone).
Can suppliers include employer provided HSA funding in the actuarial value?
Plan design should take into account the average (not the maximum) employer's seed money into Health Savings Accounts or Health Reimbursement Accounts.
Does the ACA affordability maximum apply to dependents as well?
The dependent portion of the plan cannot exceed 50% of the total plan cost. For dependents, if the plan costs $1000, then the cost for the employee to cover his/her dependent must be less than $500. Also, using this example, the plan cost above for the employee + dependent, it would be the amount of the annual affordability maximum for the employee (for 2022 the amount is $103.14) + no more than $500 for the dependent. If the example is an employee + 2 kids, the cost in 2022 would be no more than $103.14 (employee) + no more than $500 (Child 1) +no more than $500 (Child 2).
Can suppliers require their employees to source healthcare insurance on the open market and reimburse them for the cost of the plan?
Yes. As an alternative to providing a healthcare insurance plan, suppliers can reimburse their employees for healthcare plans that they purchase in the open market as long as the plans align with the requirements of the ACA Gold Plan. The supplier would be responsible for ensuring that plans are purchased and maintained by their qualifying employees and that the plans align with the ACA Gold Plan.
Does the parental leave require that my company add 12 paid weeks of leave on top of my existing paid leave program?
Tuition Reimbursement
While short-term disability is in addition to the 12 weeks of “bonding” leave, if specifically allowed by (or at least not specifically disallowed based on) law, our parental leave requirement can run concurrently with any federal or state family leave. Moreover, your company will be responsible for making the individual whole, compensation-wise, for any delta between a state family leave benefit and an employee’s full pay. For example, if a state leave provides 80% for 8 weeks, your company would need to cover the additional 20% across those 8 weeks to get to the 100%, and would need to cover the additional 4 weeks at 100% to reach the total of 12 weeks -- the key being that all 12 weeks are paid at 100%.
If my employee is eligible for parental leave, per Google’s policy of 12 fully paid weeks of leave after working on a Google assignment for at least 90 days, are they also eligible for the additional 12 weeks that are available under CFRA (California) after working for the employer for 1 year?
If your employee has been working for your company on a Google account for at least 90 days, this policy requires that they receive full parental leave benefits, even if they are not eligible under California’s parental leave law. Once California’s parental leave law applies to your employee, then we expect that your company will cover any gaps that may exist to make the employee whole at 12 (total) fully paid weeks of parental leave.
Is this leave job protected?
The purpose of this leave is so that parents can have some assurance that they can take time off to care for a new baby without the added stress of losing their job or being demoted. We expect that individuals will not be released because they requested parental leave, or because the company was unable to find a temporary replacement for the worker requesting the leave. We expect that the individual will not be subject to lay offs while they are on leave as well.
Can we set up guidelines that include advanced notice of leave when possible?
Absolutely. We leave it up to the employer to determine what is a reasonable amount of notice, but we do ask for concessions to be made for emergency instances, (e.g. a baby that is born premature).
Can we implement a process outlining how an individual may request the tuition reimbursement and designate the types of courses that would qualify?
Enforcement
Yes. Employers can designate the types of courses that would qualify as “career related” as well as establish a policy for notification of intent and approval to take courses prior to enrollment.
If an employee has been working for me for more than 90 days, must I approve eligible courses for tuition reimbursement?
Not necessarily. Your employees will be eligible for tuition reimbursement if they have been working on the Google account for at least 90 days. Employees that have been with your company longer than 90 days must still wait until 90 days after they start on the Google account before they are eligible for tuition reimbursement.
Can we require an individual requesting tuition reimbursement to achieve a certain grade in the course and/or to pass the course?
Yes. Google requires that the individual have access to $5000 worth of career-based learning annually. The courses can be provided internally or externally if your company does not provide the career development courses and/or training. Suppliers can choose to require certain levels of achievement in order to receive the reimbursement.
Will suppliers in the program be audited against the policy requirements?
We plan to audit all suppliers for compliance with policy requirements. Our goal will be to ensure non-compliant suppliers understand the requirements and are positioned to come into compliance within a reasonable timeframe.